reporting to the eprtr in the uk alex hole assessment & reporting advisor
TRANSCRIPT
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Reporting to the EPRTR in the UKAlex HoleAssessment & Reporting Advisor
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Overview EPRTR reporting in the UK Reporting from PPC activities Reporting from non-PPC activities Discussion
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The United Kingdom
(UK)
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EPRTR reporting in the UKEngland & Wales PPC (part A) - Environment Agency (EA) PPC (part B) - Local Authorities Non-PPC activities – Environment Agency (EA)
Scotland/Northern Ireland Scottish Environmental Protection Agency (SEPA) Northern Ireland Environment & Heritage Service (NIEHS) Local Authorities
UK Offshore Oil & Gas – BERR Diffuse releases (air only) – NAEI (AEA on behalf of Defra
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EPRTR reporting in the UK 2
Compilation of the UK return Defra are responsible for ensuring that the UK
complies with the EPRTR regulation The EA will compile the data for the UK for
submission to the EU A new UKPRTR website will be launched later this
year
The EA and SEPA both make their PRTR data available electronically through their websites
NAEI data available on the web
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EPRTR reporting to EA - PPCPPC (Part A) sites that we regulate• Required to report using a Regulation 28 information
notice under the PPC regulations – see pack• Required to report to our Pollution Inventory which is
more extensive than the EPRTR• more substances• lower thresholds• required to report ‘brt’ releases• more detailed reporting of waste transfers
• Required to report by 28th Feb of the year following that which releases relate to
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EPRTR reporting to EA – non PPC activities• Required to report using a Regulation 28 information
notice under the PPC regulations• Give us power to enforce the requirements even
though operators are required by regulation to provide information
• Report against EPRTR list only• Report by end of April of following year (will move to
Feb)
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EPRTR reporting to EA – How do they do it?• Complete a paper form – see handouts• Electronic copies available on website to
download• Form sent to all non PPC operators along with
notice – 1st year only• Report using electronic system (not available for
non-PPC in 1st year) – see tomorrow
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New PPC activities – Intensive Agriculture
Key issues and problems How to calculate
emissions Security issues over
farm locations Ensuring notice
reached appropriate person for completion
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New PPC activitiesIntensive Agriculture - emissionsCalculation of emissions
Several sets of emissions factors available
Farmers unions involved in choosing emissions factors
Disagreement over which factors to use
Used a combination of Corinair emissions factors plus those used on H1
Our IA colleagues involved in discussions Likely to change next year to ensure all factors used for
IA are consistent across the EA
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New PPC activitiesIntensive Agriculture – Concerns 1 Concern by Industry that information
submitted to PRTR would be used to alter permit conditions – assured them that this is not the case
Concerns over complexity of form – separate form has not been provided as we would be deciding for them which substances to report
Guidance note issued to say how to calculate emissions and how to complete form – again some complaints that it is too complicated – see pack for copy
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New PPC activitiesIntensive Agriculture – Concerns 2 Concern by Industry that publication
of names and addresses on web could lead to security breaches
Same procedure used to asses claims for confidentiality as per PPC application process
Government Minister for Agriculture confirmed that names and addresses would have to be published to allow the UK to comply with EPRTR requirements
Details used on PPC applications used to contact all farms - although because some sites are run on behalf of a big company – issues as to who completed form
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QA of PPC activities dataSeveral levels of QA are carried out following the
submissions of data to us1. Electronic reporting system raises ‘check flags’
where data is significantly different from previous years reporting or to the threshold
2. Site inspector checks return to see if return is consistent with their knowledge of site and permit conditions – see checklist in pack
3. Regional QA – use database tool to look for ‘outliers’ – see tomorrow
4. National QA – check trends to and totals to find any erroneous data
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QA of PPC activities dataOperator notified to submit (or re-
submit) data
Operator submits (or re-submits) data using electronic data capture
Site Inspector:Is operator data
acceptable?NO
YES
Entry level validation checks.
Operator cannot submit data that does not pass
validation
Quality Manager: Is operator data
comparable?
Publish data on website
NO
YES
Inspector must agree there is
an issue before going back to
operator
Online validation
Inspectorverification
Quality validation
Public validation
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Non PPC activitiesMines & Quarries 1Key issues/problems • Identifying sites• Interpreting 25Ha requirement• How to calculate emissions• How to QA data
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Non PPC activitiesMines & Quarries 2Identifying Sites• Defra consultation sent to mining and quarrying
trade association to inform them of new requirement• Used list from BGS – all active mines and quarries
in England and Wales• List found not to be very accurate• Decision taken that we will not chase up those that
do not respond – we have gone to our best efforts to identify them
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Mines & Quarries 3Problems• Landfills often operate in quarries and this activity is
regulated by us under PPC• Crushing activity generally regulated by Local
Authority• Requires double checking with some operators to
make sure they do not report twice• Most mines and quarries have been <25Ha, but
need to refer the operator to the definition in the regulation
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Mines & Quarries 4• Most mines and quarries have been
<25Ha, but need to refer the operator to the definition in the regulation
• Onus on them to ensure that they report as appropriate
Opencast mining and quarrying – where the surface area effectively under extractive operation equals 25 hectares.
“Surface of the area effectively under extractive operation” means the surface of the area of the site reduced by the surface of the rehabilitated area and reduced by the area of future excavation.
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Mines & Quarries 5Guidance• Very generic guidance provided for operators – see
pack• No funding or time for us to develop guidance with
methods for calculation • Anticipating very few sites to report any values that are
above threshold • Used indicative sector specific list for EPRTR guidance
document• No local site knowledge so data will be QAd nationally
– likely to compare data between sites, and with other sectors. No methodology prepared yet
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Non PPC activitiesIOWWTWs - 1Key issues/problems• Identifying sites• What is a treatments works?• Which pollutants?• QA of data
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Non PPC activitiesIOWWTWs - 2
Identifying sites• Used lists of discharge consents• Issued S28 notices as per other sectors• Likely to be only 10 or so sites reporting• Most have/are part of PPC permits
What is a treatments works?• Site must have some chemical/biological treatment• Water extracted for cooling at Power Stations does
not counts as treatment (filtering for debris only)
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Non PPC activitiesIOWWTWs - 3Which pollutants?• Due to limited time/budget and number of sites – no
guidance has been issued• All sites have discharge consents which have limits
set on how much of a substance can be released to the environment. Loads can be worked out as a proportion of this limit
QA of data• Likely that data will be QAd nationally – likely to compare
data between sites, and with other sectors. No methodology prepared yet
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Website Contains copies of the Forms (word and pdf) Link to electronic reporting system (PIEDC) Copies of generic guidance note Copies of reporting codes document Copies of sector specific guidance notes Details of how to contact us with enquiries
http://www.environment-agency.gov.uk/pi
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Discussion / Questions
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Reporting of Waste
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Overview• EPRTR requirements • How we do it in England and Wales• Problems/difficulties
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Reporting of Off site waste transfersEPRTR requirements • Process related waste going off site for Disposal or
Recovery• Require separate reporting of hazardous and non-
hazardous waste• Thresholds are:
• Hazardous waste 2 tonnes• Non- hazardous waste 2000 tonnes
• If total sent off site is above threshold then all waste need to be reported
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Reporting of Off site waste transfersHow we do it in England and Wales• Require sites to report waste according to Waste
type (EWC code) and WFD D or R code• Reporting threshold for PPC sites are:
• Hazardous waste: 0 tonnes• Non-hazardous waste: 5 tonnes
• Reporting threshold for non PPC sites are as per the EPRTR regulation
• Lists of EWC and D&R codes in PI reporting codes document – see pack
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Off site waste continuedKey issues/problems• Sludge – Agricultural sludge that is spread on land
for the benefit of agriculture needs to be reported in the waste section
• Other Farm waste e.g. dead animals. Some confusion as to whether to report D/R as ultimate fate is often fertiliser or land spreading
• Non-process related waste does not need to be reported (e.g. municipal office waste, demolition waste)
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Overseas waste transfers• Operators need to report who they are sending the
waste to, and what it’s final destination is• In the UK it is illegal to send waste overseas for
disposal – so we are only expecting waste sent for recovery to be reported
• Where the waste is taken overseas by a waste carrier, the producer of the waste needs to report it’s final destination
• If the waste is sent to a waste management facility, and is sorted and then snet overseas. The waste management facility must report the overseas waste transfer
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Guidance & tools 1
• Food & Drink• Cement & Lime• Chemicals• Incineration• Metals (ferrous & non-
ferrous)• Paper & Pulp• Intensive agriculture
• Waste oil estimator• Landfill leachate estimator• Landfill Gas emissions
estimator (Gassim)• Municipal waste water
treatment works estimator tool• Combustion activities• Petroleum activities
All available to download from website• General guidance• Reporting codes document• Sector specific guidance for existing PPC sectors
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Guidance & tools 2• Guidance and tools developed in collaboration with
industry and other regulators
• Sector specific guidance for new EPRTR activities – sent with notice and on website• Mining and quarrying
www.environment-agency.gov.uk/pi
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Lessons learnt• Try to liaise with trade associations, industry
representatives and policy experts in your organisation when writing guidance and communicating with industry
• Provide guidance and tools so it is clear what is expected
• Use electronic data capture to increase accuracy at data entry stage (and reduce administrative burden)
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Questions/discussion
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Alex Hole
Assessment & Reporting Advisor
0044 117 914 2622