CASE STUDIES
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In the context of industrial regulation, the European Industrial Emissions Directive (IED) stands as a critical framework that regulates the permit issuance for significant industrial activities. This directive plays a key role in mitigating pollution across air, water, and land, while ensuring that industrial practices are in harmony with objectives of environmental protection. Its impact is enhanced by the establishment of specific Emission Limit Values (ELVs), determined by official Best Available Techniques (BAT) conclusions. These conclusions are applicable across a diverse range of sectors, including but not limited to refining, large combustion plants, and waste treatment systems within the chemical industry.
Gunvor’s industrial facilities comply with their respective BAT standards, continually aiming to reduce their emissions further.
2024 Objectives
Gunvor’s management rigorously maintains operational compliance, promptly addressing and investigating regulatory breaches to prevent future occurrences. In 2023, our assets exceedances mainly involved short-term air emissions, with fewer cases related to wastewater and cooling water. Although there was a slight increase in such exceedances compared with last year, the long-term trend shows progress. One example involved a slight increase in our GRI SOx daily bubble limit following a trip in the sulfur recovery unit.
Furthermore, Gunvor’s assets were not subject to any fines by complying with environmental regulations and actively collaborating with local communities to resolve concerns about operational effects. The data detailing environmental exceedances and community complaints are illustrated in the following graph.

About this graph: The numbers of environmental permit exceedances and community complaints around Gunvor’s refining sites.
Gunvor is committed to maintaining environmental norms, adhering to the European Pollutant Release and Transfer Register (EPRTR) regulation. Our industrial sites follow strict emission regulations, consistently overseeing and documenting pollutant levels both internally and to respective authorities.
Air Emissions
The most relevant air pollutants at Gunvor’s refining sites are Sulphur Dioxide (SO2 ), Nitrogen Oxides (NOx), Particulate Matter (dust), and Volatile Organic Compounds (VOCs).
The main source of Nitrogen Oxides (NOx) are the furnaces where a small part of the nitrogen in the combustion air reacts with oxygen depending on the conditions in the flame. Gunvor has equipped many of its furnaces with low-NOx burners to reduce emissions. Volatile Organic Compounds (VOCs) emissions are controlled by means of vapor recovery systems, equipment on floating roof tanks, and Leak Detection and Repair programs. Sulfur Dioxide (SO2 ) originates from sulfur in the fuel used at the company’s plants and from the regeneration of the catalyst in the Fluid Catalytic Cracking unit (FCC). Through several measures, such as the use of natural gas instead of oil as fuel, Gunvor has drastically reduced the SO2 emissions in the past. These measures also have reduced the emission of particulates such as soot particles. Further reduction of SO2 emissions follow from the installation of an SO2 scrubber at the FCC unit in Ingolstadt in 2023.
Air emissions are measured according to the permit requirements on a continuous or periodic basis. When measures show that a concentration is higher than what is permitted, this is reported as an exceedance. The following table shows the emissions for Gunvor’s two refining sites. In 2023, GRI reported lower total emissions compared with previous years, mainly due to the refinery undergoing a scheduled shutdown from mid-February to early April during the turnaround. GER, emissions have also decreased compared with the previous year. SO2 emissions dropped due to a reduction in the sulfur content of the feedstocks, resulting in lower quantities of sulfur in the fuel gas used in combustion units. NOx emissions were lower due to decreased operational hours of the older boilers. Additionally, VOCs emissions have declined as a result of less flaring and fewer leaks from flanges, valves, and similar components.

In accordance with the Corporate Sustainability Reporting Directive (CSRD), specifically disclosure requirement E2-4 (Pollution of air, water and soil), Gunvor must continue to report the pollutants emitted through its operations as specified in Regulation No. 166/2006. Additionally, the company should disclose the microplastics it generates or uses. Gunvor should contextualize these disclosures by describing the changes over time, the measurement methodologies, and the data collection processes for pollution-related accounting and reporting.
