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Inspection of LCPs: System for Inspection.

ECENA Training Workshop

Bristol, March 2008

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Introduction

This presentation, Session 5, addresses Inspection of LCPs: System for inspection: General requirements and

development of a programme of inspection. Implementation of a programme of Inspection Follow up activities.

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IPPC Process

LCPs are subject to the IPPC directive: Pre-IPPC approach was one of

command and control – industry was seen as the problem!

IPPC approach is one of co-operation between regulators and industry. Incorporates a large degree of self compliance as industry knows best on how its facilities should be operated efficiently – industry seen as the solution.

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Relationship with Industry

In countries where the integrated approach has been operating for a number of years, experience has shown that nearly all companies are pro-active: They want a good relationship with their regulators

and neighbours. They are concerned about their image. They demonstrate self compliance.

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Relationship with Industry

Experience has shown that there are a very limited number of companies, who have poor compliance, even to the point of misleading the authorities.

These companies need a high level of compliance supervision that would not be appropriate to the previous circumstances.

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Inspectors’ support groups

ECENA – of course!! Detailed set of guidance on website: http://www.rec.org/REC/Programs/rerep/BERCEN/TrainingManual.html

IMPEL Network of environmental inspectorates: http://ec.europa.eu/environment/impel/index.htm

TAIEX – Technical Assistance Information Exchange Unit. Set up for 10 new Member States, now being phased out: http://taiex.ec.europa.eu/

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Guidelines for Inspection of IPPC Activities

Guideline prepared by PM Group in 2005 for Romanian IPPC project. Given as handout.

Experience has shown in other Member States that one inspector can handle about 25 installations annually.

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Guidance on Inspection

Recommendation 2001/331/EC of European Parliament Planning

Annual Plans; Inspection plans Types A & B Installations – based on Risk (LCPA) Routine & Non routine

Authorisation Inspection Diagnostic – initiated by complaint Accident case Permit review

Reporting Inspections Annual reports

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Inspection types

Routine inspections Impacts, informing, permit evaluation, operator assessment

Authorisation Inspection With permitting & monitoring staff, Reviews management style

Diagnostic inspections Proactive inspection – aimed at compliance support

Accident & Complaints Failure analysis, may be followed by enforcement

Permit review Inspects scope and impact of changes

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Inspections Plans

Annual PlansRisk AssessmentFrequency of routine inspectionsAllow for the unforeseen!

Inspection plans Inspection Stages Resources for the inspection

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Sample Basis for Inspection Plan

Inspection Activity Events per year

Authorisation Inspections One per application

Visits to installations - Pro-active management 1 site visits minimum

Compliant management 2

Reluctant management/ high risk 10

Data review at Agency - Pro-active management 4

Compliant management 4

Reluctant management / high risk 12 - 50

Diagnostic investigations Estimate 1 per 5 sites

Accident investigations Estimate 1 per 10 sites

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Minimum requirements

All inspections: Compliance with EU Legislation Co–ordination between authorities Reporting Access to significant areas of site

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Reporting

Inspection reports Publicly available Consultation with operator

Annual reports Regional reports National reports

To EU Formats provided in Recommendation 2001/331/EC

Resources, activity, compliance, actions & assessment

All reports accessible to public.

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Follow up!

Minutes of meeting need to be promptly issued to company.

Inspection report needs to be completed and publicly available within 2 months.

Inspection data needs to be safely filed and stored. Conclusion on whether further action should follow, e.g.

enforcement proceedings, issuing of new or revised IPPC permit, follow-up inspections, etc.

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The Feedback Loop!

Inspections provide the feedback necessary to ensure a good permit: Significant emissions or waste not controlled by

permit conditions permit may need to be updated! Irrelevant or ineffective monitoring permit

conditions may need to be updated!

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Permit Life Cycle

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Proposed New Directive on Industrial Emissions

The EU Commissions IPPC Action Plan for 2008 – 2010 includes five key actions: Action 3: Enhanced monitoring and compliance

checks of the application of the legislation on industrial emissions – The commission will continue to monitor the number of IPPC permits issued and updated, and where required investigate the system of monitoring and inspection at IPPC installations.

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Proposed New Directive on Industrial Emissions

Article 9 Non-compliance: 1. Member States shall take the necessary measures

to ensure that the conditions of the permit are complied with.

Article 25 Inspections: 1. Member States shall set up a system of inspections

of installations. That system shall include on-site inspections.

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Proposed New Directive on Industrial Emissions

Article 25 Inspections: 2. Member States shall ensure that all installations are covered

by an inspection plan. 3. Details of each inspection plan. 4. Competent authority shall draw up an inspection

programme – at least one site visit every 12 months. 5. Routine inspections. 6. Non-routine inspections. 7. Report preparation.

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What are the Main Inspection Issues with LCPs:

All fuel types: Compliance with air emission parameters and noise, improvement programmes to meet BAT, general housekeeping, energy efficiency, complaints received.

Oil: Integrity of oil storage and transfer systems, surface water discharges,

Coal: Dust emissions from coal storage and landfilling of ash.

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Questions?