Pollution Prevention and Control (PPC) Sector Permitting Plan - Chemicals


1. Objectives
1


• This ‘Sector Permitting Plan’ (SPP) is one of a series that identifies key sectoral environmental issues. It
aims to give operators in the Chemicals sector a steer on the priority that we give to the various aspects
of Pollution Prevention and Control (PPC) and so will be of value in the preparation of PPC applications.
• SPPs will be used by our permitting teams to focus industry efforts towards producing environmental
improvements and preventing harm to human health, through the PPC permits. They will also inform the
drafting of our PPC guidance notes and will, in turn, advise staff of the issues they must address with
particular care during application determination and compliance assessment.
• Through our Chemical Strategy we are giving increasing consideration to priority substances that may
have adverse environmental impact. Since PPC is an important vehicle for collecting information and
effecting improvements, the SPP also identifies these priority substances.

• The SPP is aimed at the practicalities of PPC and is distinct from our Chemicals ‘Sector Plan’ which will
provide medium-term, strategic coverage of a broader range of environmental issues.
• Reissue
2
of the SPP is timed to coincide with the 2005 application window, but the SPP is written
generically and will be useful in the preparation of any Chapter 4 PPC application.

2. Introduction

Chemicals is one of the largest sectors covered by the Pollution Prevention and Control (PPC) Regulations
2000 (SI 2000/1973) and will be regulated predominantly by the Environment Agency. Operators of

installations will need to apply for new integrated environmental permits in six application windows:

1 1 January to 31
March 2003
Organic chemicals 4.1 (A) (a)(i), (a)(v), (a)(vi), (a)(vii), (b), (f), (g)
2 1 June to 31
August 2003
Organic chemicals 4.1(A) (a)(ii), (a)(iii), (a)(iv)
3 1 October to 31
December 2004
Inorganic chemicals – 4.2 (A) (a)(i), (a)(ii), (a)(iii), (a)(vi), (b), (c), (d), (e), (f), (g), (h), (i), (j)
Manufacturing activities involving carbon disulphide or ammonia
4 1 June to 31
August 2005
Inorganic chemicals – 4.2 (A) (a)(iv), (a)(v)
Chemical fertiliser production
5 1 January to 31
March 2006
Organic chemicals – 4.1 (A) (a)(viii), (a)(ix), (c), (d), (e)
Plant health products & biocides
Pharmaceutical production
Explosives production
6 1 June to 31
August 2006
Organic chemicals – 4.1(A) (a)(x), (a)(xi)

Applications must set out how operators propose to operate; what emissions and effects are likely as a result
of their proposals; and how they will apply Best Available Techniques (BAT) in order to prevent and, where
that is not practicable, generally to reduce emissions and the impact on the environment as a whole. PPC
applications represent a substantial challenge for both industry and us in terms of the resources to make and

determine them. Following the SPP will help ensure that those resources are targeted.


1
For further information on this Sector Permitting Plan contact: Alex Radway – Policy Advisor, Industry Regulation.
Tel. 01925 542342. Email:

2
The SPP supersedes the same-titled version dated May 2004, which in turn replaced the ‘Advice Note – PPC
Implementation Plan for the Organic Chemical Sector’ (October 2002).
PPC Sector Permitting Plan - Chemicals Page Version 2 (April 2005)
1
3. Status of Technical Guidance

The following UK and European technical guidance is currently available and is provided on the Sector CD
3
:


UK PPC Guidance (issue date or status)
(ironment-
agency.gov.uk/business/444217/444663/298441/)
European BREF (issue date or status)
(
Organic
chemicals
• S4.01 Large Volume Organic Chemicals (April
2003)
• S4.02 Speciality Organic Chemicals (April 2003)
• Large Volume Organic Chemicals (Feb 2003)

•
Organic Fine Chemicals (Draft 2)
• Polymers (Draft 1)
Inorganic
chemicals
• S4.03 Inorganic Chemicals (Consultation draft) • ChlorAlkali (Dec 2001)
•
Large Volume Inorganic Chemicals -
Ammonia, Acids & Fertilisers
(Draft 2)
•
Large Volume Inorganic Chemicals - Solid &
Others (Draft 1)
•
Speciality inorganic chemicals (Draft 1)
Other
• H1: Environmental Assessment and BAT
Appraisal (July 2003)
• H2 : Energy Efficiency (Feb 2002)
• H3 : Noise (Sept 2002)
• H4 : Odour (Oct 2002)
• H7 : Protection of Land - Application Site
Report and Site Protection & Monitoring
Programme (Aug 2003)
• H8: Protection of Land - Surrender Site Report
& Template (Consultation draft June 2004)

• Common waste water and waste gas treatment
and management systems in the chemical
sector

(Feb 2003)
•
Emissions from storage of bulk or dangerous
materials
(Jan 2005)
• Economic and cross media issues under IPPC
(Final Draft)


4. Considerations for PPC applications and determinations

The SPP identifies those elements
4
of the PPC application process that are sufficiently important to be
considered in detail in each chemical sector application, and those that only need detailed consideration
where there is a clearly identifiable local issue. We will concentrate our determination on the important
issues for the sector, using improvement conditions where appropriate.

4.1 Operational Techniques and In-Process Controls (Priority: High)

Operators currently authorised under IPC should use the PPC application to demonstrate that operating
conditions, even for the same plant, remain appropriate. This should include reference to any developments
in techniques that have occurred since the IPC authorisation was granted.

The sector commonly uses stirred tank reactors to produce batch products. This technology may not have
been reviewed for many years and PPC provides an opportunity to ensure that the techniques in use remain
appropriate. Consideration should be given to newer techniques involving small, low-inventory ‘fast’
reactors that have the potential to achieve better yields whilst generating considerably lower quantities of
wastes. Individual fast reactors are usually custom-built for each reaction in order to optimise reaction
specificity and maximise yields. They may appear to offer less flexibility than conventional reactor systems

but in many cases the equipment is so small that individual pieces can be constructed cheaply and installed
easily whenever a reaction change is required. Optimisation of reaction conditions and the reduced need for
separation, purification and waste treatment or disposal may balance the economics when compared to
conventional batch-reactor systems, whilst having the potential for marked environmental benefits.
Accordingly, operators who wish to use conventional stirred-tank reactors should demonstrate in the PPC
application how their systems compare with newer techniques.


3
IPPC Chemicals Regulatory Package (available by emailing )
4
The PPC elements are dealt with in a similar order to that in our template PPC application.

2
Current ‘envelope’ authorisations will be re-examined to ensure that they are still appropriate and represent
BAT. In practice the plant may be over-designed for many of the reactions so that it accommodates the full
range of operational conditions. The extra cost of this being offset against the commercial advantage the
operator may secure through increased flexibility. If plant usage evolves into a single product then it must be
optimised to ensure that it uses BAT to produce that product. Multi-product permits should not be seen as an
option for less than adequate operation. If anything the standards should be higher to reflect the foreseen
operational variability. The Multi-Product Protocol (MPP) is provided on the Sector CD and should be used
where an applicant is only able to identify a baseline list of products and a range of chemistry, rather than a
definitive list of specified products. Applicants should consider with care the wording of any MPP as it will
form part of the PPC Permit.

4.2 Emissions

Annex 1 gives Pollution Inventory (PI) data for 2003 and shows the chemical sector’s contribution to the
overall emissions to air, controlled waters and sewer from IPC / PPC regulated industry. The analysis also
indicates which installations have a significant (>10%) contribution to the total release. This analysis is

useful for contextualising the sector’s emissions and identifying key pollutants. We will need to consider
circumstances where local environmental standards are threatened and the extent to which this is the result of
operations within this sector.

We are giving increasing prominence to environmental ‘performance indicators’ as complements to
traditional emission limits. Emission data can be normalised for the scale of process operation and/or
environmental burden to generate performance data that are valuable in targeting regulatory effort at the
most important environmental issues. Performance indicators can address not only emissions (to air, water
and waste) but also raw material use (including water and energy). Applicants should give consideration to
appropriate performance indicators for their installation, whilst avoiding claims for commercial
confidentiality on product volumes.

4.2.1 Emissions to Air (Priority: High)

Although significant reductions have been made by the sector in recent years, emissions to air remain a
significant issue for some sites. The following conclusions can be drawn from the PI data at Annex 1.1:

• The chemical sector is a significant source (>10%) for the release to air of 83 substances.
• For 26 substances the chemical sector is responsible for 100% of the release. In 12 of these 26 cases the
100% contribution came from a single chemical installation.
• Of those air pollutants subject to the UK Air Quality Strategy
5
the chemical sector is a significant source
(>10%) for 1,3 butadiene (85%), benzene (18%), lead (17%) and carbon monoxide (11%).
• The sector is a small contributor to the national emissions of nitrogen oxides, sulphur dioxide and PM
10
.
• The 4th Air Quality Daughter Directive (2004/107/EC) sets ambient air quality ‘target values’ for arsenic
(6 ng/m
3

), cadmium (5 ng/m
3
), nickel (20 ng/m
3
) and benzo(a)pyrene (1 ng/m
3
). The chemical sector
does not make a significant contribution to the national emissions of these substances.

Where installations make a significant contribution to the exceedance of an air quality objective, or breach of
an EU limit value, or the emission forms a significant part of the Pollution Inventory total, we expect PPC
applications to include emission reduction plans.

In some chemical production activities fugitive, or diffuse, emissions may be more significant than point
source emissions. Activities that often give rise to such releases including the loading and unloading of
materials into transport containers and spillage or unplanned events on site. It has been recognised that, for
part of the chemical sector, fugitive releases are an issue and we will work with the industry to secure
improvements. Initially we will be looking for better quantification of fugitive releases, followed by specific
actions to secure reductions.


5
The Government's Expert Panel on Air quality Standards (EPAQS) is developing ambient air quality guidelines for a
number of halides (HCl, HF, HBr, HI, Cl and Br) and consultation is expected in 2005.
PPC Sector Permitting Plan - Chemicals Page Version 2 (April 2005)
3
Our forthcoming Sector Plan for the Chemical Industry will include a number of environmental performance
indicators and these identify important air emission priorities for the sector, including:

• Volatile Organic Compounds: emissions from the sector represent 44% of the total from all regulated

processes
• Ozone Depletion Potential (ODP) - includes releases of carbon tetrachloride, hydrochlorofluorocarbons
(HCFCs), chlorofluorocarbons (CFCs), methyl bromide, methyl chloroform and halons. We have been
directed by Defra to effect the Ozone Depleting Substances (ODS) Regulations (SI 528 of 2002) and the
determination of PPC applications should consider the containment, use and destruction of ODS.
• Photochemical Ozone Creation Potential (POCP) - includes releases of benzene, carbon monoxide and
1,3 butadiene.
• Global Warming Potential (GWP) – nitrous oxide’s GWP of 310 makes it a high priority to control the
emissions from nitric acid, fertilisers and nylon production. Also includes emissions of
hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs).
• Carcinogens, Mutagens and human Reproductive toxins (CMR)
• Substances that are Persistent, Bioaccumulative and Toxic (PBT) and very Persistent, Bioaccumulative
and Toxic (vPBT)
• Acidification gases
• Phase-out date for chlor-alkali production by mercury cells.

4.2.2 Solvents Emissions Directive (Priority: Medium)

The aims of the Solvent Emissions Directive (SED) are to prevent or reduce the direct and indirect effects of
emissions of volatile organic compounds (VOCs) on the environment and the potential risks to human
health. To achieve these objectives, SED requires certain measures and procedures to be implemented for
defined activities operated above specified solvent consumption thresholds.

The main defined activity for this Sector is the manufacture of pharmaceutical products (where solvent
consumption exceeds 50 tonnes/year). Although not directly applicable to other chemical activities, SED also
provides a wider benchmark for sector performance.

For substances or preparations containing VOCs, which are carcinogenic, mutagenic or toxic to
reproduction, there is a requirement to use less harmful substitutes within the shortest possible time. For
other VOCs there is a requirement to meet either emission limit values or total emission limit values, or,

alternatively, to implement a solvent reduction plan with the equivalent effect.

All new SED installations must comply with SED before operations start and this will be achieved through
the PPC permitting process. Existing SED installations must achieve full compliance with the Directive by
31 October 2007. The definition of ‘existing installation’ includes SED installations where a valid
application under IPC or PPC was made before 1 April 2001, provided that the SED installation was put into
operation by 1 April 2002. A substantial change at an existing SED installation can require partial or full
compliance with SED for the part of the SED installation that undergoes the substantial change.

Partial compliance with regard to substitution and emission limits for some potentially more harmful VOCs
is required for existing SED installations within “the shortest possible time” after the date SED came into
force (1 April 2001). Defra required plans for substitution to be submitted to us by 31 October 2003 for
existing and currently regulated installations. For existing installations not currently regulated, the company
will be required to comply when they make their application under PPC.

With respect to the transition from IPC to PPC, SED requirements will only be incorporated when more
harmful risk phrase substances are being used. Otherwise it is not intended to incorporate SED requirements
ahead of the 2007 deadline for PPC implementation.





4
4.2.3 Emissions to Controlled Waters (Priority: High)

Some significant reductions have been made by the sector in recent years, but emissions to controlled waters
remain an issue for many sites. The following conclusions can be drawn from the analysis of Pollution
Inventory data at Annex 1.2:


• The chemical sector was a significant source (>10%) for the release to water of 35 substances.
• For 10 substances the chemical sector was responsible for 100% of the release. In 8 of these 10 cases the
100% contribution came from a single chemical installation.
• Of those pollutants subject to water quality standards, the chemical sector was a significant source
(>10%) for: benzene (92%), toluene (83%), phenols (81%), mercury (80%), xylene (76%), cadmium
(49%), carbon tetrachloride (47%) and arsenic (26%).

Our forthcoming Sector Plan for the Chemical Industry will include a number of environmental performance
indicators and these identify important air emission priorities for the sector, including:

• Chemical Oxygen Demand of releases
• Eutrophication potential - phosphorus and nitrogen
• Releases of substances for which the chemical sector is a major source of UK industrial releases -
namely; arsenic, pentachlorophenol, mercury, cadmium, chromium, chloroform, PCBs, octyl and nonyl
phenols, 1,2 dichloroethane
• Eco-toxicity to aquatic life – through Direct Toxicity Assessment (DTA) we are increasingly interested
in assessing the actual environmental impact of aqueous discharges (see section 4.9.2).
• Acidification potential
• Substances that are Persistent, Bioaccumulative and Toxic (PBT) and very Persistent, Bioaccumulative
and Toxic (vPBT) – the key pollutants are recalcitrant organics and the List I and II Dangerous
Substances (see Annex 2).

The Dangerous Substances Directive (DSD)
6
requires the prior authorisation of effluents liable to contain
Dangerous Substances – see Annex 4.2. This was not considered with sufficient rigour during the
introduction of IPC and should be properly delivered through PPC.

Where sites make a significant emission of a pollutant with a Water Quality Standard or a significant
contribution to the Pollution Inventory total, we expect the PPC application to include plans for the reduction

of emissions. We will examine all significant releases to water and in particular will be looking for an
assessment of Dangerous Substance releases.

4.2.4 Emissions to Sewer (Priority: Low)

Emissions to sewer are not a general issue for the sector but may be locally important. Where applicable,
Applicants should demonstrate that the treatment provided by an off-site sewage works represents BAT for
the effluent constituents (especially recalcitrant organics) and not just coincidental removal or dilution. The
following conclusions can be drawn from the Pollution Inventory data at Annex 1.3:

• The chemical sector was a significant source (>10%) for the release to sewer of 50 substances.
• For 10 substances, the chemical sector was responsible for 100% of the release. In 6 of these 10 cases the
100% contribution came from a single chemical installation.

4.2.5 Emissions to Land or Groundwater (Priority: High)

PPC activities should not usually allow releases to land or groundwater, or result in the deterioration of land
condition. The direct discharge of effluents to groundwater is not a widespread issue within the sector
although many sites show evidence of ground / ground water contamination as a result of historical site

6
The Dangerous Substances Directive will be repealed in 2013 and will be eventually replaced by the Water
Framework Directive (with transitional arrangements for the interim period). Member States will have to ensure that
any existing controls under 76/464/EEC (or daughter directives) are maintained / replaced to ensure no deterioration.
PPC Sector Permitting Plan - Chemicals Page Version 2 (April 2005)
5
activities. Older sites with poorly characterised drainage systems may represent a potential risk to
groundwater.

Applicants should use the Site Protection and Monitoring Programme (SPMP) to define robust pollution

prevention measures, in particular integrity testing and environmental management systems. The SPMP
should consider the need for ongoing groundwater monitoring. Where there is a reasonable possibility of
current or future pollution arising from substances in use or produced, or likely to be, reference data (which
may include intrusive investigations) will be required. Since SPMPs need to be agreed within two months of
the Permit issue, Applicants may find it advantageous to submit a draft SPMP with their application.

4.3 Management Issues (Priority: Medium)

Overall the chemical sector seems to be well run and has a history of structured environmental management.
The sector has a good understanding of legislative requirements having been subject to Integrated Pollution
Control (IPC) for a decade and COMAH since 1999. Our ‘Spotlight Report 2002’ notes that the sector has a
good record on environmental improvements and spends more than any other heavy industry on
environmental protection measures (£628 million in 2000).

Scores under our Operator and Pollution Risk Appraisal (OPRA) schemes indicate that Operator
Performance is generally good and processes are well managed compared with other industry sectors. The
Pollution Hazard element of OPRA scores gives more hazardous ratings when compared with other sectors,
and this reflects the nature and inventory of chemicals present on sites. Operators are encouraged to seek
performance improvements to improve further their OPRA scores.

Generally the sector makes sophisticated products, often of high value, which may demand high
specification product and close operational control. Through the Chemical Industries Association (CIA) the
industry has developed the Responsible Care Management System (RCMS) and this is being enhanced to
include external verification. There is an opportunity to reward this initiative by building it into our
regulatory systems for PPC (e.g. OPRA assessment). We will recognise externally verified RCMS when
demonstrably equivalent to either ISO 14001 or EMAS.

4.4 Raw materials (Priority: High)

Our experience of the sector suggests that not all operators are driven to minimise the use of raw materials,

including water and energy. This may be attributable to process reasons (e.g. reaction yields were the main
driver and excess raw materials were used). Changing a raw material, or reducing its use to the
stoichiometric quantity, is often difficult as third party approvals may have to be gained, or equipment /
operating conditions changed. The scale of investment in chemical plant is often very large but the scope for
plant changes may be small. Minimisation of raw materials may also be hindered by lack of financial
incentive (e.g. where the raw material has a low value when compared to the final product).

Under PPC, applicants should consider whether their chosen production techniques minimise raw material
use and whether the cycles of plant investment / renewal offer opportunities for the adoption of new, more
efficient processes. We will include appropriate improvement conditions where there is scope for improved
efficiency (and hence reduced waste generation).

We are increasingly interested in the use, in raw materials, of a number of priority substances – as described
in section 4.13.

4.5 Waste minimisation and selection of disposal option (Priority: High)

When determining the conditions of a PPC permit, we need to take account of the requirement that
installations are operated so as to prevent or reduce waste production. Where waste is produced, the IPPC
directive says that it is to be recovered unless ‘technically and economically impossible’. If waste is to be
disposed of, either by the operator or via a waste management company, the operator must ensure that the
chosen disposal option avoids, or reduces, any impact on the environment. These obligations are over and
above those to use Best Available Techniques to avoid causing pollution. However a factor to be considered

6
when determining BAT is “the use of low waste technology”. Waste minimisation, and selecting the best
environmental waste disposal option, are therefore of primary consideration in the PPC permitting process.

In addition to the above overarching obligations, there are a number of specific obligations and controls that
operators have to be aware of regarding the landfilling of waste. These are:


• The ban on the co-disposal of hazardous and non-hazardous waste
• The need to pre-treat waste destined for landfill
• The wider definition of ‘hazardous’ wastes as compared to ‘special’ waste
7

• The need for any landfilled waste to meet certain waste acceptance criteria (WAC)
• The ban on the landfilling of liquid wastes
• The relatively small number of merchant landfills permitted to accept hazardous wastes
• Recent EU case law which may re-classify by-products and co-products as ‘waste’.

The chemical sector is a major producer of waste, including hazardous waste. The main hazardous waste
streams for the sector are expected to include - spent catalyst, process residues (heavy ends, sludges), spent
solvents, effluent treatment sludges (including filter cakes), contaminated soils and oily sludges. Arisings
have reduced in recent years and the CIA has targeted a further 25% reduction between 2000 and 2010.
Applicants should demonstrate how hazardous waste arisings will be treated / disposed through in-house or
third-party facilities.

4.6 Energy Efficiency (Priority: Medium)

Generally the chemical industry uses a lot of energy and this is often the major source of emissions for the
sector (even if the actual release may be elsewhere and from a third-party energy supplier).

Many companies in the chemical sector have signed an agreement (via their trade association) with the
Secretary of State under the provisions of the Climate Change Levy Agreement (CCLA). Under current
advice from Government, our role in energy efficiency for companies with a CCLA is limited to basic
energy conservation measures. These companies are required to deposit a copy of their plans with us, and
their management system need to provide for proper consideration of the energy used, that operating
conditions are optimised and equipment is maintained in good condition.


If there is no CCL Agreement in place, then a full assessment of energy requirements is necessary.

Where operators are participating in the national Emissions Trading Scheme (ETS), the ETS Regulations (SI
2003 No.3311) have amended the PPC Regulations by adding a new PPC regulation 12(8A). This states that
the PPC permit shall not include an "emission limit value, equivalent parameter or technical measure", in
respect of emissions of pollutants covered by conditions of the Operator's ETS permit, unless we consider
them necessary to prevent significant local pollution. The ETS Regulations currently only apply to carbon
dioxide emissions, although there is a future intention to extend to other greenhouse gases.

4.7 Accident Prevention and Control (Priority: Medium)

Many chemical installations will be covered by the requirements of the Control of Major Accident Hazards
(COMAH) Regulations 1999. COMAH is enforced in England and Wales by the Health and Safety
Executive (HSE) and us acting as a joint Competent Authority.

We consider COMAH, where available, to be the most appropriate legislation to regulate major accident
prevention and control. COMAH requires the operator to use all measures necessary to prevent major
accidents and limit their consequences to persons and the environment. Our view is that “all measures
necessary” requires the application of BAT as a minimum.

For top tier COMAH installations we will assess control of environmental major accident hazards during the
safety report assessment process and by inspection.

7
For further information see www.environment-agency.gov.uk/subjects/waste/232021/799638/799655/?version=1&lang=_e
PPC Sector Permitting Plan - Chemicals Page Version 2 (April 2005)
7

For lower tier COMAH installations there is no safety report assessment process. We will assess control of
environmental major accident hazards by inspection. However, for COMAH sites PPC applications should

include a summary of accident prevention and control arrangements with a clear indication of how measures
have been extended to those aspects that are not regulated under COMAH (i.e. minor accidents such as
spillages). Sites not subject to COMAH should follow the PPC application guidance.

4.8 Noise and Vibration (Priority: Low)

Noise and vibration nuisances are not a general issue for the chemical sector. However, particular
consideration should be given where local concerns have been raised.

4.9 Monitoring of emissions

4.9.1 Data Quality (Priority: High)

The results of monitoring are increasingly being placed on national and international databases, and used as a
guide to regulation. This will require stronger emphasis on the quality and quantity of monitoring data.

Monitoring was addressed with some variability in IPC authorisations. The transfer to PPC is an opportunity
to rationalise monitoring requirements and to reduce variability between permits. Close attention will be paid
to 12(9)(e) of the PPC Regulations that states that a permit shall include conditions: “setting out suitable
emissions monitoring requirements, specifying the measurement methodology and frequency and the
evaluation procedure, and ensuring that the operator supplies the regulator with data required to check
compliance with the permit”.

We intend that, compared with IPC authorisations, PPC permits for the chemical sector will include fewer,
better specified, emission limits and monitoring requirements. Where a release justifies the inclusion of a
release limit, then it also warrants monitoring to recognised standards. It is important that all monitoring
required by a permit uses test methods and equipment that produce meaningful and accurate data. The use of
certified schemes, such as MCERTS, are likely to be required where available.

4.9.2 Direct Toxicity Assessment (DTA) (Priority: High)


DTA is a method for testing whole samples of liquid discharges for their effect on aquatic organisms. This is
conducted in accordance with well-defined procedures, set out in detailed technical guidance
8
.

DTA can establish the potential impact of a discharge without requiring a detailed knowledge of its chemical
composition. As such DTA can be used to supplement chemical specific assessments to account for the
effects of substances which might otherwise go undetected, or may provide an alternative to chemical
specific assessment when there is insufficient ecotoxicological data on the chemicals concerned.

DTA is an essential component of the environmental assessment (such as H1) and BAT appraisal. We expect
DTA for all effluent discharges, unless they are smaller than 100 m
3
/day, or the effluent is 'simple', or the
discharge is to a sewage treatment works. A ‘simple’ effluent is one where all components have been fully
speciated by chemical analysis and where the toxicity of the effluent can be explained by the chemical
properties of the components. Very few effluent streams would be currently categorised as ‘simple’.

4.10 Decommissioning and Surrender Planning (Priority: Medium)

For many chemical installations this is an issue that will not have been considered before but it has the
potential to be significant. Particular attention should be given to the objectives of pollution prevention and
site condition monitoring associated with the new ‘Policy for the Protection of Land under PPC’.


8
UK Direct Toxicity Assessment (DTA) Demonstration Programme: Technical Guidance - Addressing Water Quality
Problems in Catchments where Acute Toxicity is an Issue (Report No. 00/TX/02/07)


8
4.11 Installation Issues

4.11.1 Multi-Operator Installations (Priority: Medium)

The law requires that the whole installation is operated using BAT not just the segments covered by
individual permits. We require that, when applications are made, the responsibilities of each operator are
clearly defined. It is particularly important that all operators of parts of an installation (including direct
service providers such as pumping stations / waste treatment etc but not general utility services) have made
applications. This is often very relevant to chemical installations.

4.11.2 Confidentiality (Priority: Medium)

Claims for confidentiality under PPC will be re-examined to see that they are not simply carried over from
previous regimes. The aim should be to limit to an absolute minimum the information required to be kept
confidential. Applicants should present information in such a way that confidentiality will not be
compromised and that exclusion from the public registers is not required.

4.12
Impact

4.12.1 Conservation Considerations (Priority: Medium)

Applicants should consider whether the installation, either alone or in combination with emissions from other
sources, could adversely affect the integrity of any site designated as a ‘Natura 2000’ site under the Habitats
Regulations, or damage the special features of any Site of Special Scientific Interest (SSSI) regulated under
the CROW (Countryside and Rights of Way) Act. We have agreed with the Conservation Agencies a
screening mechanism for the chemicals sector that identifies a list of priority sites / substances and so
reduces the number of applications requiring a full assessment under the Habitats Directive. Our permitting
officers will consult this list to ensure that the appropriate assessment is carried out.


4.12.2 Human Health (Priority: Medium)

Protection of human health is an essential requirement of PPC. Companies must consider the potential
effects on human health of their permitted activities. This can be an emotive issue and in some sectors is the
major cause of protracted and resource-intensive permitting. In those sectors, Applicants should be
encouraged to engage with Primary Care Trusts / Local Health Boards at the earliest opportunity to ensure
that the application addresses their concerns.

4.13 Chemicals Strategy (Priority: High)

Our ‘Chemicals Strategy’ (Managing Chemicals for a Better Environment)
9
aims to focus controls on those
chemicals that may affect the environment or human health through environmental exposure. Such controls
will target points in chemical life cycles that provide the most effective and efficient outcomes.

There have been, and are, many initiatives to improve our understanding of chemicals and how they are
managed. Outlined below are summaries of some of these initiatives and the priority chemicals that they
have identified to date. We lack good information about the use and release of many of these substances, and
so PPC is an important delivery mechanism for both improving our understanding and effecting change. It is
envisaged that for substances listed in Annex 3 we will use PPC as follows:

• PPC applications should provide the fullest possible information on the use, release and potential release
of the listed substances.
• Where the PPC application or determination identifies information gaps, Permit improvement conditions
may be used to gather additional information on use, release and potential release of the substances.
• On the basis of information provided by the PPC permitting process, the relevance of releases can be
assessed and further actions prioritised (maybe via Permit improvement conditions).


9
See />PPC Sector Permitting Plan - Chemicals Page Version 2 (April 2005)
9

4.13.1 Current controls on substances


EU Review under the Existing Substances Regulation (ESR): The EU is reviewing the environmental and
human health risks for limited numbers of chemicals that are used inside the EU in significant quantities. In
some cases no risks have been identified, in other cases risks have been identified for human health and/or
the environment. A risk reduction strategy is then required to address the risks identified, and this can
include tightening controls under existing mechanisms, such as PPC, or restrictions on the marketing and use
of substances. Annex 3.1 lists those substances where, based on the EU risk assessment, an environmental
risk or a need for further information has been identified and where in our opinion the assessment is relevant
to PPC installations. For some substances a Risk Reduction Strategy has now been published in the Official
Journal of the EU.

PPC applicants using these substances should review the nature of the risk in the risk assessment
10
and
consider whether that risk might potentially arise from their installation. If the risk is possible, then site
specific risks should be clarified by identifying potential releases and estimating environmental levels, and
then comparing this with the appropriate Predicted No Effect Concentration (PNEC) in the risk assessment
.
Further background information can be found on the EU website
11
.

Marketing & Use Restrictions: Following identification of environmental, or health risks, restrictions on
the marketing and use of the chemical may have been selected as an appropriate part of a risk reduction

strategy. The controls can vary from a complete ban, to restrictions in certain applications. Annex 3.2 lists
the current Marketing & Use Restrictions
12
. Where appropriate, applicants should ensure they comply.

Water Framework Directive (WFD) (2000/60/EC): The WFD aims at enhanced protection and
improvement of the aquatic environment through a variety of measures. The WFD requires ‘Priority
Substances’ to be identified in accordance with Article 16(2), and listed under Annex X, and requires
specific measures for the progressive reduction of discharges, emissions and losses
13
. Amongst the Priority
Substances are the ‘Priority Hazardous Substances’ which, by virtue of their toxicity, persistence and
liability to bio-accumulate, the WFD requires the additional aim of cessation or phasing out of discharges,
emissions and losses (see Annex 3.3).

PPC applicants should consider the use, and generation, of Priority Hazardous Substances in / by their
installations and address the WFD requirements of aiming to cease and phase out releases to water and
releases to other environmental medium where such a release may impact on water.

4.13.2 Anticipated future developments

REACH - Registration, Evaluation and Authorisation of Chemicals, is a new and more comprehensive
regulatory regime covering manufacture rather than just marketing and use, that will replace existing,
separate pieces of chemical legislation. The REACH system is expected to come into force in a phased
manner in 2007 and will involve:

(i) registration of basic information on all substances exceeding a production volume of 1 tonne / year
(ii) evaluation by the authorities of substances exceeding a production volume of 100 tonne / year, and
those of lower tonnage where concern exists.
(iii) authorisation of substances with properties that give rise to very high concern, where specific

permission will have to be given before they can be used.
Chemical Stakeholders Forum (List of Chemicals of Concern): In 1997, as a result of concerns about the
effect of chemicals on the environment and human health and a lack of information about some effects, the

10
/>11
Additional background information and details of the risk reduction strategy for some chemicals can be found at:
/>12
A consolidated version of the directive with details of the extent of the restrictions applied can be found at:

13
An Article 16 Daughter Directive is under development and may introduce EU environmental quality standards for
Priority Substances together with emission control measures. A proposal is expected in late 2005.

10
Government launched a review of its policies on chemicals. A main outcome of the review was creation of
the UK Chemicals Stakeholder Forum (CSF) to advise the Government on reducing the risks from industrial
chemicals to the environment and to human health via the environment.

The CSF has set out criteria to flag up which chemicals are of concern on the basis of their hazard properties.
Laboratory tests for these criteria can give an indication of the extent to which a chemical is toxic; if it lasts a
long time in the environment (persistence); and accumulates in living organisms (bioaccumulation). These
tests cannot give a definitive picture of whether the chemical poses a risk, as it depends on the way the
chemical is used and whether there is exposure to humans or the environment.

The CSF has produced a list
14
of high production volume chemicals (> 1000 tonnes per year) which are used
in the UK and which meet their criteria for concern on the basis of current information. The list is intended to
raise questions and invite input, and so a chemical’s presence on the list does

not mean that it is banned, or
will be banned or restricted in the future. Even if a chemical has hazardous properties it may be used in ways
that do not pose an unacceptable risk to the environment or human health. However, even in the absence of
confirmatory data, these properties mean that the chemicals are of concern and the use of safer substitutes
should be encouraged.

EU Implementation of the Stockholm Convention on Persistent Organic Pollutants (POPs): An EC
Regulation
15
fulfils EU obligations under the Stockholm Convention
16
on Persistent Organic Pollutants and
the 1979 Convention on Long Range Trans-boundary Air Pollution on Persistent Organic Pollutants. The
Regulation bans the marketing and use of certain POPs and implements a number of measures to reduce
releases of other POPs. POPs listed in the Regulation include of a number of pesticides (such as DDT and
lindane), PCBs and dioxins/furans
17
. PPC Applicants that use, produce or release any of these substances will
need to consider how the regulations apply - even to trace quantities of POPs in waste streams. The
Convention also requires Member States, when permitting new facilities or significantly modified existing
facilities, to give priority consideration to alternative processes, techniques or practices that have similar
usefulness but which avoid the formation or release of listed POPs.

Persistent, Bioaccumulative and Toxic (PBT) substances: The European Commission proposes that PBT
substances, and substances that are very Persistent and very Bioaccumulative (vPvB), should be subject to
authorisation under REACH. We are developing our own approach on these substances. Part of this has
been to screen existing databases to identify possible candidates and to seek early clarification of their status.
This has been done both through dialogue with the UK Chemical Stakeholder Forum, the European
Chemicals Bureau (ECB) and other Member States. Approximately 100 substances have been identified as
potential candidates and we are acting as rapporteur on about 20% of these to help clarify their status. As

their status is clarified, we will communicate our general approach to these substances and any action we
intend to take.

Carcinogenic, Mutagenic and Reproductive (CMR) Toxins: We are developing further our approach on
these substances and will be communicating this later in 2005.

National Risk Assessments: We are undertaking national risk assessments on the substances in Annex 3.4.
Where appropriate the Government will develop a risk reduction strategy to address the risks identified and
we will communicate any actions it intends to take. The intention is to make these risk assessments available
on our web site when they are finalised.
Where an environmental risk or a need for further information has
been identified and where in our opinion the assessment is relevant to PPC processes, the same approach
should be taken as for ESR substances.

14
View the list at: />15
EC Regulation 850/2004. See
16
See and />17
The EU has proposed the addition of new substances to the Regulation, including short chain chlorinated paraffins.
See
/>PPC Sector Permitting Plan - Chemicals Page Version 2 (April 2005)
11
Annex 1: Analysis of 2003 Pollution Inventory (PI) data

NB: The PI covers additional substances but these tables only show those with Chemical Sector contributions.

Release from IPC and PPC
processes / installations
Significant' chemical processes (i.e. releasing >10% of chemical

sector contribution)
Chemical sector
Annex 1.1 Air releases


(* Air Quality Standard or limit applies)
Total (kg)
kg %
No. Details (reference number and % of chemical sector
contribution)
Acrylonitrile (2-Propenenitrile) 274017 274017 100 2 AK6505 (73%), AK6772 (27%)
Aniline (Benzeneamine) 3040 3040 100 3 AK5784 (16%), AK7841 (66%), AN9000 (18%)
Benzyl Chloride (Chloromethylbenzene) 1122 1122 100 2 AO0261 (68%), BH2626 (24%)
Carbon Tetrachloride (Tetrachloromethane) 8700 8700 100 2 AL7421 (75%), AL7456 (23%)
Cyanamide 265 265 100 1 AF6086 (100%)
Di(2-Ethylhexyl)Phthalate (DEHP) 430 430 100 1 AO0725 (100%)
Epichlorohydrin 158 158 100 2 AL6794 (45%), AN9158 (55%)
Ethyl Acrylate 225 225 100 2 AJ4928 (33%), BM0273IJ (67%)
Ethyl Bromide 4902 4902 100 2 AL8223 (81%), AL8533 (19%)
Ethylene Oxide (1,2 Epoxyethane) 28892 28892 100 3 AK4001 (48%), AL7251 (23%), AO9277 (14%)
Hexabromocyclododecane 3430 3430 100 1 AL8223 (100%)
Hydrobromofluorocarbons (HBFCs) 1530 1530 100 1 AL7243 (100%)
Hydroxyethyl Acrylate 43 43 100 1 AI9516 (100%)
Iodomethane 620 620 100 1 AK5709 (100%)
Maleic Anhydride 3915 3915 100 1 AJ7269 (89%)
Methyl Bromide (Bromomethane) 146134 146134 100 1 AK7228 (99.9%)
Methyl Chloroform (1,1,1-Trichloroethane) 2000 2000 100 1 AL7421 (100%)
Nitrobenzene 700 700 100 2 AK7841 (71%), AW5069 (29%)
Other Individual Organic Compounds 596735 596735 100 1 AK5687 (93%)
Phosgene (Carbonic Dichloride) 20100 20100 100 1 AL7421 (100%)

Propylene Oxide 84602 84602 100 1 AK4001 (92%)
Trichlorotoluene 336 336 100 2 AN9891 (60%), AO0261 (40%)
Vinyl Chloride 177591 177591 100 3 AK6039 (17%), AL7421 (57%), AP7563 (25%)
Methyl Chloride (Chloromethane) 549446 549300 100 2 AL0567 (55%), AL7456 (313%)
Hydrofluorocarbons (HFCs) 217931 217658 100 3 AL7243 (16%), AL7448 (22%), AL9092 (55%)
Chloroform (Trichloromethane) 28952 28812 100 2 AL7421 (21%), AL7456 (63%)
Toluene Diisocyanate - All Isomers 82 82 99 1 AU7362 (99%)
Methylene Chloride (Dichloromethane) 1870203 1855503 99 3 AK5687 (17%), AU7362 (29%), AU7664 (13%)
Tetrachloroethylene 122641 121631 99 2 AL7421 (66%), AL7863 (22%)
Dioxane 6831 6688 98 3 AK6969 (44%), AK8236 (33%), AL7251 (23%)
Styrene 62628 60909 97 4 AJ3808 (16%), AK5555 (15%), AK7884 (20%), AZ0799 (13%)
Propylene (1-Propene) 9656131 9386131 97 2 AJ6505 (67%), AL1393 (27%)
Ethylene (Ethene) 2107039 1992938 95 4 AK4028 (23%), AK6845 (14%), AL7421 (20%), BS3590IE (23%)
Ethylene Dichloride (1,2-Dichloroethane) 589683 550143 93 2 AK6039 (15%), AL7421 (84.7%)
Acetaldehyde (Ethanal) 41955 37920 90 3 AK6845 (42%), AK8236 (35%) AL7251 (19%)
Chlorofluorocarbons (CFCs) 3459 3057 88 1 AK7493 (92%)
Dimethylformamide 162831 139631 86 1 AP3169 (99.99%)
Butadiene (1,3-Butadiene) * 80855 68589 85 2 AK4117 (18%), BS3590IE (65%)
Acetonitrile (Ethane Nitrile) 18525 15583 84 2 AJ6505 (53%), AK6772 (17%)
Carbon Disulphide 2875307 2311666 80 1 AO2345 (99.5%)
Nitrous Oxide 13134512 10425322 79 3 AK3803 (32%), AL7561 (35%), AL8614 (31%)
Hydrochlorofluorocarbons (HCFCs) 290395 228719 79 3 AL7243 (13%), AL7448 (53%), AL7456 (10%)
Ammonia 2713346 1975360 73 1 AL7855 (78%)
Hydrogen Cyanide 131909 81899 62 2 AJ6505 (36%), AM7265 (63%)
Ethyl Toluene (All Isomers) 1236 702 57 1 AJ3000 (100%)
Xylene (All Isomers) 1433100 810286 57 1 AK7728 (91%)
Chromium 19181 10726 56 3 AK3803 (22%), AN9727 (56%), AN9735 (11%)
Toluene 2209211 1136561 51 3 AJ9326 (23%), AO2345 (11%), BU0311IX (23%)
Formaldehyde (Methanal) 50691 22885 45 2 AK5873 (21%), AO2345 (53%)
Non-Methane Volatile Organic Compounds

(NMVOCs)
77088598 33681183 44 2 AJ6505 (21%), AK7728 (23%)
2-Ethoxyethanol 130 54 42 1 AK8511 (100%)
Trichloroethylene 632610 236230 37 1 AL7421 (72%)
Perfluorocarbons (PFCs) 24180 7880 33 1 AL7219 (99%)
Mercury 3947 1229 31 2 AL7294 (85%), AL9319 (11%)
Butene (All Isomers) 720594 183300 25 5 AJ3000 (17%), AK4591 (18%), AL0524 (14%), AL0567 (39%),

12
BS3590IE (12%)
Phenol 24072 5001 21 2 AK7914 (56%), BM0273IJ (16%)
Benzene * 1077543 199243 18 1 AK7728 (69%)
Pentane 3144836 562600 18 3 AK4591 (24%), AN4369 (26%), BU4520IZ (44%)
Copper 13197 2264 17 1 AN8437 (88%)
Lead * 73526 12561 17 1 BM0508IG (97%)
Pentene (All Isomers) 249160 40160 16 3 AJ7650 (38%), AL0524 (31%), BS3590IE (28%)
Methane 24739539 3611207 15 1 AL7855 (74%)
Carbon Monoxide * 465253348 49017045 11 3 AJ6505 (25%), AK7728 (17%), AM0147 (15%)
Zinc 64194 4421 7 3 AN8437 (45%), AO0571 (15%), AO1381 (40%)
Methylamine 1013 59 6 1 AO9277 (100%
Halons 1778 99 6 1 AL8550 (100%)
Tetrachloroethane (1,1,2,2-
Tetrachloroethane)
23245 1077 5 2 AB3048 (32.5%), AL7421 (67.5%)
Boron 281401 10900 4 1 AK3803 (100%)
Particulate Matter - Total 27378729 947547 3 2 AL7855 (50%), AL7553 (19%)
Arsenic * 1371 38 3 3 AN8712 (23%), AO1225 (12%), AO1233 (65%)
Carbon Dioxide 230852611364 6118566829 3 3 AL7855 (11%), AN8321 (13%), BS3590IE (19%)
Nickel * 15263 300 2 2 AK4594 (33%), AN8437 (67%)
Dioxins And Furans - as ITEQ 0.0375 0.0006 1 2 AK6039 (36%), AL7251 (60%)

Dioxins And Furans- as WHO TEQ 0.0392 0.0006 1 2 AK6039 (35%), AL7251 (62%)
Nitrogen Oxides (NO and NO2) as NO2 * 440995384 5834239 1 3 AL7855 (12%), AN8321 (23%), BS3590IE (17%)
Particulate Matter - PM10 * 14974412 165376 1 3 AK8821 (19%), AL7553 (56%), AL8282 (22%)
Cadmium * 1187 13 1 3 AN8712 (43%), AO0032 (33%), AO1390 (23%
Trimethylbenzene (All Isomers) 624458 4964 1 2 AK5598 (16%), AM1518 (75%)
Sulphur Hexafluoride 24408 126 1 1 BJ6747IZ (100%)
Sulphur Oxides (SO2 and SO3) as SO2 * 764501808 1898759 0.2 4 AL8282 (14%), AL9459 (19%) (AL9459 (19%), AM7265 (20%)
Chlorine And Total Inorganic Chlorine
Compounds - as HCl
30637360 65800 0.2 2 AJ5720 (28%), AQ1773 (72%)
Hydrogen Chloride 29833672 48175 0.2 1 AQ1773 (98%)
Isophorone Di-Isocyanate 104 0.16 0.2 1 AU7982 (100%)

Release from IPC and PPC
processes / installations
Significant' chemical processes (i.e. releasing >10% of chemical
sector contribution)
Chemical sector
Annex 1.2 Controlled Water releases


(* Water Quality Standard applies)
Total (kg)
kg %
No. Details (reference number and % of chemical sector
contribution)
Aniline (Benzeneamine) 34018 34018 100 1 AK7841 (99.955)
Biphenyl 176 176 100 1 AW6570 (100%)
Halogenated Organic Compounds - as AOX 20842 20842 100 4 AK7337 (27%), AL8533 (41%), AL8550 (10%), BM0508IG
(13%)

Nonylphenol Ethoxylates 2899 2899 100 2 AJ4928 (76%), AK6969 (24%)
Nonylphenols 100 100 100 1 AK6969 (100%)
Octylphenol Ethoxylates 12303 12303 100 1 AK4109 (98%)
Octylphenols 240 240 100 1 AK6969 (100%)
Cyanides - Total Nos (as CN) 7294061 7292272 100 1 ak3196 (99.8%)
Methylene Chloride (Dichloromethane) 83243 83172 100 1 AK5687 (97%)
Polychlorinated Biphenyls (PCBs) 2.8 2.8 100 1 AN6787 (100%)
Chlorides - Total As Cl 1461729819 1376779000 94 2 AO0385 (43%), AO0393 (52%)
Ethylbenzene 2581 2401 93 2 AK5547 (83%), BS3590IE (10%)
Benzene * 28070 25833 92 1 BS3590IE (93%)
Ethylene Dichloride (1,2-Dichloroethane) 838 751 90 1 AL7421 (5%)
Phosphorus - As Total P 593631 507366 85 4 AH2389 (14%), AJ6505 (27%), AK5687 (19%) ak8686 (15%)
Toluene * 7059 5856 83 2 AK5547 (15%), BS3590IE (66%)
Chloroform (Trichloromethane) * 959 781 81 3 AK7337 (31%), AL9092 (31%), BS3590IE (17%)
Phenols - Total As C * 172141 139884 81 1 AN6787 (77%)
Mercury * 233 187 80 1 AL7294 (84%)
Hexachlorobenzene 3.47 2.77 80 2 AL7421 (45%), AL7456 (54%)
Chromium 11447 9084 79 3 AK8686 (10%), AL8282 (55%), AN9727 (15%)
Lead 12712 9960 78 1 BM0508IG (87%)
Xylene (All Isomers) * 3277 2487 76 2 AL6794 (46%), BS3590IE (37%)
Nitrogen - As Total N 9083864 5989704 66 3 AJ6505 (20%), AL8614 (25%), AO0393 (11%)
Nickel 12330 8045 65 2 AJ6505 (63%), AL8282 (12%)
Trichlorobenzene - All Isomers 5.84 3.64 62 4 AL7294 (22%), AL7421 (33%), AL7456 (27%), AN6787 (16%)
Zinc 71307 37765 53 3 AK2050 (15%), AL8282 (37%), BU4732IJ (15%)
Cadmium * 302 148 49 4 AK7337 (28%), AK8686 (15%), AL8282 (13%), BM0508IG
(18%)
PPC Sector Permitting Plan - Chemicals Page Version 2 (April 2005)
13
Carbon Tetrachloride (Tetrachloromethane) * 104 49 47 4 AL7421 (12%), AL7456 (45%), AL8363 (10%), BM0508IG
(25%)

Total Organic Carbon (TOC Or COD/3) 35277233 14890895 42 2 AJ6505 (16%), AL8282 (16%)
Hexachlorobutadiene 3.53 1.41 40 2 AL7421 (36%), AL7456 (64%)
Pentachlorophenol 10.81 3.60 33 1 AN6787 (100%)
Copper 12216 3485 29 2 AK8686 (15%), AL8282 (44%)
Arsenic * 2002 517 26 1 AK7809 (14%)
Fluorides - Total As F 988542 229584 23 1 AK4087 (83%)

Release from IPC and PPC
processes / installations
Significant' chemical processes (i.e. releasing >10% of chemical sector
contribution)
Chemical sector
Annex 1.3 Sewer releases
Total (kg)
kg %
No. Details (reference number and % of chemical sector contribution)
2,4-Dichlorophenoxyacetic Acid (2,4-D) -
Ester And Non-Ester
1266 1266 100 2 AL6018 (23%), AM2026 (77%)
Di(2-Ethylhexyl)Phthalate (DEHP) 59 59 100 1 AO0725 (100%)
Ethylene Dichloride (1,2-Dichloroethane) 710 710 100 1 AK7493 (100%)
Hexabromocyclododecane 311 311 100 1 AL8169 (100%)
Mecoprop 3248 3248 100 2 AL6018 (30%), AM2026 (70%)
Methyl Chlorophenoxy Acetic Acid (MCPA) 13318 13318 100 1 AL6018 (93%)
Nonylphenols 512 512 100 2 AK7078 (33%), AK0863 (67%)
Phosphorus - As Total P 152136 152136 100 2 AK9666 (14%), AI6100 (69%)
Propylene Oxide 1850 1850 100 1 AK4001 (100%)
Tert-Butyl Methyl Ether (MTBE) 202 202 100 1 AK4079 (100%)
Naphthalene 576 567 98 1 AK8821 (99.7%)
Halogenated Organic Compounds - as AOX 23037 22100 96 2 AK4362 (13%), AK7230 (87%)

Toluene 64102 60662 95 1 AK7493 (81%)
Ethylbenzene 1955 1845 94 1 AL1393 (91%)
Phenols - Total As C 74546 70171 94 1 BM0273IJ (74%)
Methylene Chloride (Dichloromethane) 2096 1897 91 1 AK4702 (94%)
Bisphenol-A 56 49 88 1 BM0273IJ (97%)
Zinc 7128 5730 80 3 AK6225 (16%), AK3579 (17%), AK9666 (37%)
Copper 4935 3832 78 2 AV2862 (20%), AK3579 (34%)
Benzene 18302 13838 76 2 AL1393 (10%), AW5069 (79%)
Nitrogen - As Total N 4944967 3687534 75 2 AN8437 (41%), AK3803 (43%)
Lead 1293 924 71 2 AK7493 (32%), AO1837 (45%)
Nickel 1127 790 70 2 AK2335 (11%), AK7493 (14%)
Chromium 4236 2944 69 1 AK3579 (92%)
Chloroform (Trichloromethane) 44 28 64 2 AO0261 (46%), BU4376IS (54%)
Chlorides - Total As Cl 53677016 32943000 61 2 BM0273IJ (20%), AK7493 (71%)
Atrazine 2.15 1.21 56 1 AK8058 (99.99%)
Simazine 5.23 2.84 54 1 AK8058 (99.9%)
Mercury 34 16 47 2 AI6100 (26%), AO2345 (28%)
Arsenic 349 153 44 2 AO1241 (20%), AI6100 (55%)
Octylphenol Ethoxylates 1163 500 43 1 AK4109 (100%)
Xylene (All Isomers) 2305 796 35 4 AK7078 (12%), AK5199 (19%), BM0273IJ, (24%), AM8601 (28%)
Cadmium 82 26 32 4 AK7493 (11%), AL8185 (11%), AI6100 (15%), AQ17773 (24%)
Total Organic Carbon (TOC Or COD/3) 69577395 18731615 27 1 AK7493 (14%)
Fluorides - Total As F 362707 90260 25 1 AL7219
Nonylphenol Ethoxylates 5867 611 10 2 AK3960 (22%), AJ1228 (75%)
Trichlorobenzene - All Isomers 7.37 0.57 8 1 AO0261 (99.99%)
Cyanides - Total Nos (as CN) 1928 81 4 1 AL8509 (100%)
Fenitrothion 0.332 0.00021 0.06 1 AK5326 (100%)
Malathion 0.349 0.00021 0.06 1 AK5326 (100%)
Dichlorvos 0.442 0.00021 0.05 1 AK5326 (100%)
Polychlorinated Biphenyls (PCBs) 0.105 0.00004 0.04 1 AK5326 (100%)

Aldrin 0.106 0.00004 0.04 1 AK5326 (100%)
Endrin 0.117 0.00004 0.04 1 AK5326 (100%)
Hexachlorobenzene 0.119 0.00004 0.04 1 AK5236 (100%)
Trifluralin 0.160 0.00004 0.03 1 AK5326 (100%)
Dieldrin 0.187 0.00004 0.02 1 AK5326 (100%)
Dichlorodiphenyltrichloroethane (DDT) - All
Isomers
0.529 0.00011 0.02 1 AK5326 (100%)
Endosulfan 0.420 0.00004 0.01 1 AK5326 (100%)
Hexachlorobutadiene 2.002 0.00004 0.002 1 AK5326 (100%)

14

Annex 2: Dangerous Substances Directive

The following lists have been generated from Table A3.1 (List I), Table A3.2. Table A3.3 and Table A3.4 (All List II)
in the Appendix to the ‘Agency Guidance on Consenting of Dangerous Substances in Discharges to Surface Waters’
(EAS/2301/4/2 v5).

Those marked (X) are also ‘prescribed substances’ under IPC (SI 1991/472 Schedule 5)

List I List II (inorganics) List II (organics)
Mercury X Arsenic Benzene
Cadmium X Lead Toluene
Trichloroethylene (TRI) Chromium Xylene
Tetrachloroethylene (PER) Zinc Naphthalene
1,2-dichloroethane (EDC) X Copper Biphenyl
Chloroform Nickel 1,1,1-Trichloroethane
Carbon tetrachloride (CTC) Boron 1,1,2-Trichloroethane
Trichlorobenzenes (TCB) X Iron 2-Chlorophenol

Hexachlorobenzene (HCB) X Vanadium 2,4-Dichlorophenol
Hexachlorobutadiene (HCBD) X pH 2,4-D (ester and non-ester)
Hexachlorocyclohexane (HCH) (all isomers) X 4-Chloro-3-methyl-phenol
Pentachlorophenol (PCP) X Chloronitrotoluenes
DDT (all isomers including p-p-DDT) X Atrazine and Simazine X
Aldrin X Azinphos-methyl X
Dieldrin X Bentazone
Endrin X Demetons
Isodrin Dichlorvos X
Dimethoate
Endosulfan X
Fenitrothion X
Linuron
Malathion X
Mecoprop
Mevinphos
Omethoate
Permethrin
Trifluralin X
Triazaphos
PCDSs
Cyfluthrin
Sulcofuron
Flucofuron
Tribuyltin X
Triphenyltin and its derivatives X

NB: Polychlorinated biphenyls (PCB) are prescribed in Schedule 5 to SI 472 but it is in neither Dangerous
Substances Directive List.
PPC Sector Permitting Plan - Chemicals Page Version 2 (April 2005)

15
Annex 3: Substances of potential concern or relevance to the Chemicals Sector

Annex 3.1: Existing Substances Regulation (ESR) – only relevant chemicals listed

CAS No. Chemical Name CAS No. Chemical Name
7664-39-3 hydrogen fluoride 1314-13-2 zinc oxide
84-74-2 dibutyl phthalate 557-05-1, 91051-01-3 zinc distearate
101-77-9 4,4'-methylenedianiline 7646-85-7 zinc chloride
1163-19-5 bis(pentabromophenyl)ether * 7733-02-0 zinc sulphate
79-01-6 trichloroethylene 7779-90-0 trizinc bis(orthophosphate)
91-20-3 naphthalene 11138-47-9 perboric acid, sodium salt
127-18-4 tetrachloroethylene 1306-19-0 cadmium oxide
7722-84-1 hydrogen peroxide 7440-43-9 cadmium
80-62-6 methyl methacrylate 1634-04-4 tert-butyl methyl ether
79-10-7 acrylic acid 85-68-7 benzyl butyl phthalate
107-13-1 acrylonitrile 75-91-2 tert-butyl hydroperoxide
108-88-3 toluene 79-11-8 chloroacetic acid
120-82-1 1,2,4-trichlorobenzene 81-15-2 5-tert-butyl-2,4,6-trinitro-m-xylene (musk xylene)
25637-99-4 Hexabromocyclododecane * 110-85-0 piperazine
7681-52-9 sodium hypochlorite (chlorinated
byproducts from use of ) *
80-05-7 4,4'-isopropylidenediphenol (bisphenol-A) *
67-66-3 chloroform 1333-82-0 chromium trioxide
95-76-1 3,4-dichloroaniline 7775-11-3 sodium chromate
62-53-3 aniline 7778-50-9 potassium dichromate
98-01-1 2-furaldehyde 7789-09-5 ammonium dichromate
108-05-4 vinyl acetate 10588-01-9 sodium dichromate
108-95-2 phenol 85535-84-4 alkanes, C10 - 13, chloro (SCCPs) *
60-00-4 edetic acid (EDTA) 85535-85-9 alkanes, C14-17, chloro (MCCPs) *

64-02-8 tetrasodium ethylenediaminetetraacetate
(sodium EDTA)
79-94-7 2,2',6,6'-tetrabromo-4,4'-isopropylidenediphenol
(TBBPA)
71-43-2 benzene 84852-15-3 and 25154-
52-3
Nonylphenol (branched) and nonylphenol
115-96-8 tris(2-chloroethyl) phosphate * 25103-58-6 tert-Dodecanethiol (including n-dodecanethiol)*
7440-66-6 zinc
* Substance at conclusion (i) (i.e. potential concern in need of further investigation), rather than conclusion (iii) (i.e. risk identified)


16
Annex 3.2: Current Marketing and Use Restrictions

1,1 Dichloroethylene Methyl bromoacetate
1,1,1 Trichloroethane Monomethyl — tetrachlorodiphenyl methane Trade name: Ugilec 141
1,1,1,2 Tetrachloroethane Monomethyl-dibromo-diphenyl methane Trade name: DBBT
1,1,2 Trichloroethane Monomethyl-dichloro-diphenyl Methane. Trade name: Ugilec 121,
Ugilec 21
1,1,2,2, Tetrachloroethane Mutagen category 1 or 2
album and Veratrum nigrum Naphthylamine and its salts
Arsenic Nickel and its compounds
Azocolourants Nitrobiphenyl
Benzene Nonylphenol, Nonylphenol ethoxylate
Benzidine and its salts, o nitrobenzaldehyde. Wood powder.
Benzidine and/or its derivatives Organostannic compounds
Blue colourant Organostannic compounds
Butyl bromoacetate PCBs/PCTs
Cadmium Penta and Octabromodiphenyl ether

Carbon tetrachloride Pentachloroethane
Carcinogen category 1 or Carcinogen category 2 (as per
Annex I to Directive 67/548/EEC)
Pentachlorophenol and its salts and esters
Chlorinated solvents Phthalates
Chloro-1-ethylene (monomer vinyl chloride) Polybromobiphenyls (PBB)
Chloroform Polychlorinated biphenyls (PCB) except mono- and dichlorinated
biphenyls
CMRs Powder of the roots of Helleborus viridis and Helleborus niger
Creosote Powder of the roots of Veratrum
di-µ-oxo-di-n-butylstanniohydroxyborane Propyl bromoacetate
Ethyl bromoacetate Short-chain chlorinated paraffins
Flammable or extremely flammable substances (67/548/EEC) Soap bark powder (Quillaja saponaria) and its derivatives
Hexachloroethane Tin, PCP and cadmium
Lead carbons:— lead hydrocarbonate 2 Pb— neutral
anhydrous carbonate
Toxic for reproductive purposes category 1 or 2
Lead sulphates Tris (2,3 dibromopropyl) phosphate
Liquid subs/preparations, which are dangerous according to
the Dangerous subs. directive 67/548/EEC
Tris-aziridinyl)-phosphinoxide
Mercury compounds
Note: A consolidated version of the directive with details of the extent of the restrictions applied can be found at
/>

Annex 3.3: Water Framework Directive - Priority Hazardous Substances

CAS number EU number Name of priority hazardous substance
120-12-7 204-371-1 Anthracene(***)
n.a. n.a. Brominated diphenylethers (**) - Only Pentabromobiphenylether (CAS number 32534-81-9)

7440-43-9 231-152-8 Cadmium and its compounds
85535-84-8 287-476-5 C
10
-
13
-chloroalkanes (**)
115-29-7 204-079-4 Endosulfan(***)
118-74-1 204-273-9 Hexachlorobenzene
87-68-3 201-765-5 Hexachlorobutadiene
608-73-1 210-158-9 Hexachlorocyclohexane
7439-97-6 231-106-7 Mercury and its compounds
25154-52-3 246-672-0 Nonylphenols
608-93-5 210-172-5 Pentachlorobenzene
n.a. n.a. Polyaromatic hydrocarbons
688-73-3 211-704-4 Tributyltin compounds
12002-48-1 234-413-4 Trichlorobenzenes(***)
** These groups of substances normally include a considerable number of individual compounds. Presently, appropriate
indicative parameters cannot be given.
*** Identified following a review of possible Priority Hazardous Substances in the original Annex X list (2455/2001/EC).

N.B. Decision 2455/2001/EC gives a complete list of Priority and Priority Hazardous Substances for the Water Framework Directive.

PPC Sector Permitting Plan - Chemicals Page Version 2 (April 2005)
17

Annex 3.4: Substances undergoing national risk assessments

Hindered phenols (several substances)
- 2,2',6,6'-Tetra-tert-butyl-4,4'-methylene-diphenol (CAS no. 118-82-1)
- 6,6'-Di-tert-butyl-2,2'-methylenedi-p-cresol (CAS no. 119-47-1)

- 2,6-Di-tert-butyl-p-cresol (butylated hydroxytoluene, BHT) (CAS no.
128-37-0)
- 4,6-Di-tert-butyl-m-cresol (CAS no. 497-39-2)
- 1,1,3-Tris(2'-methyl-4'-hydroxy-5'-tert-butylphenyl)butane (CAS no.
1843-03-4)
- Octadecyl 3-(3,5-di-tert-butyl-4-hydroxyphenyl)propionate (CAS no.
2082-79-3)
- Pentaerythritol tetrakis(3-(3,5-di-tert-butyl-4-
hydroxyphenyl)propionate) (CAS no. 6683-19-8)
Aryl phosphates (several substances):
- Triphenyl phosphate (CAS no. 115-86-6)
- 2-Ethylhexyl diphenyl phosphate (includes diphenyl
octyl phosphate)(CAS no. 1241-94-7)
- Tricresyl phosphate (CAS No. 1330-78-5)
- Trixylyl phosphate (CAS no. 25155-23-1)
- Cresyl diphenyl phosphate (CAS no. 26444-49-5)
- Isopropylphenyl diphenyl phosphate (CAS no. 28108-
99-8)
- Isodecyl diphenyl phosphate (CAS no. 29761-21-5)
- tert-Butylphenyl diphenyl phosphate (CAS no. 56803-
37-3)
- Resorcinol bis-diphenylphosphate (CAS no. 57583-54-
7)
4-tert-Octylphenol (CAS no. 140-66-9)* Perfluorooctanylsulphonate (PFOS) and derivatives* -
N.B. this also includes polymers.
[PFOS acid (CAS no. 1763-23-1), ammonium salt (CAS
no. 29081-56-9), diethanolamine salt (CAS no. 70225-
14-8), potassium salt (CAS no. 2795-39-3) and lithium
salt (CAS no. 29457-72-5)]
Dodecylphenol, mixed isomers, branched (tetrapropenylphenol) (CAS

no. 121158-58-5 & 74499-35-7)*
Long chain chlorinated paraffins (Paraffin waxes and
hydrocarbon waxes, chloro (CAS no. 63449-39-8) and
Paraffin oils, chloro (CAS no. 85422-92-0)*
Alkylthiols
- tert-Dodecanethiol (CAS no. 25103-58-6)*

- Dodecyl mercaptan (CAS no. 112-55-0)
- tert-Nonyl mercaptan (CAS no. 25360-10-5)
Octamethylcyclotetrasiloxane (CAS no. 556-67-2)* and a
group of related organosiloxanes
(hexamethylcyclotrisiloxane &
decamethylcyclopentasiloxane).




Note: As there is no legal obligation for companies to supply information (unlike the ESR for example), a conclusion of risk may be
drawn if no data are forthcoming, even if the concern could in theory be removed with better information. Substances of particular
relevance to PPC are identified with an asterisk.


18