2. Hellenic Ministry for the Environment, Spatial Planning and Public Works Greek Experience on the Implementation of EPER REPORTING IN GREECE Η ΕΛΛΗΝΙΚΗ ΕΜΠΕΙΡΙΑ ΣΤΗΝ ΕΦΑΡΜΟΓΗ ΤΟΥ EPER ALEXANDROS KARAVANAS - Chemical Engineer

3. Hellenic Ministry for the Environment, Spatial Planning and Public Works l 1. According to the DECISION 2000/479 Member States shall report to the Commission on emissions from all individual facilities with one or more activities as mentioned in Annex I of Directive 96/61/EC. l The report must include the emissions to air and water for all pollutants for which the threshold values are exceeded; both pollutants and threshold values are specified in Annex A1. What is the EPER

4. Hellenic Ministry for the Environment, Spatial Planning and Public Works 1.Member States shall report to the Commission every three years.2003-2006. 2.The successor of EPER from 2007 and onwards is the EUROPEAN POLLUTION AND TRANSFER REGISTER E- PRTR. 3.“Guidance Document for EPER implementation” 4.Member States shall provide all reported data by electronic data transfer. 5.The Commission assisted by the European Environment Agency will make the reported data publicly accessible by dissemination on the Internet. What is the EPER

5. Hellenic Ministry for the Environment, Spatial Planning and Public Works GUIDANCE DOC. (1) l IDENTIFICATION of FACILITY IDENTIFICATION l 1.Identify each facility with Annex I activities l 2.Select for the facility the NACE code, source categories and corresponding NOSE-P codes l 3.Select the main activity and its NOSE-P code l 4.Report the facility if at least the emission of one pollutant exceeds the threshold value

6. Hellenic Ministry for the Environment, Spatial Planning and Public Works GUIDANCE DOC. (2) EMISSION DETERMINATION l 1.Select all pollutants released from the Annex I activities (by use of sector-specific sub-lists) l 2.The emissions include all facility releases, but non- Annex I releases can be excluded l 3.Report the emission data for all pollutants exceeding the threshold values as releases to air, direct and/or indirect releases to water l 4.Report each of the emission data (in kg/year) with its determination method (M, C, E)

7. Hellenic Ministry for the Environment, Spatial Planning and Public Works GUIDANCE DOC. (3) INDIVIDUAL REPORTING 1. Report for each facility individually according to the (electronic) format of Annex A2 2.Specify the main Annex I activity and corresponding NOSE-P code 3.Report the emission data for the facility as totals for all pollutants exceeding the threshold values of Annex A1

8. Hellenic Ministry for the Environment, Spatial Planning and Public Works GUIDANCE DOC. (4) AGGREGATED REPORTING 1. Specify the source categories according to Annex A3 and select the NOSE-P codes 2. Sum all individually reported emission data for identical main Annex I activities and also for identical main NOSE-P codes 3.Report the national emission totals for all pollutants by source category as aggregated by Annex A3 category and NOSE-P code

9. Hellenic Ministry for the Environment, Spatial Planning and Public Works IMPLEMENTATION The EPER Decision legally implemented in Greece l Type of legislation : Ministerial Decision and Note by the General Secretary of the Ministry for the Environment. a) Ministerial Decision KYA 11014/703 /F 104/2003, article 12.3.i.”Environmental appraisal,Evaluation and permitting procedure.Environmental Conditions Decision contents.”. a) Ministerial Decision KYA 11014/703 /F 104/2003, article 12.3.i.”Environmental appraisal,Evaluation and permitting procedure.Environmental Conditions Decision contents.”. b) Note by the General Secretary 117266 /27-5-2003, Implementation of the provisions of article 12.3 of της KYA 11014/703 /F 104/2003 regarding the obligation of sending information to the responsible authorities for releases (emission and wastes). b) Note by the General Secretary 117266 /27-5-2003, Implementation of the provisions of article 12.3 of της KYA 11014/703 /F 104/2003 regarding the obligation of sending information to the responsible authorities for releases (emission and wastes).

10. Hellenic Ministry for the Environment, Spatial Planning and Public Works Data Collection l Identification of IPPC facilities from Environmental Permits l Pathway of EPER data collection was directly from facilities to the Ministry for the Environment. l Between7./.2003.and11./2003., on paper and partially by e mail. l The checking of the data the correction validation and all the necessary procedures was made by the Chemical Engineer’s Scientific and Educational Centre under a contract with the Ministry for the Environment).

11. Hellenic Ministry for the Environment, Spatial Planning and Public Works PROCEDURE-ΔΙΑΔΙΚΑΣΙΑ(1) l The approach we have taken relied heavily on submission of data by the sites themselves. l existing environmental condition permits data and previous data compilations to identify potential IPPC facilities. compilations l Out of an initial database of 556 potential IPPC sites, (321 ) were identified finally as IPPC facilities. (at the moment) l 82 reported.

12. Hellenic Ministry for the Environment, Spatial Planning and Public Works PROCEDURE-ΔΙΑΔΙΚΑΣΙΑ(2) l The report has been assembled according to the specific rules set out in the “Guidance Document for EPER Implementation”. l The Guidance Document DOES NOT REFER TO METHODOLOGY OF REPORTING FROM FACILITIES TO AUTHORITIES l However, certain Annex I Activities have been deliberately omitted from the report.

13. Hellenic Ministry for the Environment, Spatial Planning and Public Works Procedure (3). Checking the data submitted l Permits l Interviews l Federations-Unions l Additional data and details

14. Hellenic Ministry for the Environment, Spatial Planning and Public Works PROCEDURE(4). Verification, completion of the data l Completion with calculations using emission factors and permit data. l Comparison of the data submitted with determination using calculation with approved emission factors. l CORINAIR-IPCC, BREF l Notice to all the facilities for any objection on the corrections and acceptance of the data. l Notice to the 82 reported facilities for their reported emissions to the Commission.

15. Hellenic Ministry for the Environment, Spatial Planning and Public Works PROCEDURE(5). VALIDATION - REPORTS l We use Commission’s tools Commission’s toolsCommission’s tools l The contractor in contact with CDR l Final reports l Reports to the Comission Reports to the Comission Reports to the Comission l Uploading to CDR Uploading to CDR Uploading to CDR l EPER SITE SITE l Future Corrections

16. Hellenic Ministry for the Environment, Spatial Planning and Public Works PROCEDURE(6). Database of the results l Excel Data base l Update of our existing Access data base with the results

17. Hellenic Ministry for the Environment, Spatial Planning and Public Works Main Problems and findings(1) l Often usage of the results for other purposes l The determination of the releases. Lack of Knowledge. l The contractor very often (more than 70% ) had to contact the facility operators in order to clarify missing data or other details

18. Hellenic Ministry for the Environment, Spatial Planning and Public Works Main Problems and findings(2) l Time enough for the preparation and compilation l Way of the submission of the data l Lack of Information l Training of the responsibles of the reporting facilities

19. Hellenic Ministry for the Environment, Spatial Planning and Public Works Main Problems and findings(3) l Poultry and swine intensive farming a very large number of small, personal and family businesses with limited resources, for the most of them, to provide elaborate data at request. and moreover, we have found that the IPPC capacity threshold for these sectors is far lower than justified by the quantities of pollutants actually emitted l Landfill sites Most of the landfill sites now operating, were only at development stage or less in year 2002. Therefore, pollutant data for the sector would be non-representative and best not reported.

20. Hellenic Ministry for the Environment, Spatial Planning and Public Works FUTURE ACTIONS for 2004 l Correction of the submitted data l Reexamine and completion of the IPPC facilities list for the next Reporting. New thresholds. l Methodology and Tools for the Reporting from facilities to the Authority l Methodology for assessing the quality of the data l Better Information and Collaboration

21. Hellenic Ministry for the Environment, Spatial Planning and Public Works FUTURE ACTIONS for 2004 (2) l Development of an electronic system including the monitoring of the permits an the eper emissions l Starting Preparation for the E-PRTR obligations ( 86 pollutants,56 activities, annual reporting, ( 86 pollutants,56 activities, annual reporting, releases to land, off-site transfers of waste,diffuse releases to land, off-site transfers of waste,diffuse sources(voluntarily),public participation in decision sources(voluntarily),public participation in decision making ). New Regulation. making ). New Regulation.