Newsletter Q2 2011
Welcome to our compendium of environmental industrial 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.
**Please note that Environet is running an IPPC Licence Management Training Course on 12th October 2011 in the Radisson Hotel, Little Island, Cork. See our website for details.**
Gerard Kelly
CONTENTS
Solvent Use – How should industry comply? (28/4/2011)
Changes at IPPC and Waste Licensed Facilities (23/5/2011)
Reporting Incidents to the EPA (7/6/2011)
Industrial Emissions Directive – Some Implications (17/6/2011)
Save Money! – Change your monitoring frequency (20/6/2011)
IPPC Licence Management Training Course – Enroll Now! (24 June 2011)
Solvent Use – How should industry comply? (28/4/2011)
The use of solvents in Ireland comes under 2 distinct regulatory regimes, IPPC and AIC.
IPPC
The EPA is the regulatory authority in Ireland for the implementation of the IPPC Directive. While the IPPC Directive of 1996 specified an annual consumption threshold of 200 t per annum, its implementation in Ireland set the annual threshold limit at just 10 t.
AIC
The Solvents Directive of 1999 is implemented in Ireland through the Solvents Regulations (SI 543 of 2002). Where a facility comes under the regulations and does not require an IPPC licence, the facility must obtain an annual compliance certificate from the Local Authority. The compliance certificate is issued following acceptance of a report issued to it by an AIC (Accredited Inspection Contractor).
The AIC regime generally applies to smaller activities, however due to the low IPPC threshold there are activities that are not covered by the Solvents Directive but are covered by IPPC. For example under the Solvents Directive the solvent consumption threshold for web offset printing is 15 t per annum, however if you consume > 10 t per annum then the IPPC licensing regime will apply.
Where IPPC applies then the requirements of the Solvents Regulations should be included in the conditions of the IPPC licence.
For further information contact Environet Solutions and see http://www.epa.ie/whatwedo/advice/air/solvents/.
Changes at IPPC and Waste Licensed Facilities (23/5/2011)
What needs to happen when there are changes at a licensed facility that may have an environmental impact? 3 common scenarios are outlined below;
Minor Changes - such as minor changes to process, raw materials, final product and abatement with no impact on emissions.
These are usually accommodated under Condition 1.4 of the IPPC licence which requires the licensee to obtain approval from the EPA but does not involve a Technical Amendment of Licence Review.
Changes - such as moving existing emission points, changing flows (but not increasing mass emissions), increasing mass emissions for a particular emission point but keeping the 'bubble limit' for the site the same or less.
These would normally be accommodated under a Technical Amendment to the licence where the overall mass emission of substances from the site is the same or less, there are no new substances emitted and there is no increased impact on the environment. The Technical Amendment will allow for changes to be made to the licence and is a process that can be completed in approximately 4 months.
Significant Changes - additional emission points, additional substances emitted, increased overall mass emission, increased impact on the environment or new major abatement will normally trigger a Licence Review. The review process is similar to an application for a new licence and will normally take a minimum of 9 months to complete.
Please note that the EPA tends to deal with this issue on a case-by-case basis. If you have any concerns regarding planned changes at your facility please feel free to contact Environet Solutions.
Reporting Incidents to the EPA (7/6/2011)
When someone refers to an ‘incident’ in relation to environmental compliance we immediately think of a spill or other relatively serious occurrence at a facility. However the EPA definition of a reportable incident is very broad and can be summarised as follows;
- An emergency
- Any emission which does not comply with the requirements of the licence
- An exceedance of the daily duty capacity of the waste handling equipment
- Any trigger level specified in the licence which is attained or exceeded
- Any indication that environmental pollution has, or may have, taken place
Incidents are ranked as follows;
1. Minor – no contamination, localised effects
2. Limited – simple contamination, localised effects of short duration
3. Serious – simple contamination, widespread effects of extended duration
4. Very Serious – heavy contamination, localised effects of extended duration
5. Catastrophic – very heavy contamination, widespread effects of extended duration
Where an incident takes place during office hours the licensee must;
- Speak with the facility inspector and if he/she is not available ask for another inspector. Leaving a phone message or email is not acceptable.
- Complete Incident Notification Form and fax to EPA Regional Inspectorate.
Where an incident takes place outside of office hours the licensee must;
- For all incidents ring EPA at HQ or Regional Inspectorate and leave a message.
- For incidents ranked 2-5 record as an urgent environmental incident.
- In all cases complete and fax incident notification form.
In summary any exceedance of an ELV (even if it isn’t environmentally significant) is a reportable incident and licensees need to follow the steps outlined above.
Please remember that for exceedances of emissions to sewer or surface waters, your IPPC/Waste licence may require you to report to the Water Services Authority or Fisheries as well.
Industrial Emissions Directive – Some Implications (17/6/2011)
Environet has recently completed a review of the Industrial Emissions Directive (24 November 2010) and its implications for impacted facilities. Below are the main outcomes of that review. We have excluded implications for large combustion and waste incineration plants which will be dealt with in a future news item.
- ‘BAT conclusions’ should be the reference for setting permit conditions.
- EU BAT reference documents should be updated at least every 8 years.
- BAT emission levels can be exceeded where there is ‘disproportionately high costs compared to the environmental benefit.’ Such derogations need to be documented by the EPA in the licence issued.
- ELVs (Emission Limit Values) specifically set out in the Directive cannot be exceeded.
- A ‘baseline report’ on soil & groundwater conditions should be prepared for each facility. The Commission will establish guidance on the content of the report.
- Where process effluent is discharged to a municipal wastewater treatment plant, the effect of that treatment can be taken into account when setting ELVs.
- The EPA can grant a temporary derogation to BAT ELVs for a period not exceeding 9 months when a facility is testing emerging techniques.
- Groundwater monitoring must be carried out at least every 5 years.
- Licence conditions must be updated within 4 years of publication of new BAT conclusions.
- The EPA is now required to issue a report to the licensee within 2 months of an inspection/audit taking place.
- In general the majority of the IED must be transposed into Irish law by 7 January 2013.
- With some exceptions, existing installations shall have until 7 January 2014 to comply with the requirements of the Directive.
One of the biggest changes associated with the implementation of the IED will be the requirement to comply with ELVs as specified in BAT conclusions. The only derogation that appears to be allowed is on the basis of cost and any such derogation must be explained and included in an annex to the licence by the EPA. Under the IPPC Directive it was possible to argue that BAT was being applied if there was no significant impact on the environment, but this is no longer the case.
For more information please contact Gerard Kelly at 058-51155.
Save Money! – Change your monitoring frequency (20/6/2011)
One of the easiest ways to reduce your environmental cost is to reduce the amount of monitoring carried out at your facility. One of the conditions included in most IPPC, Waste and Trade Effluent permits allows the regulator to vary the frequency of monitoring once requested to do so by the licensee or permit holder.
As an example, take BOD monitoring of process effluent. This is a relatively expensive test and the licence will usually require COD to be monitored as well. If COD is required once per day and BOD required, say, once per week then you have probably established a good relationship between the two. If the relationship is pretty constant and has been proven over a minimum of one year then the regulator will probably allow a reduction in the frequency of BOD monitoring to monthly or perhaps even quarterly, as essentially both COD and BOD are measuring oxygen demand.
For emissions to atmosphere the savings can be even greater. If your licence requires monthly monitoring of a particular parameter and you can demonstrate that monitoring results are compliant and pretty constant then you can apply to the regulator for a reduction in monitoring frequency to at least quarterly and perhaps even annually.
In general monitoring frequencies in licences and permits in Ireland err on the side of being onerous when compared to other EU countries. There is a condition in your licence that allows you to change that frequency and save some environmental budget, so why not use it!
IPPC Licence Management Training Course – Enroll Now! (24 June 2011)
Our next IPPC Licence Management Training Course takes place in the Radisson Hotel, Little Island, Co. Cork on 12th October 2011 (9:30 – 16:30). Course places are strictly limited to 10 to allow for interaction and discussion. Topics covered include;
- Managing your relationship with the EPA
- Incident Notification
- Relevant Legislation Review
- Licence Reviews & Technical Amendments
- BAT and its application in Ireland
- Environmental Liability Directive
- Notifying the EPA regarding changes to your activity
- Reporting under IPPC
- Storage & Transportation of Materials
- Residuals Management Planning
- Environmental Liabilities Risk Assessment
- Impact of the Industrial Emissions Directive
- Waste classification and management
Who should attend?
- Environmental/EHS Managers
- Production Managers
- Engineering Managers
- Environmental Officers
- Environmental Operatives
Cost:€185 per person + VAT. Includes lunch, training material and refreshments during the day. A 10% discount applies where more than one person is booked per organisation.
The course will be given by Gerard Kelly (BE, MEngSc) of Environet Solutions. Gerard has over 20 years experience as both regulator, during his time with the EPA, and as an environmental consultant with some of the world’s leading environmental consultancies.
To book please email training@environet.ie with the following information;
Name:
Position:
Organisation:
Training Course:
Date of training:
PONumber (if applicable):
Payment of our invoice will confirm that your place has been held.