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/Trainin
gManual.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 (LCPA)
 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 Plans
 Risk Assessment
 Frequency of routine inspections
 Allow 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?

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