Reporting to the EPRTR in the UK

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Reporting to the EPRTR in the UK

• Alex Hole
• Assessment Reporting Advisor

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Overview

• EPRTR reporting in the UK
• Reporting from PPC activities
• Reporting from non-PPC activities
• Discussion

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• 
  The United Kingdom
• 
  (UK)

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EPRTR reporting in the UK

• England Wales
• PPC (part A) - Environment Agency (EA)
• PPC (part B) - Local Authorities
• Non-PPC activities Environment Agency (EA)
• Scotland/Northern Ireland
• Scottish Environmental Protection Agency (SEPA)
• Northern Ireland Environment Heritage Service
  (NIEHS)
• Local Authorities
• UK
• Offshore Oil Gas BERR
• Diffuse releases (air only) NAEI (AEA on behalf
  of Defra

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EPRTR reporting in the UK 2

• The EA and SEPA both make their PRTR data
  available electronically through their websites
• NAEI data available on the web

• Compilation of the UK return
• Defra are responsible for ensuring that the UK
  complies with the EPRTR regulation
• The EA will compile the data for the UK for
  submission to the EU
• A new UKPRTR website will be launched later this
  year

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EPRTR reporting to EA - PPC

• PPC (Part A) sites that we regulate
• Required to report using a Regulation 28
  information notice under the PPC regulations
  see pack
• Required to report to our Pollution Inventory
  which is more extensive than the EPRTR
• more substances
• lower thresholds
• required to report brt releases
• more detailed reporting of waste transfers

• Required to report by 28th Feb of the year
  following that which releases relate to

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EPRTR reporting to EA
non PPC activities

• Required to report using a Regulation 28
  information notice under the PPC regulations
• Give us power to enforce the requirements even
  though operators are required by regulation to
  provide information
• Report against EPRTR list only
• Report by end of April of following year (will
  move to Feb)

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EPRTR reporting to EA How do they do it?

• Complete a paper form see handouts
• Electronic copies available on website to
  download
• Form sent to all non PPC operators along with
  notice 1st year only
• Report using electronic system (not available for
  non-PPC in 1st year) see tomorrow

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New PPC activities Intensive Agriculture

• Key issues and problems
• How to calculate emissions
• Security issues over farm locations
• Ensuring notice reached appropriate person for
  completion

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New PPC activitiesIntensive Agriculture -
emissions

• Calculation of emissions
• Several sets of emissions factors available
• Farmers unions involved in choosing emissions
  factors
• Disagreement over which factors to use

• Used a combination of Corinair emissions factors
  plus those used on H1
• Our IA colleagues involved in discussions
• Likely to change next year to ensure all factors
  used for IA are consistent across the EA

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New PPC activitiesIntensive Agriculture
Concerns 1

• Concern by Industry that information submitted to
  PRTR would be used to alter permit conditions
  assured them that this is not the case
• Concerns over complexity of form separate form
  has not been provided as we would be deciding for
  them which substances to report

• Guidance note issued to say how to calculate
  emissions and how to complete form again some
  complaints that it is too complicated see pack
  for copy

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New PPC activitiesIntensive Agriculture
Concerns 2

• Concern by Industry that publication of names and
  addresses on web could lead to security breaches
• Same procedure used to asses claims for
  confidentiality as per PPC application process

• Government Minister for Agriculture confirmed
  that names and addresses would have to be
  published to allow the UK to comply with EPRTR
  requirements
• Details used on PPC applications used to contact
  all farms - although because some sites are run
  on behalf of a big company issues as to who
  completed form

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QA of PPC activities data

• Several levels of QA are carried out following
  the submissions of data to us
• Electronic reporting system raises check flags
  where data is significantly different from
  previous years reporting or to the threshold
• Site inspector checks return to see if return is
  consistent with their knowledge of site and
  permit conditions see checklist in pack
• Regional QA use database tool to look for
  outliers see tomorrow
• National QA check trends to and totals to find
  any erroneous data

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QA of PPC activities data
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Non PPC activitiesMines Quarries 1

• Key issues/problems
• Identifying sites
• Interpreting 25Ha requirement
• How to calculate emissions
• How to QA data

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Non PPC activitiesMines Quarries 2

• Identifying Sites
• Defra consultation sent to mining and quarrying
  trade association to inform them of new
  requirement
• Used list from BGS all active mines and
  quarries in England and Wales
• List found not to be very accurate
• Decision taken that we will not chase up those
  that do not respond we have gone to our best
  efforts to identify them

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Mines Quarries 3

• Problems
• Landfills often operate in quarries and this
  activity is regulated by us under PPC
• Crushing activity generally regulated by Local
  Authority
• Requires double checking with some operators to
  make sure they do not report twice
• Most mines and quarries have been lt25Ha, but need
  to refer the operator to the definition in the
  regulation

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Mines Quarries 4

• Most mines and quarries have been lt25Ha, but need
  to refer the operator to the definition in the
  regulation
• Onus on them to ensure that they report as
  appropriate

Opencast mining and quarrying where the surface
area effectively under extractive operation
equals 25 hectares. Surface of the area
effectively under extractive operation means the
surface of the area of the site reduced by the
surface of the rehabilitated area and reduced by
the area of future excavation.
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Mines Quarries 5

• Guidance
• Very generic guidance provided for operators
  see pack
• No funding or time for us to develop guidance
  with methods for calculation
• Anticipating very few sites to report any values
  that are above threshold
• Used indicative sector specific list for EPRTR
  guidance document
• No local site knowledge so data will be QAd
  nationally likely to compare data between
  sites, and with other sectors. No methodology
  prepared yet

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Non PPC activitiesIOWWTWs - 1

• Key issues/problems
• Identifying sites
• What is a treatments works?
• Which pollutants?
• QA of data

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Non PPC activitiesIOWWTWs - 2

• Identifying sites
• Used lists of discharge consents
• Issued S28 notices as per other sectors
• Likely to be only 10 or so sites reporting
• Most have/are part of PPC permits

• What is a treatments works?
• Site must have some chemical/biological treatment
• Water extracted for cooling at Power Stations
  does not counts as treatment (filtering for
  debris only)

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Non PPC activitiesIOWWTWs - 3

• Which pollutants?
• Due to limited time/budget and number of sites
  no guidance has been issued
• All sites have discharge consents which have
  limits set on how much of a substance can be
  released to the environment. Loads can be worked
  out as a proportion of this limit
• QA of data
• Likely that data will be QAd nationally likely
  to compare data between sites, and with other
  sectors. No methodology prepared yet

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Website

• Contains copies of the Forms (word and pdf)
• Link to electronic reporting system (PIEDC)
• Copies of generic guidance note
• Copies of reporting codes document
• Copies of sector specific guidance notes
• Details of how to contact us with enquiries
• http//www.environment-agency.gov.uk/pi

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Discussion / Questions
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Reporting of Waste
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Overview

• EPRTR requirements
• How we do it in England and Wales
• Problems/difficulties

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Reporting of Off site waste transfers

• EPRTR requirements
• Process related waste going off site for Disposal
  or Recovery
• Require separate reporting of hazardous and
  non-hazardous waste
• Thresholds are
• Hazardous waste 2 tonnes
• Non- hazardous waste 2000 tonnes
• If total sent off site is above threshold then
  all waste need to be reported

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Reporting of Off site waste transfersHow we do
it in England and Wales

• Require sites to report waste according to Waste
  type (EWC code) and WFD D or R code
• Reporting threshold for PPC sites are
• Hazardous waste 0 tonnes
• Non-hazardous waste 5 tonnes

• Reporting threshold for non PPC sites are as per
  the EPRTR regulation
• Lists of EWC and DR codes in PI reporting codes
  document see pack

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Off site waste continued

• Key issues/problems
• Sludge Agricultural sludge that is spread on
  land for the benefit of agriculture needs to be
  reported in the waste section
• Other Farm waste e.g. dead animals. Some
  confusion as to whether to report D/R as ultimate
  fate is often fertiliser or land spreading
• Non-process related waste does not need to be
  reported (e.g. municipal office waste, demolition
  waste)

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Overseas waste transfers

• Operators need to report who they are sending the
  waste to, and what its final destination is
• In the UK it is illegal to send waste overseas
  for disposal so we are only expecting waste
  sent for recovery to be reported
• Where the waste is taken overseas by a waste
  carrier, the producer of the waste needs to
  report its final destination
• If the waste is sent to a waste management
  facility, and is sorted and then snet overseas.
  The waste management facility must report the
  overseas waste transfer

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Guidance tools 1

• All available to download from website
• General guidance
• Reporting codes document
• Sector specific guidance for existing PPC sectors

• Food Drink
• Cement Lime
• Chemicals
• Incineration
• Metals (ferrous non-ferrous)
• Paper Pulp
• Intensive agriculture

• Waste oil estimator
• Landfill leachate estimator
• Landfill Gas emissions estimator (Gassim)
• Municipal waste water treatment works estimator
  tool
• Combustion activities
• Petroleum activities

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Guidance tools 2

• Guidance and tools developed in collaboration
  with industry and other regulators
• Sector specific guidance for new EPRTR activities
  sent with notice and on website
• Mining and quarrying
• www.environment-agency.gov.uk/pi

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Lessons learnt

• Try to liaise with trade associations, industry
  representatives and policy experts in your
  organisation when writing guidance and
  communicating with industry
• Provide guidance and tools so it is clear what is
  expected
• Use electronic data capture to increase accuracy
  at data entry stage (and reduce administrative
  burden)

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Questions/discussion
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Alex Hole Assessment Reporting
Advisor alex.hole_at_environment-agency.gov.uk 0044
117 914 2622