2009-09 - IRI Portugal - FINAL REPORT - IMPEL

• In case there is lack of guidelines and norms for a certain component, IGAOT makes
use of information it can find in other countries. For example, for soil and
groundwater limit values norms have been used from Canada (Ontario norms) and
The Netherlands.
3. Execution and reporting
Objective
Find out how routine and non-routine inspection activities are carried out and
reported and how data on inspections carried out, their outcomes and follow-up is
stored, used and communicated.
Overview
Inspections, reports and notice of violation
All inspection activities are unannounced except for some of the SEVESO inspections.
IGAOT also inspect sites that do not have a permit.
IGAOT do not use warning letters. They issue a notice of violation whenever a noncompliance
is identified. After a notice of violation is issued and notified to the
operator, the operator has 10 days to respond. When operators do not comply after a
notice of violation has been issued, IGAOT has the authority to take the necessary
enforcement measures. When a notice of violation is issued the operator receives the
report jointly with the notification of the violation. Otherwise, the report is sent to the
operator as soon as it is concluded (and approved by management level).
IPPC inspection reports are sent to APA. SEVESO inspection reports are sent to APA,
ANPC, the municipalities and the Permitting Authority for the activity. Whenever CCDR
and ARH had asked for IGAOT’s cooperation to enforce a certain company the
inspections reports are also sent to those authorities.
The reports include a lot of information, for example, all the observations during the
inspection (compliance and non compliance) and the promotion of best practices are
recorded. The review team noted that the time spend in writing an inspection report
was disproportionate in relation to the time taken to conduct the inspection itself. The
review team suggests IGAOT change the procedure for writing inspection reports.
SEVESO accidents
After a SEVESO accident occurs a working group with representatives from APA, ANPC
and IGAOT is formed to analyse the causes and consequences of the accident. The
working group also decides whether the accident has to be reported to the European
Commission. Figure 3 elaborates the process.
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