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In order to reduce emissions of volatile organic compounds the EU Solvent Directive 99/13/EC sets fugitive emission limits as a percentage of annual solvent input. A solvent management plan is given in annex III, to calculate the fugitive emission value from paper data of solvent inputs and outputs, and to demonstrate compliance. In a project for the Environmental Inspectorate Division of the Flemish Government we measured fugitive emissions at three different sites in the printing sector, all equipped with regenerative incinerators. Several experimental measurement techniques were applied, with the aim of demonstrating the feasibility of checking the reported solvent emissions independently. It was found that in all three cases the fugitive emissions are considerably higher than those reported in the solvent mass balances according to the Directive. The main reasons for the great underestimation are the unfounded assumption of 100% effectiveness of vapour capture by ventilation systems, and the wrong allocation of emission flows to the output terms O1 and O4, which in one case led to a 10-fold lower fugitive emission estimate. We conclude that verification of solvent balance by measurements is necessary to underpin emission reports and national emission data. Our results show that there is a risk that the Solvent Directive is not an effective policy instrument without the proper measurements for verification.

Measuring fugitive emission in the printing sector as a verification of the solvent management plan according to the EU Solvent Directive