The IPPC Directive and EPER

Iksan van der Putte

Objectives of IPPC (Integrated Pollution Prevention and Control)• To prevent or minimise emissions• To provide a high level of environmental

protection for the environment as a whole• To minimise the consumption of raw

material and energy• To simplify and strengthen the role of the

Control Authorities

The IPPC Licensing System• controls

– Effluent discharge– Emissions to air– Waste management– Noise– Related activities

• from Specified Activities• with

• IPPC: Integrated stand for Individual balance of cost and benefit. All aspect in one permit.

• IPPC: Pollution is all that may be harmful to human health and to the quality of the environment. Include Energy consumption and waste production => BAT shall be use to prevent Pollution but also to conservation of energy and waste minimization

• IPPC: Prevention comes before control (can take more time)

IPPC free interpretation !

Air

Land/soil

Water

Energy efficiency

Raw materials

Waste Generation

Noise

integrated approachPrevention of Accident

… and restoration of the site upon closure.

integrated approach

Best Available Techniques(BAT) means...

Best = Most effective and advancedAvailable = Commercially available

and demonstratedTechniques = Technology and operating

practices/managementto reduce impact on the environment as a whole

ESTABLISHING Best Available Techniques (BAT)

• The ‘competent body’ / environmental regulator in Member States

• i.e. determined for specific installations according sector and local issues

• you will get different BATs in different places and different countries

• there is no ‘single’ BAT for a certain type of industrial activity

Issues considered in identifying BAT(a balanced judgment)

Identification of BAT

Costs and benefits of measure

Achievable emissions

Environmental impacts – air, land, water

BREF’s

Energy use

Technical reliability

Installation time

Use of BAT in IPPC

IPPC Permit

Emission limit value & other conditions

Level of control achievable by BAT

Other issues:

- local environment

- geographic location

- technical characteristics

EQS

IPPC Licensing appliesto these sectors

• Energy Industries• Production and Processing of Metals• Mineral Industry• Chemical Production• Waste Management• Other Activities (but excluding Nuclear)

The Directive lists the activities covered by IPPC under 6 main headings and 31 sub-categories (Annex I)

Total 56 industrial activities

“Other Activities” includes...

• Pulp, Paper, Timber

• Dyeing of Textiles

• Tanneries

• Slaughterhouses

• Food Processing

• Milk processing

• Disposal of dead Animals

• Intensive rearing of Poultry and Pigs

• Use of Solvents for surface treatment

• Manufacture of Carbon

Some categories include activities of all sizes e.g. Manufacture of Fertilisers

Other categories have specified thresholdse.g. Slaughterhouses with a throughput exceeding 50 t/d

Does IPPC apply to all sizes of enterprise?

What is a PER?

An integrated database with emission data or pollutant releases associated from identified facilities which is accessible to the public

EPER: European Pollutant Emission Register

IPPC Directive - Article15 (3)

Article 15 (3) states:-

“An inventory of the principal emissions and sources responsible shall be published every three years by the Commission on the basis of the data supplied by the Member States. …………………….”

PER - Commission Decision

Commission Decision 2000/479/EC detailed the measures Member States must take to implement Article 15 (3) of the IPPC Directive.

Requirements

The Decision requires Member States to supply data about IPPC facilities (every 3 years) under the following headings:

• Releases

• Time

• Pollutants (above a threshold)

• Sources

• Locations

Releases

The report must include the direct releases to air and water as well as the indirect release by transfer to an off-site wastewater treatment plant;

Releases to land or groundwater, transfers of waste and on-site transfers are not included..

Time

The release year will make it possible to follow trends and analyse emission reductions as a result of the achievement of industrial sectors;

The EPER has started in 2003 with a reporting frequency of 3 years.

Pollutants

The emission data must be reported for a list of 50 pollutants (chemicals or groups of chemicals), of which 37 substances for air and 26 for water,

Waste is excluded from the reporting obligations.

Sources

The emissions of about 20,000 individual facilities covered by the IPPC Directive must be reported together with an identification code of the industrial sector, so that the data can be aggregated and compared for both sectors and countries.

Locations

The site of the facility must be identified geographically, so the data can be used for modeling and calculations of the concentrations in ambient air

ObjectivesThere are several objectives of a PER. Some the key ones being:

• provides data to aid governments in developing environmental policy;

• it is a public instrument for governments to monitor environmental policies;

• a tool to enhance public awareness of environmental pollution.

BenefitsA PER can have several benefits:

• harmonises reporting requirements and avoids duplicate reporting by industry;

• provides additional information to prioritise enforcement of permit compliance;

•it enables facilities to compare their performance with similar facilities.

EU Goals

The goals of the EPER (from the Commissions point of view) are related to different groups of users:

•Government

•Public

•Industry

Selected PollutantsThe selection criteria for putting substances into Annex 3 (of the Decision) were based on the environmental significance of the pollutants and are as follows:

• considering the Annex III list of the Directive and making a differentiation between air & water;

•pollutants for which international reporting requirements already exist;

•having both individual chemicals and groups;

•including pollutants for both air and water.

QualityQuality Assurance: responsibility of Government & Reporting Industries;

Quality Control: responsibility of Government.

Quality of reported data is the accumulated result of the following aspects:

• Timeliness;

• Completeness;

• Uncertainty;

• Comparability;

•Consistency; and

•Transparency.

Determination Methodologies

The EPER database indicates for each data set what methodology was used to determine the emission data. These are:

M = measured using standardised or accepted methods;

C = based on nationally or internationally accepted estimation methods;

E = based on non-standardised estimations or expert guesses

Timetable

The timetable for the EPER, originally, was as follows:

• first reporting by Member States June 2003;

• second reporting by member states June 2006;

• after review a decision should be taken as to whether to move to annual reporting;

• from 2008 the Member States will be encouraged to report the annual data in December rather than June of the following year.

The “Future” of EPERAfter each reporting cycle the whole aspect of the EPER is to be reviewed. Possible changes (currently being accomplished) include:

• the reporting frequency may change;

• the contents of the list of pollutants and the thresholds may change;

• the facilities that have to report may be expanded beyond those covered by IPPC

• expansion of the scope of the EPER into a fully integrated PRTR

PER: Responsibilities

There are 3 bodies with differing responsibilities associated with the functioning of the EPER:

• Industry (IPPC Processes);

• Government;

• The Commission (& the EEA).

Industry Functions• Identify those substances which are in Annex 3 of the Decision which the plant emits above the thresholds in that Annex;

• Calculate the amount (kgs/year) released;

• Report to the to the competent authority in a timely manner.

Government Functions

• Identification of facilities with Annex I Activities;

• Identification of Source Categories & NOSE-P Codes;

• Collection of Data;

• Validation of Data (Quality Control);

• Submission of data to the Commission

Commission Functions

• Receipt of data;

• Consistency checking;

• Compilation of data;

• Dissemination of data;

• Issuing of Guidance;

• Review of methodology.

Examples of Situations with Various Sites, Facilities and

Activities

Example 1Fa cil ity Q , O pe ra t o r Q

O n-s iteW W T P A

No n -I PPC A ct iv ity

S urfac e T reatm ent of M etals &P las tic s

N O S E-P 105.01M a in I PPC A ct iv ity

S UR FA C E W A TER

R .4R .3

R .2

R .5

M etal Indus tryN O S E-P 105.12I PPC A ct iv ity

Com bus tion P roc es s > 50M WN O S E-P 101.02I PPC A ct iv ity

O ther Ins tallationsNo n I PPC A ct iv it ie s

R .6

Fa cil ity Q , O pe ra t o r Q

S urfac e T reatm ent of M etals &P las tic s

N O S E-P 105.01M a in I PPC A ct iv ity

R .1

Releases to WaterReportingUnit

NOSE_P Release Reporting Requirements Comments

Facility P Surface treatmentof Metals andPlasticsSurface treatmentof Metals andPlastics

R.1

R.2

Reported as indirect release towater

Reported as direct release towater

Facility Q Surface treatmentof Metals andPlasticsOtherInstallationsOn-site WWTP BMetal Industry

R.3

R.4

R.5R.6

Not to be reported

Not to be reported

Sum of R.5 & R.6 to be reportedas direct release to water

Non IPPC activitiesare allowed to beexcluded

Releases to Air

ReportingUnit

NOSE_P Release Reporting Requirements Comments

Facility P Surface treatmentof Metals andPlastics

All To be reported

Facility Q Combustionprocess; metalindustry; surfacetreatment ofmetals & plasticsOtherInstallations

All

Optional

To be reported as the sum ofemissions from all 3 processes

Can be excluded Non IPPC activitiesare allowed to beexcluded

Example 2

Fa cility R , O pe ra t o r R

Fa cili ty S , O pe ra to r S

Fa cility T, O pe ra to r TW W T P B

Non -I PPC A ct iv ity

M anufac tu re of organic c hem ic als(p roduc tion o f VC)

N O S E-P 105.09M ain I PPC A ct iv ity

M anufac tu re of organic c hem ic als(p roduc tion of P VC)

N O S E-P 105.09I PPC A ct iv ity

Com bus tion P roc es s > 50M WN O S E-P 101.02I PPC A ct iv ity

O ther Ins tallationsNo n I PPC A ct iv it ie s

M anufac tu re o f Carbon orG raphite

N O S E-P 105 .09M a in I PPC A ct iv ity

No n -f a cility D o m e s t icW a s t e wa te r

S UR FA C E W A TER

R .8R .7

R .9

R .1 0

Releases to Water

ReportingUnit

NOSE_P Release Reporting Requirements Comments

Facility R Carbon orGraphite

R.7 Reported as indirect releaseto water

Facility S OrganicChemicalsOtherInstallations

R.8 Reported as indirect releaseto water

The contribution from “Otherinstallations” to release R.8 isallowed to be excluded in thereporting for Facility S

Facility T WWTP B R.10 Not to be reported Is non-IPPC activity

Releases to Water - Combined Facilities(exception- ref service contract)

ReportingUnit

NOSE_P Release Reporting Requirements Comments

Facility T WWTP B R.10 Reported as direct release towater

Use the main IPPC Activity andcorresponding NOSE-P code of thefacility (R or S) which contributesmost to R.10 in the report onFacility T.

Releases to Air

ReportingUnit

NOSE_P Release Reporting Requirements Comments

Facility R Carbon orGraphite

All Reported

Facility S OrganicChemicals

OtherInstallations

All

Optional

Reported as the sum of emissionsfrom basic organic chemicals andcombustion processCan be excluded Non IPPC activities may be

excluded

Reporting Information Flow

Monitoring

RIEW

ECCommission

RIEW

Annual report

(aggregated)

BEEA

Annual report

(aggregated)

CommissionIPPC review

EIONet

EPER/PRTR

Art 15.3

Enterprise

annual report

(detailed)

Non IPPC

Registration

AmbientMonitoring

ExEA

MOEW

EC

database

Art 16.1+3

EEA

Example Bulgaria

RIEW: Regional Inspectorate for Environment and WaterMOEW: Ministry of Environment and WaterExEA: Executive Environment Agency; EEA: European Environment Agency

I think you have a problem

EPER

“Industry and government should co-operate to get EPER moving into the right direction”