A push for cleaner industrial production - EEB

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A PUSH FOR CLEANER INDUSTRIAL PRODUCTION Enforcement The Problem Site inspections are key tools for ensuring compliance with IPPC. However, the current IPPC Directive contains no concrete obligations with regards to inspections and as a result there is a wide divergence across Member States in terms of the policies and practices in inspecting industrial sites and ensuring compliance 20 . In particular, in some of the new Member States planning is only now underway for the establishment of inspection systems. Although Recommendation 2001/331 provides minimum criteria for environmental inspections (RMCEI) 21 , it is not legally binding and not specific to IPPC installations. Inspections are a prerequisite in order to assess compliance and enable competent authorities to detect leaks or malfunctions of abatement equipment. Where non-compliance goes undetected at an industrial site, the consequences can be devastating. Potential cost of non-compliance: • 10% exceedence of SO ELVs for 1 year 2 • additional 100 tonnes of SO2 • € 0.6-1.6 million Commission, 2007a The Solution In order to minimise administrative cost and encourage compliance, inspection frequencies should be tailored to reflect the compliance record of the installation, the implementation of environmental management systems (EMAS), and the risks associated with the activities. Annual inspections Compliant low-risk installations with EMAS 2 random inspections per year General case 3 random inspections per year Installations where a breach has been detected Additional costs for a minimum frequency of 1 inspection per year for all installations are estimated at about €18 million per year. Considering that currently 52.000 installations are covered by IPPC that would represent about € 350 per year per installation. In addition, industrial operators should provide an annual report on their compliance with permit conditions and their performance against the range of BAT in the BREF. This will provide valuable information to the authorities on how the performance of the installation compares with other similar installations. Such a report can be streamlined with other reporting obligations, for example for the European Pollutant Release and Transfer Register (E-PRTR) and under EMAS. In addition, this information can then be brought into the Sevilla Process when updating the BREFs. 20 IMPEL, 2007 21 Recommendation of the European Parliament and of the Council of 4 April 2001 providing for minimum criteria for environmental inspection in the Member States, 2001/331/EC 22
Sevilla Process and BREFs: The BREFs are high quality technical documents developed by technical experts in a multi-stakeholder group • Participants include representatives from Member States, industry and non-governmental organisations promoting environmental protection • Much of the data upon which decisions are based is submitted by industry, which has significant influence over the final BREF document and the BATAELs therein • The BREF set the European benchmark for environmental performance and are used worldwide • Developing one BREF costs €5-10 million, about €150-300 million over 1997-2007 (Commission, 2007a) The Benefits Such a system will ensure that breaches are quickly detected and that impacts on the environment and human health are minimised. It enhances the prevention of pollution and is based on the polluter pays principle. It will also serve to foster an ongoing dialogue between operators and permitting authorities on BAT. In addition, public confidence in the safety of industrial installations will be bolstered. 23
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Page 3 and 4: A PUSH FOR CLEANER INDUSTRIAL PRODU
Page 5 and 6: Contents Background to the Revision
Page 7 and 8: The Goalposts The proposed Directiv
Page 9 and 10: WATER The Water Framework Directive
Page 11 and 12: The Solutions The recast of the IPP
Page 13 and 14: The Solution: Playing Fair Accordin
Page 15 and 16: BAT-based binding ELVs will deliver
Page 17 and 18: The Solution: Applying BAT(Example
Page 19 and 20: Potential Benefits The benefits of
Page 21 and 22: Co-Incinerating Waste The Problem:
Page 23: Potential Benefits Implementing SCR
Page 27 and 28: The Solution: Baseline Reports The
Page 29 and 30: Source: Commission, 2007, “Report
Page 31 and 32: The Solution: A Differentiated Thre
Page 33 and 34: References AEAT, 2004, “Costs and
Page 35 and 36: Leibacher, U., Bellin, C., Linero,
Page 37 and 38: ENTEC 2008, Table 4.15 The five hig
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