3rd BERCEN Exchange Programme, Prague WASTE CONDITIONS IN ENVIRONMENTAL PERMITS Mrs. Marianne Lindström, Finnish Environmental Institute, Environmental Management Division

MY PRESENTATION Participants and team Objectives The questionnaire Results from the questionnaire Examples of permit conditions Results from the seminar Conclusions The working process

THE WORKING PROCESS ToR Legal Base, Grant Draft and Final Ques- tionnaire to MS Seminar in Helsinki Final Report Dec.04 Dec. 02June 03Febr. 04 Draft Report Sept. 04 Advisory Comm. Meeting April 03 Sept 04Aug 03Oct 03May 04

PARTICIPANTS AND TEAM Finland has the lead Finnish Environment Institute has the overall responsibility of the project Project leader and project researchers from SYKE Members of the project from EU 14 MS + 1 (AT, BE, CY, CZ, DE, EE, ES, FI, GR, IE, IT, SE, SK, UK and HR) An advisory committee with members from participating countries (AU, DE, EE, UK, IE, FI and CION)

OBJECTIVES This project covers industrial operations excluding landfills and waste incineration plants Improvement of the implementation of IPPC Directive and waste related directives, special focus on waste minimisation Exchange of information Provision of advise Harmonisation of the permitting procedure Harmonisation of the supervision General benefit to IMPEL

 How are the directives implemented legally and practically?  What are the responsibilities of authorities and other organisations?  Are there guidelines for the applicants?  What information is required in the application documents?  What are the specific items in permit consideration?  What kind of permit conditions exist?  Are BREFs useful when assessing waste management?  Are EMS useful tools in relation to permitting?  How do you monitor and report waste conditions?  How do you supervise waste conditions?  Is the access to information and public participation ensured? THE QUESTIONNAIRE

RESULTS FROM THE QUESTIONNAIRE 1/2 Guidance to the applicant (AT, FI, IE, SE and UK) Information required in the application documents –waste amount per production unit (nearly all) –packaging (GR, IT, ES) –product design (CZ, GR, IT) –minimisation of the consumption of single-use products (CZ, DE, GR, IE, IT, UK) –origin, storage, transportation of waste (nearly all) –data on waste recovered & disposed (nearly all) –data on generated hazardous waste (nearly all)

RESULTS FROM THE QUESTIONNAIRE 2/2 All information required in the application is obligatory for permitting Additional requirements for permitting –use of BAT (nearly all) –monitoring programmes –cost-benefit analysis –planned measures for environmental investments –information concerning the education of the staff & training plans (CY, CZ) –environmental liability provisions (IE) –contamination from historical waste mgmt practices, cross media issues (IE)

EXAMPLES OF PERMIT CONDITIONS 1/3 Substituting raw material –the operator can be forced to use less dangerous chemical substances (causing the same effects) in an industrial process in order to reduce the amount of hazardous waste (AU) –The operator shall consider suitable alternative materials to reduce environmental impact (UK) Audits and assessments –the operator shall carry out periodic waste minimisation audits and water use efficiency audits (UK) –the operator shall carry out a systematic assessment and review of the management of all wastes generated… the purpose of the assessment shall be to identify methods of avoiding or reducing the impact on the environment (UK)

EXAMPLES OF PERMIT CONDITIONS 2/3 Plans and programmes –the operator shall make a plan for the management of waste (SE) –the waste management plan shall be approved by the inspection authority (SE) Records of waste –the operator shall maintain and implement a system which ensures that a record is made of the quantity, composition, origin and delivery date of any waste that is received for disposal or recovery at the installation (UK)

EXAMPLES OF PERMIT CONDITIONS 3/3 Minimisation condition the quantity of metal scrap arising in the production shall be reduced in such a way that in year x the respected amount of waste is 5 % less than in year y. (FI) limitation of HCl-production as a by-product and commitment to set up a recovery scheme for inevitably produced HCl (DE) use of certain chemical substances is prohibited, in case a significantly higher potential of risk arises (AU) Measures to minimise the waste amount the operator shall at the latest by year x submit to the competent authority a proposal concerning measures to minimise the total amount of wastes arising in the production (FI) the operator shall in connection with the annual report deliver to the competent authority an account of the implemented measures to reduce the amount and hazardousness of waste during the past year (FI)

RESULTS FROM THE SEMINAR 1/2 KEY ISSUES Variations in practical legal implementation and definition of waste Waste issues in the sector-BREFS are not well described Not enough reliability of data on waste production The permits and permit conditions vary Different approaches about transparency and confidentiality No EU-wide inspection guidance specific to waste prevention EMAS statements too general

RESULTS FROM THE SEMINAR 2/2 GOOD PRACTICE EU-wide guidelines for definitions of waste Improvement of sector-BREFs and the new cross-media BREF Horizontal BREF on waste issues Reliable book-keeping as the basis of annual report Analysing permit conditions for some sectors Transparency should be the general rule EWC-guideline for waste categorisation and classification

CONCLUSIONS Results from the replies to the questionnaire and the compilation of the replies as an annex to the final report Results from the studies on BREFs and other documents Results from the seminar; key issues and good practice Permit conditions concerning waste Final report with overall conclusions