1. 1 Permitting of LCPs, Reporting Obligations on LCPs. ECENA Training Workshop Bristol, March 2008

2. 2 Introduction This presentation, Session 4, addresses: Permitting of LCPs in particular reporting requirements. Reporting obligations on LCPs. E-PRTR Requirements. Streamlining of reporting obligations under proposed Directive on Industrial Emissions.

3. 3 IPPC Process LCPs are subject to the IPPC directive: Deadline for implementation of IPPC directive within Member States (EU27) was 30 October 2007. Estimated that circa. 52,000 installations fell under the directive and at this stage should have an IPPC permit.

4. 4 Irish IPPC Permits Irish permits are all available at www.epa.iewww.epa.ie E.g. Full file for Bord Gais Eireann’s 440 MWe Combined Cycle Gas Turbine and, including application and public correspondence: http://www.epa.ie/terminalfour/ippcApril/ippc- view.jsp?regno=P0830-01 http://www.epa.ie/terminalfour/ippcApril/ippc- view.jsp?regno=P0830-01

5. 5 Permit to Ensure Integrated Approach Specified in IPPC Directive waste Raw materials SO2 CO2 Hg BOD water energy VOCs nois e odou r

6. 6 Permit Conditions Permit must include Emission Limit Values (ELVs) based on BAT. For plants not meeting BAT realistic timeframes to achieve BAT need to be defined. However, techniques or specific technology can’t be specified by permit unless proposed in application, e.g. a management system can be outlined but accreditation to ISO 14001 or EMAS can’t be requested.

7. 7 BAT Conditions for a Permit When defining BAT, particularly for an existing installation, the permit writer needs to consider carefully: Cost and benefits analysis. Time for implementation. Prevention of detrimental environmental impacts. Monitoring and reporting obligations. Control of industrial accidents. Data supporting the above will be in the application.

8. 8 The Aarhus Convention Best practice for environmental approval procedures: Access to information. Public participation protocols. Access to justice. Appeals. Confidentiality issues. Articles 15 and 16 of Codified IPPC Directive 2008/1/EC. Inspector’s report dealing with issues raised by public, see www.epa.ie for projects which received objections.www.epa.ie

9. 9 First UK IPPC Permit UK had operated Integrated Pollution Control for 8 years. New Power Plant (215 MW) using gas turbine for heat and power in large paper factory. Issued in March 2001 after 5 months and 1 request for information. Permit was issued by Environment Agency (EA).

10. 10 Departure form Previous Authorisations Previous authorisations issued by the EA focused on processes in isolation. The new IPPC permits take all aspects of the site’s operations into account.

11. 11 Permit Requirements Many reports on improvement programmes rather than full information at beginning: 1 month - Commissioning of Turbines 3 months Demonstrate Energy Efficiency Noise Management Plans 12 months - Annual Environmental Report

12. 12 Permit Requirements Report every 3 years on: Potential Environmental Improvements including costs and benefits against BAT criteria.

13. 13 Permit Requirements Environmental Management System (EMS) After 9 months the company must submit a report on progress towards certification to ISO 14001 or EMAS.

14. 14 Waste The company EMS must contain procedures to assess the recovery options for each waste stream. Waste oil is collected for off-site recovery or disposal.

15. 15 Emissions to Air Turbine uses natural gas with oil as stand-by. NO X was main concern: Limits were 60 mg/m 3 on gas 125 mg/m 3 on oil Annual mass 640 t

16. 16 Emissions to Air Plant uses low NO X combustion technology. Permit requires continuous monitoring of: oxides of nitrogen carbon monoxide oxygen

17. 17 Emissions to Water Surface water discharge to be continuously monitored for: flow oil in water pH

18. 18 Emissions to Sewer Wastewater discharges to drained to oil separator. Discharges to sewer continuously monitored for: flow oil in water pH

19. 19 Noise Permit requires: The use of acoustic enclosures of the gas turbines. The use of air intake and exhaust silencers. Low noise fans on the air cooled condenser system. Acoustic shielding in design of site layout.

20. 20 Land Contamination Application form showed some contamination because of former use as steelworks. The Permit prohibits releases to land. Requires operator to get approval from the Agency for changes to the site.

21. 21 Reporting Obligations - Operators Article 13 of LCP Directive 2001/80/EC requires that the operator informs the competent authority within reasonable time limits about: Results of continuous measurement. Checking of the measuring equipment, required by Annex VIII at least every year. The individual measurements and all other measurements carried out for compliance.

22. 22 Reporting Obligations - Authorities Annex VIII of LCP Directive 2001/80/EC requires that the Member States shall establish each year an: An inventory of SO 2, NOx and dust for each plant. The competent authority shall obtain for each plant: Total annual emissions of SO 2, NOx and dust. Total annual energy input in categories of fuel: Biomass, other solid fuels, liquid fuels, natural gas, other gases. Year by year plant data to be made available to the Commission on request.

23. 23 Reporting Obligations - Authorities Annex VIII of LCP Directive 2001/80/EC requires that the Member States shall provide to the Commission an annual report on ‘End of Life’ plants, Article 4(4): A record of used and unused time allowed for the plants’ remaining operational life. Same annual report required for plants on derogations; Article 5 or Annex III and VIA.

24. 24 Reporting Obligations - Authorities Article 15 of LCP Directive 2001/80/EC requires that the competent authority provide the Commission with a summary report on the progressive reduction of total annual emissions from existing plants: At the latest one year after the end of the different phases for reduction of emissions from existing plants. An intermediate report is required in the middle of each phase.

25. 25 Reports – Where do they end up? Most of the reports submitted on environmental data from Member States and other European Countries can be found on European Environment Agency’s data repository: http://cdr.eionet.europa.eu/ Note first annual LCP submission was 31/12/07.

26. 26 EPER Map of South Western UK

27. 27 EPER E-PRTR 50 Pollutants 56 IPPC Activties Reports every 3 Years Emissions into Air and Water Emissions into Water (indirect) 91 Pollutants 65 Annex I-Activities Annual Reporting Emissions into Air, Water and Land Accidential Release Transfer of Pollutants into Waste Water Waste Transfer (non-haz./haz. waste) Emissions from diffuse Sources Public Participation EPER  E-PRTR

28. 28 Relevant E-PRTR Compounds for LCPs Main Compounds Carbon monoxide: CO Carbon dioxide: CO 2 Nitrogen oxides: NOx/NO 2 Sulphur oxides: SOx/SO 2 Particulate Matter: PM 10 Trace compounds Heavy metals such as Hg, Cd. Dioxins

29. 29 Annual Reporting E-PRTR 1. Report 2007 20082009 Reported year 15.6.08 (31.7.08) Operator to Competent Authority Competent Authority to National Authority National Authority to EU COM 15.2.2009 30.6.2009 2. Report 200820092010 Reported year 31.5.09 (30.6.09) 31.12.2009 31.3.2010 n. Report nn + 1 Jahrn + 2 Jahre Reported year 31.5.n+1 (30.6.n+1) 31.3.n+2 31.12.n+1 29

30. 30 Useful Links on E-PRTR Commission PRTR Site: http://ec.europa.eu/environment/ippc/eper/index. htm http://ec.europa.eu/environment/ippc/eper/index. htm German PRTR site: www.prtr.dewww.prtr.de Irish PRTR Site: http://www.epa.ie/whatwedo/enforce/lic/prtr/ http://www.epa.ie/whatwedo/enforce/lic/prtr/ EPER Site: http://www.eper.ec.europa.eu/eper/http://www.eper.ec.europa.eu/eper/

31. 31 Comparison EPER vs E-PRTR EPER represents the basis for E-PRTR Supplementary information in E-PRTR  Additional + Pollutants, Waste, etc. Diffuse Emission Sources  Traffic, Agriculture, Aviation, etc. E-PRTR involves more that the operators & Authorities Annual Reporting  More Data

32. 32 Reporting Requirements for New Directive on Industrial Emissions EU recognises that existing requirements are bureaucratic with duplication of effort. Goal of new directive is to streamline reporting requirements for both operators and authorities: Estimated savings €105 to €255 million per year.

33. 33 Questions?