Reporting to the EPRTR in the UKAlex HoleAssessment & Reporting Advisor

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

The United Kingdom

(UK)

EPRTR reporting in the UKEngland & 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

EPRTR reporting in the UK 2

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

The EA and SEPA both make their PRTR data available electronically through their websites

NAEI data available on the web

EPRTR reporting to EA - PPCPPC (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

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)

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

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

New PPC activitiesIntensive Agriculture - emissionsCalculation 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

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

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

QA of PPC activities dataSeveral levels of QA are carried out following the

submissions of data to us1. Electronic reporting system raises ‘check flags’

where data is significantly different from previous years reporting or to the threshold

2. Site inspector checks return to see if return is consistent with their knowledge of site and permit conditions – see checklist in pack

3. Regional QA – use database tool to look for ‘outliers’ – see tomorrow

4. National QA – check trends to and totals to find any erroneous data

QA of PPC activities dataOperator notified to submit (or re-

submit) data

Operator submits (or re-submits) data using electronic data capture

Site Inspector:Is operator data

acceptable?NO

YES

Entry level validation checks.

Operator cannot submit data that does not pass

validation

Quality Manager: Is operator data

comparable?

Publish data on website

NO

YES

Inspector must agree there is

an issue before going back to

operator

Online validation

Inspectorverification

Quality validation

Public validation

Non PPC activitiesMines & Quarries 1Key issues/problems • Identifying sites• Interpreting 25Ha requirement• How to calculate emissions• How to QA data

Non PPC activitiesMines & Quarries 2Identifying 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

Mines & Quarries 3Problems• 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 <25Ha, but

need to refer the operator to the definition in the regulation

Mines & Quarries 4• Most mines and quarries have been

<25Ha, 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.

Mines & Quarries 5Guidance• 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

Non PPC activitiesIOWWTWs - 1Key issues/problems• Identifying sites• What is a treatments works?• Which pollutants?• QA of data

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)

Non PPC activitiesIOWWTWs - 3Which 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

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

Discussion / Questions

Reporting of Waste

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

Reporting of Off site waste transfersEPRTR 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

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 D&R codes in PI reporting codes document – see pack

Off site waste continuedKey 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)

Overseas waste transfers• Operators need to report who they are sending the

waste to, and what it’s 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 it’s 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

Guidance & tools 1

• 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

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

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

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)

Questions/discussion

Alex Hole

Assessment & Reporting Advisor

alex.hole@environment-agency.gov.uk

0044 117 914 2622