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Newsletter Q1 2012

 

Q1 2012 Newsletter

Welcome to our compendium of environmental compliance news items that appeared on our website www.environet.ie over the past quarter. This is a free service, issued every quarter. If you wish to unsubscribe please click the link at the end of this mail.

Due to the success of our IPPC/Waste Licence Management Training Course in October we are running the course again on 25th April 2012. Numbers will be limited so book early. See our website for details.

You can now follow us on Twitter at http://twitter.com/#!/EnvironetIre where our news items will also appear.

Best Regards

Gerard Kelly

 

CONTENTS

Process Water Analysis Available Online (3/2/2012)

Radon in the Workplace (9/2/2012)

Nutrient Reduction in Rivers (21/2/2012)

Waste Contractors – Are you taking risks? (5/3/2012)

Pharmaceuticals in the Environment – A new approach (12/3/2012)

Change to Household Waste Collection Meets Resistance (13/3/2012)

 

Process Water Analysis Available Online (3/2/2012)

Access to a safe drinking water supply is critical for society. For many industries drinking water supplied by the local Water Services Authority also acts as their process water supply. In many cases the quality of that water is critical to both product quality and efficient process operation.

The EPA has recently published drinking water analysis data for 2010 on a county by county basis and this can be accessed here

http://erc.epa.ie/drinkingWater.html

 

Radon in the Workplace (9/2/2012)

It is estimated that as many as 200 deaths per year in Ireland occur as a result of lung cancer caused by exposure to radon. We are all aware of radon exposure in the home but radon exposure in the workplace gets less media attention.

The Radiological Protection Institute of Ireland (RPII) is the competent authority under the legislation. S.I. 125 of 2000 allows the RPII to direct that above ground workplaces in High Radon Areas are tested. High Radon Areas are defined as areas where > 10% of homes are expected to have concentrations above the 200 Bq/m3 level. The RPII Radon Map can be accessed here http://www.rpii.ie/radon-map.aspx.The Health & Safety Authority (HSA) also requires that all indoor work places at basement or ground floor level must have radon levels assessed when they are located in High Radon Areas.

Where workplace concentrations are > 400 Bq/m3 (averaged over 3 months) the business must inform the RPII and include a report addressing the implementation of mitigation measures. Monitoring must then be undertaken after mitigation measures have been implemented to ensure that levels are complied with.

So, in summary, it’s a good idea to have radon concentrations measured regardless of where your business is located. If your business is located in a High Radon Area it’s a requirement.

 

Nutrient Reduction in Rivers (21/2/2012)

Currently the EPA is reviewing IPPC & Waste licenses with a view to ensuring compliance with the Surface Water Regulations (S.I. 272 of 2009). The regulations set new ambient concentration limits which include stricter limits on nutrient (Nitrogen & Phosphorus) concentrations in surface waters.

Over the past 20 years strenuous efforts have been made to reduce nutrient inputs to our rivers, lakes and coastal waters. Excess levels of nutrients can lead to eutrophication which in turn damages ecosystems. Emissions to waters include both point source (industry, municipal wastewater treatment plants etc.) and so called diffuse sources such as those from agriculture.

However there is little information available on the impact on rivers of reductions in nutrient inputs over time. A recent report has shed some light on this issue.

The scientists (Bouraoui F. & Grizzetti B., 2011) found that some river basins experienced increases in nutrient concentrations despite reduced anthropogenic input. Looking closely at two case studies, the Elbe in Germany and the Loire in France, they found that this could be partly explained by a time lag in the transport of excess nitrate into the groundwater as well as by storage of nutrients in soil and aquifers.

For the Elbe and the Loire, the scientists calculated time lags of 8 and 14 years, respectively, but previous research suggests the lag could be up to 40 years for some rivers.

The targets for Ireland, set under the Water Framework Directive, are to achieve ‘good’ nutrient status by 2015, 2021 or 2028. These targets may not be met based on the above research. It is accepted that for most cases in an Irish context, nutrient inputs from diffuse sources (eg agriculture) account for the majority of nutrient discharges to surface waters.

The agricultural sector was encouraged by Teagasc to spread excessively high P loadings on land up until the 1990s. If the impact of this poor advice will really take 40 years to flush through the system then we can expect that ‘good’ nutrient status may not be achieved in some lakes and rivers until the 2030s, regardless of what limits are placed on current point source emissions.

 

Waste Contractors – Are you taking risks? (5/3/2012)

For facilities that are generally compliant with environmental legislation, one of the areas in which they are most exposed is in relation to waste management. In the event of a problem regarding a waste contractor, media coverage will focus on the well known companies who have used the contractor as opposed to the lesser known contractor. We believe that industrial facilities may be exposed for the following reasons;

  • Is the contractor licensed/permitted to take the waste type?
  • Is the waste transported in compliance with the regulations?
  • Is the waste stored appropriately?
  • What is the compliance history of the site?
  • Where is the ultimate waste destination?
  • Are there complaints in relation to the facility?
  • Are waste treatment activities covered by the permit/licence?
  • Does the contractor have waste tracking procedures?
  • Has the contractor developed waste acceptance criteria?
  • Does the site have an Environmental Management System?
  • Is the site operating in compliance with its permit?

While the majority of waste contractors may have an appropriate Waste Permit from the Local Authority, or Waste Licence from the EPA, it may well be the case that overstretched regulators are not adequately policing.

Environet considers that the most appropriate course of action is to audit waste contractors, probably on a three year cycle. The auditing process will allow for a due diligence review of waste contractor activities and will demonstrate that all reasonable steps have been taken to address the risks involved.

For more information contact Gerard Kelly at 058-51155.

 

Pharmaceuticals in the Environment – A new approach (12/3/2012)

Active Pharmaceutical Ingredients (APIs) released to surface waters have been an issue of concern for some time. The vast majority of APIs are discharged to the environment from municipal wastewater treatment plants but regulators have been slow to control such discharges. More attention has been paid to discharges from industrial plants as inputs and outputs are easier to control.

The current method of assessing API impact on the environment is by way of an Environmental Quality Standard called the PNEC (predicted no effect concentration) for the API of concern. This is compared to the PEC (predicted environmental concentration) using standard modelling methods to confirm no significant environmental impact.

New research has recently been undertaken which takes into account both short term and long term impacts as a result of discharges of APIs. A number of new parameters called ERCs (environmental reference concentrations) are proposed for long term exposure. ERCaquatic for protection of freshwater organisms such as fish, ERCmarine for protection of marine organisms, ERCpredator for protection of Otters etc. and ERChuman for protection of humans. Another group of parameters called MTCs (maximum tolerable concentrations) have been developed to give an indication of maximum allowable concentration over the short term (24 h).

30 APIs were assessed under the above system and its interesting to note that in some cases ERCaquatic was not the lowest concentration, meaning that humans or predators could be more sensitive to particular APIs.

For more information contact Gerard Kelly on 058-51155.

 

Change to Household Waste Collection Meets Resistance (13/3/2012)

In June 2011 the Department of the Environment, Community and Local Government published a discussion document ‘Altering the Structure of Household Waste Collection Markets’. The main policy change involves ‘franchise bidding’ from waste companies for the right to collect waste in a particular Local Authority area. The current system allows waste companies to offer services wherever they see fit. In some areas this gives residents the option of a number of providers and has in general brought more competition and keener pricing.

In general the Government appears to want to address the following;

  • It is considered that charges are high.
  • Source reduction is not incentivised.
  • It is considered wasteful for more than one service provider to provide a service in a particular area.
  • It is envisaged that the franchisee would be required to provide a service for the entire area. In some counties household waste collection is available to < 40% of households.
  • Give power back to Local Authorities in relation to waste collection
  • Rebalance the current situation where City and County Managers have the final say in relation to waste issues and give more power back to Councillors.

The local waste sector is very much against the new proposal as its likely that only the largest, or multinationals, will have the wherewithal to meet tender criteria. They point to the fact that waste disposal costs have reduced over the last number of years and that increased competition has resulted in more innovation and investment in infrastructure. Many also believe that the proposed new policy may be an attempt to allow waste to be diverted to the proposed new incinerator in Poolbeg where Dublin City Council must meet a contractual commitment to supply at least 320,000 t per annum.

On reviewing the proposed new policy, and many of the responses to it, it could be concluded that while the current system has many benefits and efficiencies it does not address the problem that 15% of households nationwide are not provided with a waste collection service. One approach would be to issue Waste Collection Permits to waste contractors for particular Local Authority areas that stipulate, for example, that all households must be offered a service and at the same price. Or that all waste collections must be by weight to incentivise reduction at source. Consumers could still choose based on price and quality of service and most national waste policy issues would be addressed using the conditions in the permit.

The consultation period for the proposed new policy closed in September 2011 and a decision is expected soon.