1. SERBIAN NATIONAL ACTION PLAN [DRAFT]
St. Petersburg, October 2009.
SERBIAN NATIONAL ACTION PLAN [DRAFT]
TO THE 1979 CONVENTION ON LONG-RANGE TRANSBOUNDARY AIR POLLUTION ON HEAVY METALS
MILORAD BIJELIC, BSc in chemistry
Provincial Secretariat for environmental protection and sustainable development

2. Steps in NAP development
Analysis of the protocol and
Obligations definition
Analysis of Serbian regulation
Comparison of obligations and current situation
Conclusions
Actions definition
Timeframe and responsibilities
Milorad Bijelic [DRAFT-Serbian NAP on LRTAP on HM]

3. Analysis of the protocol and Obligations definition (Article 3)
Application of BAT’s to new and existing sources
Paragraph 2; Annex III and IV
Application of ELV’s to new and existing sources
Paragraph 2; Annex IV and V
Product control measures
Paragraph 3; Annex VI
Additional product management measures
Paragraph 4; Annex VII
Development and maintainance of emission inventories for the HM
Paragraph 5
Milorad Bijelic [DRAFT-Serbian NAP on LRTAP on HM]

4. Analysis of Serbian regulation [key laws and by-laws]
Law on Environmental Protection(2004)
Regulation on Emission Limit Values, Methods and Time Frame for Measurement and Data Recording(1997)
Law on Integrated Pollution Prevention and Control (Law on IPPC)(2004)
Decree on the criteria for determining of the best available techniques, environmental quality standards and of emission limits values in the integrated permit(2005)
Regulation on the technical and other requirements for liquid fuels originated from oil derivates(2004)
Law on Air Protection(2009)
Law on Waste Management(2009)
Law on Chemicals Management (2009)
Milorad Bijelic [DRAFT-Serbian NAP on LRTAP on HM]

5. Comparison of obligations and current situation*
Relative degree of implementation
Remark
Application of BAT’s to new and existing sources
Legal frame present, implem. Missing
(see also slide 6)
Application of ELV’s to new and existing sources
ELV’s present for certain sources mainly for PM
Product control measures
10% Fuel
100% Batteries
Additional product management measures
Certain products not covered
Development and maintainance of emission inventories for the HM
Inventorie present, not organized, EMEP methodology missing
30%
50%
50%
40%
40%
*Rough estimations made for presentation purposes only
Milorad Bijelic [DRAFT-Serbian NAP on LRTAP on HM]

6. Approximate number of source categories present in the country
Category
Short description of the category according to annex II
No. of installations in Serbia
Translated BREF 1.
Combustion installations… 26 NO 2.
Metal ore (including sulphide ore) or concentrate roasting or sintering installations …
YES 3.
Installations for the production of pig-iron or steel 4.
Ferrous metal foundries … 5.
Installations for the production of copper, lead and zinc from ore… 6.
Installations for the smelting (refining, foundry casting, etc.)… 7.
Installations for the production of cement clinker 3 8.
Installations for the manufacture of glass using lead 1 9.
Installations for chlor-alkali production 10
Installations for the incineration of hazardous or medical waste…
N/A 11
Installations for the incineration of municipal waste -
Milorad Bijelic [DRAFT-Serbian NAP on LRTAP on HM]

7. Emission measuring issues
National accreditation body does not have harmonized approach for methods accreditation;
Self monitoring present only in small percentage of installations;
Key legislation for self monitoring does not exist;
Existing fixed measurements need serious improvement;
Requirements for laboratory competence defined in existing regulation easily fulfilled.
Milorad Bijelic [DRAFT-Serbian NAP on LRTAP on HM]

8. Coclusions 1/2
Although Serbia has a legal frame for cadastre of polluters there is no connection to classification of source categories described in IPPC decree which comply(excluding hazardous waste) with Annex II of the protocol;
There is no national BAT’s adopted;
Timescale given in IPPC law for application of BAT’s is complyent with annex IV;
Current Regulation on Emission Limit Values, Methods and Time Frame for Measurement and Data Recording does not comply with Annex V;
Regulation on the technical and other requirements for liquid fuels originated from oil derivates defines two types of motor petrol (unleade and „leaded“), where only unleaded petrols comply with limit values given in annex VI. Four types of „leaded“ petrols have permissible maximum lead content beyond limit value specified in paragraph 3 of the Annex VI;
Milorad Bijelic [DRAFT-Serbian NAP on LRTAP on HM]

9. Coclusions 2/2
Achievement of concentration levels defined in paragraph 5 of annex VI will be done in the timescale specified in same paragraph;
The minimization or substitution in products of one or more intentionally added heavy metals listed in annex I for mercury-containing: dental amalgam and pesticides including seed dressing;
Althoug integral cadaster of HM listed in Annex I will exist, methodology used is not based on EMEP;
There is no reporting of emission inventories to EMEP.
Milorad Bijelic [DRAFT-Serbian NAP on LRTAP on HM]

10. Actions definition, responsibilities and timeframe 1/4
Action definition
Responsible authority
Timeframe
1. Classification of source categories, in national cadastre of polluters, according to the Annex II of the protocol
MESP-Department for integrated permits
6 months after NAP adoption
2. Determination of priority list for BAT adoption and adoption of national BAT’s trough translation of EU BAT’s taking in account BAT’s in Annex III of the protocol;
1,5 years after NAP adoption
2.1. After completion of Action 1, final determination of number of existing installations for each source category;
3. Enforcement of IPPC law;
MESP-Sector for control and supervision/ Department for environmental protection
2015
3.1. Supervision of BAT implementation in industrial facilities;
immediately
Milorad Bijelic [DRAFT-Serbian NAP on LRTAP on HM]

11. Actions definition, responsibilities and timeframe 2/4
Action definition
Responsible authority
Timeframe
4. Adoption of new Regulation on ELV’s taking in account Annex V;
MESP-Department for Air protection
May 2010
4.1.In cooperation with Institute for standardization of Serbia adoption of CEN or ISO standards concerning emission measurements of HM;
End of 2009
4.2. General definitions concerning measurement, calculations, reference methods etc. as defined in Annex V;
4.3. Adoption ELV’s as defined in Annex V;
Milorad Bijelic [DRAFT-Serbian NAP on LRTAP on HM]

12. Actions definition, responsibilities and timeframe 3/4
Action definition
Responsible authority
Timeframe
5. Adoption of new Regulation on the technical and other requirements for liquid fuels originated from oil derivates which will prohibit usage and marketing of petrol with lead content above 0,015 g/L;
MESP in cooperation with Ministry of Mining and Energy
2012.
6. Enforcement of Law on waste management and Law on chemical management;
MESP-Sector for control and supervision/ Department for environmental protection
immediately
7. Amendments to the Law on chemicals management concerning mercury-containing pesticides and mercury containing dental amalgams;
MESP- Department for waste management
May 2010
Milorad Bijelic [DRAFT-Serbian NAP on LRTAP on HM]

13. Actions definition, responsibilities and timeframe 4/4
Action definition
Responsible authority
Timeframe
9. Implementation of EMEP methodology for formation of HM emission inventories;
SEPA-Group for Pollutant cadastre
12 months after NAP adoption
10. Reporting to the EMEP;
Milorad Bijelic [DRAFT-Serbian NAP on LRTAP on HM]

14. Difficulties and problems likely to be encountered in NAP implementation
All amendments that need to be made to adopted laws;
Adoption of regulations that involve work of two or more Ministries;
Enforcement of IPPC law;
Adoption of by-laws based on newly adopted Laws;
Cooperation between vertical levels of state authorities;
Insufficient level of technical competence in state authorities.
Milorad Bijelic [DRAFT-Serbian NAP on LRTAP on HM]

15. THANK YOU
QUESTIONS?
Milorad Bijelic [DRAFT-Serbian NAP on LRTAP on HM]