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Question 1: Solvent Emission Directive
In the document 'Guidance on solvent emissions for
chlorinated solvent users it states "Industrial sectors whose
solvent consumption is above the thresholds set by the SED will
have to reduce their emissions in order to match the emissions
limits. ... if the flow rate is above 100 g/hr the maximum
allowable concentration is set at 20 mg/cubic m. .... this drops to
2 mg/cubic m if flow rate is above 10 g/h ..."my question is what
flow rate is being measured and how?
Article 5(7) specifies for all VOC compounds
classified as CMR, independent from the section of use given in
Annex IIA, that the emission limit value to comply with is 2
mg/m3 (and not 20 mg/m3 as given in Annex IIA
(4)), if the mass flow is above 10 g/h. This means that for the use
of a CMR in surface cleaning the emission limit is
20mg/Nm3 if the mass flow is below 10g/h and drops to 2
mg/Nm3 if the mass flow is equal or above
10g/h.
Article 5(8) specifies the conditions for
halogenated R40 substances independent from the section of uses of
Annex IIA. It states that the emission limit value to comply with
is 20 mg/Nm3, if the mass flow (measure as solvent ) is
above 100 g/h. Since Annex IIA (4) also states 20 mg/m3
as emission limit however independent from the mass flow this means
that for a halogenated VOC substance used in surface cleaning the
emission limit of 20 mg/Nm3 needs to be respected in all
cases.
The mass flow is determined by measuring the air flow in
Nm3/h and the concentration in g/Nm3. Multiplication
gives the mass flow in g/Nm3.
