The PPC Permit. Simon Holbrook SPG Manager - Warrington

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1 The PPC Permit Simon Holbrook SPG Manager - Warrington

2 Introduction The role of the Area Inspector and the SPG BAT as an on-going process What to expect in your Permit Changes on the Horizon

3 The Area Inspector and SPG For non-landfill sites pre-application is the responsibility of the Area Inspector Determining the application and issuing the Permit is the responsibility of the SPG with input from the Area Inspector as appropriate

4 Pre-Application Discussions Key Discussion Points Guidance on interpretation Defining the installation boundary Providing an overview of the application template and guidance available Auditing and agreeing the EP OPRA scores Confirming use of Multi-Product Protocol or Low Impact Installation

5 Key Issues.. Best Available Techniques (BAT) Environmental Impact

6 BAT and Permit Determination Agency assesses BAT arguments as part of determination process. Agency will set permit conditions (or refuse permit) based on this assessment. For existing installations the permit may include an improvement programme. Regardless of BAT considerations the installation must still not give rise to significant pollution.

7 What is BAT? Defined in Regulation 3 as: the most effective and advanced stage in the development of activities and their methods of operation which indicates the practical suitability of particular techniques for providing in principle the basis for emission limit values designed to prevent and, where that is not practicable to reduce emissions and the impact on the environment as a whole

8 Application of BAT Regulation 11(2) requires that permit conditions ensure that: all the appropriate preventative measures are taken against pollution, in particular through the application of the best available techniques; and no significant pollution is caused.

9 Continuous Improvement BAT will change as new technology or techniques become available or economically viable. Duty on Regulators to follow developments in BAT. However, the onus is on the Operator to keep up to date. Regulation 15 requires the Regulator to periodically review permit conditions and specifically when there is a substantial change in BAT.

10 What to expect in your Permit An Improvement Programme Specific Permit Conditions on e.g. noise, odour, management, raw materials, waste, energy, accidents, and emission limits for pollutants to air and water Monitoring and Reporting requirements Regulation 12(10) Residual BAT

11 Improvement Programme Recognition in Schedule 2 of the Regulations that for existing sites the Regulator should consider the length of time needed to introduce BAT bearing in mind the likely costs and benefits and the principles of precaution and prevention. e.g. agreeing an interim ELV higher than benchmark allowing time for BAT to be implemented by the improvement programme.

12 Specific Requirements These are based on a combination of Regulation 12 which details specific requirements to be included in any Permit and Schedule 2 which lists matters that need to be considered in determining BAT e.g. consumption of raw materials, energy, reducing waste, preventing accidents etc.

13 In-Process Controls Incorporation within the Permit of the operational techniques described in the application to prevent and reduce wastes and emissions of substances including proposed abatement techniques (Questions B2.1 and B2.2) If not adequately described in the application may require submission of additional information

14 Emissions to Air, Water and Sewer Regulation 12(2) requires that a Permit includes emission limit values for pollutants, in particular those listed in Schedule 5, likely to be emitted in significant quantities having regard to their nature Considerations - impact assessment results, benchmark levels based on BAT, requirement for abatement, DSD (water/sewer) Impact assessment may require lower than BAT benchmark levels

15 Management Conditions covering training, maintenance, incidents and complaints are included in the Permit in part to satisfy the requirements of Regulation 10(3) Basic management systems are necessary to ensure that the conditions within the Permit can be complied with

16 Efficient use of Raw Materials Maintain a raw materials list Carry out periodic waste minimisation and water use efficiency audits Schedule 2 requires when determining BAT to consider the consumption and nature of raw materials (including water)

17 Waste Recovery or Disposal Regulation 10(3)..where waste is produced, it is recovered or, where that is technically or economically impossible, it is disposed of while avoiding or reducing any impact on the environment Above included as a condition plus a requirement to maintain a table of waste recovery or disposal routes

18 Energy Efficiency Provide the Agency with an annual report on energy consumed Maintain and update annually an energy management system Regulation 11(3) requires that energy is used efficiently

19 Accident Prevention and Control Maintain an accident management plan and implement when necessary Update at least every two years or after an accident Regulation 11(3) requires that the necessary measures are taken to prevent accidents and limit their consequences

20 Noise and Vibration Condition requiring the use of BAT to prevent or where that is not practicable to reduce the emissions of noise and vibration In certain circumstances the Agency may in addition set noise emission levels Noise and Vibration considered as emissions

21 Monitoring Requirements Condition to maintain and implement an emissions monitoring programme with monitoring points and parameters stated in the Permit Monitoring equipment, techniques, personnel and organisations employed for emissions monitoring shall have MCERTS certification or accreditation

22 Monitoring Requirements Regulation 12(9) requires that a Permit includes suitable emission monitoring requirements, specifying measurement methodology, frequency and reporting requirements

23 Reporting Requirements Emissions Monitoring Results Energy Consumption Performance Indicators Annual review of Fugitive Emissions having regard to BAT Formal EMS then summary report of performance against targets

24 Notifications Without delay notify the Agency of: The detection of any substance which exceeds any limit or criterion in the Permit The detection of any fugitive emission or the detection of any malfunction or breakdown or failure of techniques or any accident which which has caused, is causing or may cause significant pollution

25 Land Protection Requirements Within 2 months of Permit issue submit a detailed Site Protection and Monitoring Programme (SPMP) to the Agency The SPMP shall be implemented and maintained with reviews at least every 2 years The requirement for a SPMP is in most but not all Permits

26 Land Protection Within 6 months of Permit issue collect site reference data specified in SPMP Not required in all Permits but usually where there is a history of land contamination with materials similar to those currently being used in the process and where there is a reasonable possibility of future pollution

27 Residual BAT Regulation 12(10)..implied in every Permit a condition that the Operator will use BAT for preventing or, where that is not practicable, reducing emissions.. i.e. a catch all However, this does not apply to any aspect regulated by a specific condition in the Permit (Regulation 12(11))

28 Changes on the Horizon Agency will complete implementation of PPC through to 2007 Risk based compliance assessment plans - with the level of compliance assessment linked to environmental risk using EPOPRA