the french guidance on ied baseline report - common …€¦ ·  · 2014-10-13the french guidance...

Ministère de l'Écologie, du Développement Durable et de l’Énergie

www.developpement-durable.gouv.fr

The French guidance on IED baseline

report

Emilie FAVRIE French Ministry of ecology, sustainable developpment and energy

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French guidance

France worked on a national guideline from 2012 in order to deal with the missing European guidelines

French guidance is based on the French national standard NF X31-620 for environmental consultants on site remediation

Published in February 2014, with a specific

appendixes on waste treatment plan in May 2014 and on rearing in October 2014

The responsibility of producing a quality baseline report lies with the operator.

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Baseline report scope

Baseline reports must consider the area where there is a risk of pollution.

Soil impact are studied only inside the border of the site

However, plums of pollution must be characterised

Number of sampling must be proportionate to the actual, future and past activities and regarding the risk of soil and water contamination

2 criteria are considered for the necessity of a baseline report

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Criteria 1 : relevant hazardous substances

Substances or mixtures that are classified in at least one of the hazard classes defined in Annex I of CLP Regulation

Substances or mixtures are considered as relevant:

If there are currently used, produced or release (past substances are not considered)

Or if those substances will be used when the installation is authorised

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Criteria 2 : possibility of soil and groundwater contamination

Possibility of soil and groundwater contamination regarding to:

The dangerousness of the relevant substances or mixtures

Its chemical characteristics regarding to its capacity to impact soil

and groundwater

It’s the responsibility of the operator to establish if the used quantities present a risk of soil and ground water contamination

Preventive measures are not relevant to avoid the preparation of a baseline report => difficult to guarantee that there will never be an accident or a failure of those preventive measures

No baseline report for gaseous or non-pulverulent solid hazardous substances

Baseline is mandatory if used of priority substances in the field of water policy and/or considered in environmental quality standards from the Water Framework Directive

No baseline if operator prove no risk of contamination considering product quantities and chemical characteristics

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Baseline report content – 5 chapters

Chapter 1 : site characterisation and environmental setting

Chapter 2 : existing data collection and analysis

Chapter 5 : Analysis of the results, interpretation of data and evaluation of the state of soil and groundwater contamination

If available data are not sufficient to determine the state of soil and groundwater

Chapter 3 : Definition of sampling strategy

Chapter 4 : Site investigation and analysis of samples

The methodology is based on the French national standard NF

X31-620 for services related to contaminated sites and soils . It’s

recommended that baseline report is made by a an consulting

company qualified for contaminated sites and soils.

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1: Site characterisation and environmental setting

Site history, environmental setting

Identify potential sources or accident which may have result in presence of the substances in soil and/or groundwater

Analysis of issues and potential impacts

Defined pathway and elaborate a conceptual site model

Differences between historical pollution and current processes to deal with hazardous substances

Elements which must be provided

List of substances used, produced or

emitted and their chemical characteristics

Site history study

Maps, plans

Conceptual site model

BRGM/INERIS

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2: Existing data collection and analysis

Collect all existing data and evaluate if there are relevant

Use all data available (soil and groundwater monitoring, results of remedial works, …)

Check if data are sufficient and representative to produce a baseline report (if so it’s not mandatory to made new investigation)

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3 & 4: Definition of sampling strategy, site investigation and analysis of samples

Groundwater, soil and, if relevant, soil gas sampling

Site specific approach to determined where sample, depending on the probability of occurrence of the pollution

Standard and best practise must be used in order to have reproducible sampling and analysis strategies

All the relevant technical data (measurements, analytical standards, maps, sampling logs…) must be attached to the baseline report

BRGM/INERIS

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5: Analysis of the results, interpretation of data and evaluation of the state of soil and

groundwater contamination Results must be presented with plans and chart according to the

substances found and the location of the pollutant

Uncertainty of the results due to the sampling or the impossibility to access some area must be described

Special demands for sites updating their permit:

Preventive measures must be preserved to avoid any new contamination

No sampling under sealed slab

A substance not described is considered as not present in the soil or in groundwater but might be look for at the cessation of activity

The responsibility of producing a quality baseline report lies with the operator

National authorities do not validate the investigation program

In case of discovery an important pollution, the French contaminated site policies will be applied

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Specificity for some sectors

Specificity for intensive rearing plants : no baseline report (unless heating oil storage tank with capacity storage greater than 50 m3 or non-biodegradable cleaning substances are used)

Specificity for waste treatment plants :

Disposal of non hazardous waste: no baseline excepted if hazardous substance is used;

Disposal or recovery or temporary storage of hazardous waste: baseline for substances identified in the SEVESO campaign and the one already monitored in surface water and/or groundwater;

Hazardous waste incineration or co-incineration plants: baseline for substances monitored in surface water and/or groundwater;

Landfills: no soil sampling under the cells, groundwater sampling according to the existing legislation. If hazardous substances are used => sample in the soil bellow the storage and in the groundwater.

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Still under discussions

How to determine whether there is a significant pollution between the state of the baseline report and site closure ?

How to monitor soil properly ?

How to defined a systematic appraisal of the risk of contamination ?

Those topics are still under discussions in France and we would highly appreciate your feedback

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Thanks for your attention

Any questions ?

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Guidance on the French Environment Ministry web site :

http://www.developpement-durable.gouv.fr/IMG/pdf/Guide_Elaboration_Rapport_de_Base_IED_Dechet_v2-1.pdf