1. Pollutant Release and Transfer Register Expert Group Meeting
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French PRTR Pollutant Release and Transfer Register Expert Group Meeting 27 October 2009
Cindy LETROUVE – Ministry in charge of environment
Christophe LESCOT – INERIS
16/09/2018
Pollutant Release and Transfer Register Expert Group Meeting
Ministère de l'Écologie, de l'Énergie, du Développement Durable et de la Mer
en charge des Technologies vertes et des Négociations sur le climat

2. SUMMARY Data collection Assessment Reporting toitototototoot 3 6 12
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018

3. Data Collection Notification website GEREP as national system
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Data Collection
Notification website GEREP as national system
All E-PRTR facilities
Notify the pollutant emissions
Possible modifications of data
Validate the notification
Operator
Website « GEREP »
All inspectorate
Manage the facility sessions
Manage the notifications
Check the notifications
Validate the notifications
Local authority
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018

4. Data Collection Notification website GEREP as national system
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Data Collection
Notification website GEREP as national system
Integrated collection : E-PRTR regulation, trading emissions directive, LRTAP (EMEP, Göteborg protocols), CCNUCC (Kyoto protocol)…
2 user interfaces : facilities and inspectors (departmental / regional / national)
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018

5. Data Collection Calendar 2009 toitototototoot
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018

6. Assessment 3 levels of controls : Operator controls
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Assessment
3 levels of controls :
Operator controls
Inspectorate controls
Ministry controls
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018

7. Assessment 1. Operator controls :
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Assessment
1. Operator controls :
Sector of activities guidelines carried out by sectorial organizations as an help for reporting
Automatic controls by the application GEREP. Dysfunctions gathered on a specific page in the electronic notification :
Notification conduct (depend on characteristics of facilities) => mandatory data, prevent from validation, warning information
Anomaly detection => explanations/justifications required for validation :
Data missing
Important variations of values compared with those of year before
Exceeding of limit values fixed for each pollutant
Other controls :
Mandatory data, checking of data format, automatic reckonings, free area as a minimum, choice in lists of values as a maximum (unrolling lists)
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018

8. Assessment 2. Inspectorate controls :
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Assessment
2. Inspectorate controls :
Gathering of the notified data in an EXCEL table => comparisons
Examples : activities sector, linked data (expl : volume of released water and emission in water)
Access to the all notification of each facilities (in particular to the page gathering the different anomalies detected by the application and the explanations of the operator)
Controls on reckoning sheets (containing consumption of combustibles, emission factor, details on process…)
Comparisons of the notified data with data collected further to unexpected controls and to mandatory monitoring of releases (French regulation)
Exhaustiveness, consistency (previous-yeared data, sector data, regulation thresholds, …
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018

9. Assessment 2. Inspectorate controls :
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Assessment
2. Inspectorate controls :
If there is a lack of data or if data are wrong, the inspector can put the notification form in review in order that the operator rectifies or justifies his data.
Monitoring for management of operators notification :
visualization of notification states
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018

10. Assessment 2. Inspectorate controls :
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Assessment
2. Inspectorate controls :
If there is a lack of data or if data are wrong, the inspector can put the notification form in review in order that the operator rectifies or justifies his data.
Monitoring for management of operators notification :
visualization of notification states
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018

11. Assessment 3. Ministry controls :
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Assessment
3. Ministry controls :
All data are gathered in a data base => comparisons (at a national scale)
Access to the all notification of each facilities
Other controls : for examples
Administrative data : geographical coordinates (missing or wrong, comparison with the geographical coordinates of the town)
General data : missing data, missing facilities
Water data :
Consistency of type of release (direct or transfer) and emissions
Ratio between Total organic carbon (TOC) and Chemical Oxygen Demand (COD)
the 10 bigger emitters for each pollutant
Directive 2009/90/EC : emission estimated when the value is below the limit of quantification
Air data :
Trading emission data
The 10 bigger emitters for each pollutant
Waste :
Comparison between production and treatment
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018

12. Reporting Problems encountered for the 2007 reporting : NACE Code
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Reporting
Problems encountered for the 2007 reporting :
NACE Code
TOC / COD
Methods
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018

13. toitototototoot
Reporting
1. NACE code
NACE Code rev.1 applies to data until 2007 included.
But validation tool required NACE Code rev.2.
For the 2007 reporting, we had to collect NACE Code rev.2 during the 2008 data notification by operators.
And to complete missing data with NACE Code rev.2 (correlation table between rev.1 and rev.2)
Conclusion :
Use the referential corresponding to the data and reference year
Otherwise inform Member States in advance (one year before the data collection).
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018

14. Reporting 2. TOC / COD TOC if presence Otherwise COD/3
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Reporting
2. TOC / COD
To ensure the completeness of data, as required by E- PRTR regulation, France reported for 2007 :
TOC if presence
Otherwise COD/3
COD as chemical organic demand, represents the quantity of oxygen used by oxidizible matter contained in one litre of effluent.
TOC as total organic carbon, represents the part of organic compounds, volatile or not, natural or synthetic.
TOC = COD / 2,67 (Gray et Becker, 2002)
TOC = COD / 3 (urban waste water)
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018

15. Reporting 2. TOC / COD Explanations : COD Method : TOC Method :
Method allowing to oxidize the most of organic compounds
Some of them, very volatile, are released during the addition of sulphuric acid and the heating
Some of them are partly oxidized (lactic acid) or very little oxidized (pyridine, aromatic hydrocarbons, …)
Disturbance when chloride concentration is higher than 1,5 g/l
TOC Method :
Less subject to interference comparing to COD method
During the first step consisting in rid the sample of inorganic carbons, volatile organic compounds can be released from the sample (benzene, toluene, chloroform, cyclohexan)
Urea measured by this method but isn’t by the COD method
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018

16. Reporting 2. TOC / COD Examples : Centre technique du papier, 1990
Compound
Chemical formula
Solution (mg/l)
COD (mg/l)
TOC (mg/l)
DCO/COT
Methanoic acid
HCOOH
1000
348
261
1,33
Ethanoic acid
CH3COOH
900
960
360
2,67
Butyric acid
C3H7COOH
500
909
272
3,34
Methanol
CH3OH
1500
375 4
Glucose
C6H12O6
969
363
Phenol
C6H6O
3574
1149
3,11
Chlorophenol
C6H5OCl
2428
840
2,89
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018

17. Reporting 2. TOC / COD toitototototoot
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018

18. Reporting 2. TOC / COD : Conclusion :
For TOC data coming from COD data, unless otherwise specified from the European Commission or from others Member States, we will apply the ratio 3 for reporting year.
Does further thought need to be given to the ratio and to a possible rule of conversion which takes into account the sector of activities ?
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018

19. Air / water / soil / waste
Reporting
3. Methods
Free texte area for international calculation method when validation tool needs a list of well-defined values
Weigh method for waste added to the application for the reporting year
=> involve a manual identification for each data (2007 and reporting year)
GEREP
EPRTR
Référence
Milieu
M (Measure)
INT
Air / water / soil / waste
CEN/ISO
Air / water / (soil ?)
C (Calculation)
ETS
Air
IPCC
UNECE/EMEP
Weigh -
WEIGH
Waste
ISD
Air / water / soil
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018

20. Reporting 3. Methods Solution :
To help operators in notifying, inspectors in controling and ministry in comparing data, a well-defined list of methods needs to be drawn up.
In France, for example :
Measure / INT /
All norms of measure in E-PRTR guide
Norms used by operators (after checking)
Measure / NRO /
Only mandatory norms in departmental order
Measure / PER /
Mandatory norms in departmental order
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018

21. Reporting
3. Methods
For International and European measure methods, the European Commission could place an up-to-date list as a frame of reference at the disposal of the Member States.
Motivation
Example of polychlorinated biphenyls (PCB) :
Two methods of measure :
The first based on dioxine-like congeners
The second based on the all 256 congeners
As the case may be, the emission of PCBs can be multiplied by 2
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018

22. Conclusion
Use frames of reference which match with the data and especially with the reference year
Place an up-to-date lists of method as referential at the disposal of the Member States
To develop method of calculation, consult for example professional confederations
Reduce free text area in the collection tool in drawing up lists as referential (best quality of data, best use of data – e.g. comparison in a national scale)
Pollutant Release and Transfer Register Expert Group Meeting
16/09/2018