ISL Praxis : IPPC PPC Services and Support

Pollution Prevention and Control is a regime for controlling pollution from certain industrial activities. These activities are identified in the Pollution Prevention and Control (PPC) Regulations, which have been introduced in UK legislation as part of the implementation of the EU Integrated Pollution Prevention and Control (IPPC) Directive (EC/91/61).

The system of PPC is being introduced over 2000 to 2007, replacing the previous system of Integrated Pollution Control. This system is based on the concept of Best Available Techniques (BAT). Essentially, Operators must use BAT to control pollution from their industrial activities. The aim of BAT is to prevent, and where that is not practicable, to reduce to acceptable levels, pollution to air, land and water from industrial activities. BAT also aim to balance the cost to the operator against benefits to the environment.

In the PPC Regulations there are 3 linked systems of pollution control:

• IPPC covers A(1) installations - regulated across the UK by the Environment Agency, SEPA or E&HSNI
• Local Authority, LA-IPPC covers A(2) installations which are regulated by the Local Authorities
• Local Authority, LAPPC covers Part B installations which are regulated by the Local Authorities

All of these systems are regulated by a permitting process. An Operator must apply for a permit from the Regulator, and when issued this contains conditions aimed at reducing and preventing pollution to acceptable levels. A1 installations have the greatest potential to pollute the environment, then A2, with Part B installations the lowest. Part B processes are only regulated on emissions to air.

How We Can Help
We can help with you to comply with the PPC Regulations whether you are an A1, A2 or Part B installation. We provide a cradle to grave Permit support service, including:

• identifying whether you need a Permit;
• preparation of a permit application;
• management of permit conditions;
• variation of a permit due to operational changes; and
• surrender of a permit.

We can help you due to the knowledge we have gained in the interpretation of the Regulations since our technical staff have worked with the Environment Agency in the determination of over 100 PPC permits. We can help you to understand:

Activities Falling Under IPPC
Operators should consult Schedule 1 of the PPC Regulations to identify whether their activities require a Permit. As these Regulations are complex, we can help you to identify whether your activities require a Permit. We can also liaise with the Environment Agency on your behalf to clarify matters.

Best Available Techniques (BAT)
Operators must demonstrate BAT is being applied to control their activities during the Permit application process. This is assessed during the determination of the Permit by the Regulator. Failure to demonstrate BAT by the Operator will lead to Improvement Conditions in the Permit, which must be complied with. We can use our experience to justify BAT as part of the Permit application process or in the preparation of reports as part of the delivery of your Permit Improvement Conditions.

Significance of Environmental Impacts
H1 – we can quantify the impact of your operations on the environment on your behalf by using the H1 tool preferred by the Regulator

Our expertise in this complex area has been recognised by the Environment Agency. Our consultants have been retained by the Environment Agency to assist in the determination process of applications for permits to operate under the PPC Regulations.

Permit Application

IPPC PPC Permit Application
Operators of existing installations must submit an application within a given time window for a Permit to operate an installation under the PPC Regulations. Developers of new installation must apply for and be granted a permit prior to commencing operation. Making an application requires the Operator to explain and justify details of how the site operates. Because every site is different, each application must be tailored to contain the details specific to the site.

Supporting information in the application must consider the impacts of the site in the following areas, assessed against BAT:

• raw Materials use (including Water use);
• energy use (gas, electricity, steam, etc);
• emissions to air, water, land;
• noise and Odour emissions;
• management procedures and process techniques;
• accident prevention; and
• monitoring techniques.

The BAT assessments must demonstrate how emissions are prevented, and where this is not practicable reduced and must include the subsequent impacts on the environment from these releases. The application must demonstrate how BAT is applied or justify why BAT standards are not required to be met. BAT standards are specified in the form of BREFs, Sector Guidance Notes and Technical Guidance Notes.

A Site Report must also be prepared as part of the Permit application, which describes how the surrounding environment (land, water, habitats, human dwellings) is affected by the site operations. This must contain an assessment of the condition of the land, which is used to determine what work needs to be done to assess existing land contamination.

The application must also demonstrate compliance with a raft of cross-cutting relevant legislation (e.g. Solvent Emissions Directive, Dangerous Substances Directive, etc.) which is rigorously checked by the Regulator during the Permit determination process.

The Regulators provide guidance on their websites and also provide an application CD which is specific for each sector.

How We Can Help
ISL Praxis specialises in the preparation of PPC permit applications. You can either outsource the entire permit application to us or we can prepare specific sections for you. We can also help by negotiating on your behalf with the Regulator to agree the Installation boundary and permitted activities, which may have a large impact on your permit fees. In addition, we can help to negotiate a way forwards if you have not applied for a Permit within the given deadline.

We can help to:

• assess the impact of your operations on the environment;
• utilise the H1 software tool used to assess emission -preferred by the Environment Agency;
• carry out a habitats assessment;
• produce BAT assessments of your operations and justify any deviations;
• produce a Site assessment report;
• develop your EP OPRA profile (which determines the risk of your site and hence your Permit fees);
• produce a Site Monitoring and Protection Programme;
• produce an Environmental Management System tailored to your site operations; and
• accident risk assessments (HAZOP).

Through the work our technical staff have undertaken with the Regulator, we know exactly what is required to make an application, enabling our specialists to produce practical, cost-effective, compliant solutions for you.

Our expertise in this complex area has been recognised by the Environment Agency. Our consultants have been retained by the Environment Agency to assist in the determination process of applications for permits to operate under the PPC Regulations.

Permit Conditions

IPPC PPC Permit Conditions
Receipt of a permit represents the beginning of regulatory compliance for a business and not the end. The Permit will contain a number of conditions which must be met for compliance. These conditions require a number of ongoing reports to be issued to the Regulator against deadlines set in the Permit.

For A(1) installations, there are standard Permit conditions which require the Operator to maintain the effective operation of the activities undertaken at the installation.

Examples include:

• review of Raw Materials Table;
• waste Minimisation Audit (every 4 years);
• water Use Efficiency Audit (every 4 years);
• review of Waste Recovery/Disposal Table;
• review of Energy Management System;
• reporting of monitoring data (quarterly and annual);
• annual Report of performance;
• annual review of fugitive emissions;
• annual review of Environmental Management System (report of progress against targets); and
• preparation of Site Protection and Monitoring Programme (SPMP), with 2-yearly review.

For A(1) installations, there are frequently Improvement Conditions (ICs) in the Permit. These require the operator to report on improvements that need to be made to in the view of the Regulator justify BAT. The number of ICs in a Permit may vary and are dependent on the assessment made by the Environment Agency. Typical examples include:

• site Closure Plan;
• water efficiency audit and proposed improvements;
• waste minimisation audit and proposed improvements;
• energy efficiency audit and proposed improvements;
• noise Assessment / Noise Management Plan;
• odour Assessment / Odour Management Plan;
• generation of Environmental Management System / Address deficiencies within existing Environmental Management System;
• action plan to meet MCERTS requirements for emissions monitoring;
• generation of an Accident Management Plan / Address deficiencies within the existing Accident Management Plan;
• assessment of alternative techniques and subsequent proposals to reduce emissions;
• assessment of alternative techniques to determine the best practical environmental option;
• review against relevant sector guidance note of material containment arrangements and subsequent improvement proposals;
• emissions monitoring trials and revision of impact assessment based on monitored data;
• assessment of alternative techniques and subsequent proposals for prevent releases of fire water; and
• assessment of alternative raw materials and justification for selected materials.

How We Can Help
We can provide a complete Permit management service, by preparing all of your reports on your behalf. It should be noted that the Operator has full liability for compliance with the Permit, but we can prepare all reports for you to sign off prior to issue to the Regulator. This is an area in which we have great experience. We currently provide such a service to one of the largest Food and Drink Site in the UK.

Alternatively, you may want us to produce specific reports on your behalf to meet the requirements of improvement conditions. Due to our experience in the area of PPC Permitting, we understand the levels of control that need to be demonstrated to the Regulator. Our thorough knowledge of BAT enables us to justify the occasions where BAT is not possible.

Examples of the reports our consultants have produced include:

• quarterly Reporting of monitoring data;
• annual emissions reporting;
• performance Reporting;
• emissions Monitoring;
• site closure plan;
• site protection and monitoring program, both with and without reference data;
• noise management plan;
• noise assessment and proposed action plan;
• odour management plan;
• odour assessment and proposed action plan;
• energy efficiency audit, with proposed improvements;
• water efficiency audit, with proposed improvements;
• waste minimisation audit, with proposed improvements;
• waste recovery / disposal review, with proposed improvements;
• environmental management system;
• accident management plan;
• option appraisal of alternative techniques and recommendations to minimise emissions;
• option appraisal of alternative techniques to determine the best practical environmental option and recommendations;
• review of bunding and hardstanding arrangements, with proposed improvements;
• review of proposed techniques against MCERTS and recommendations;
• collection of emissions monitoring data and generation of revised impact assessments using Environment Agency H1 assessment methodology or air dispersion modelling, as appropriate;
• review of alternative materials and justification for proposed selection; and
• review of options to prevent release of fire water and recommendations.

Our expertise in this complex area has been recognised by the Environment Agency. Our consultants have been retained by the Environment Agency to assist in the determination process of applications for permits to operate under the PPC Regulations.

IPPC PPC Guidance

Environmental Management System
An Environmental Management System (EMS) is a set of processes and practices that enable an organisation to reduce its environmental impacts and increase its operating efficiency. Due to increasing public awareness, an EMS is seen as a valuable way for companies to demonstrate their commitment to environmental sustainability. Although many companies operate an informal EMS, the level of regulatory compliance and environmental improvement achieved is increased by operating an accredited EMS (such as ISO 14001 or European Eco-Management and Audit Scheme (EMAS)).

ISL Praxis can offer you a wide range of EMS related services including: design of a new EMS and gap analysis of an existing EMS leading to accredited status, training of staff, development of improvement programmes and environmental reporting. We have experienced consultants who can offer guidance as they are fully familiar with EMS requirements.

Benefits of an EMS
As part of a PPC Permit application, the type and accreditation level of an EMS is reviewed by the Regulator. During this review, the operator and pollution risk of an installation with an EMS is reduced; therefore the operator permit costs and ongoing fees are similarly reduced.

An EMS can further benefit an organisation by:

• improving control of risk and impacts – e.g. reducing the environmental impact of its operations;
• ensuring greater awareness of legislative requirements;
• identifying cost savings through improved operational efficiency in the use of materials and energy as well as reductions in waste production;
• providing a better understanding and greater control of processes thereby reducing emissions and the risk of pollution incidents; and
• improving its public image as environmental performance is increasingly important to the wider community.

Key Components of an EMS

• an environmental policy including a statement from senior management outlining the company’s commitment to the environment;
• an Environmental Improvement Programme setting objectives and targets;
• clearly defined roles for all employees, delivering staff ownership and enthusiasm;
• ongoing assessment of the environmental impacts of an installation - i.e. raw material use, effluent production etc;
• procedures to control activities that might have a significant environmental impact;
• defined systems for record keeping and document control; and
• periodic auditing of the system (internal or external).

How We Can Help
We can work with you to develop a business case for implementation of an EMS at your specific site(s). We will take time to understand your needs to produce an EMS that fits in with your existing systems and processes. We can either work with you as an advisor to help you to develop an EMS or we can implement your EMS on your behalf with your involvement.

ISL Praxis Process for Development of an EMS
We will follow these steps to deliver an EMS that is relevant to your business need in terms of size and scope and for which your staff feel ownership:

1. Review current environmental performance, identifying the environmental impact of activities of the organisation. This review will involve site reconnaissance, interviews with key staff and identification of relevant documentation. This review will provide an understanding of your current position and define your needs;
2. With the input of senior management write the environment policy. This will require the setting of objectives and targets to address significant impacts. These targets will be used to develop an environmental management programme;
3. Produce a definition of environmental responsibilities across the company
4. Deliver communication and training to ensure all employees are aware of EMS issues, but with more focused training for staff with environmental responsibilities;
5. Prepare control procedures and EMS documentation;.
6. Audit the EMS and ensure that corrective actions are carried out; and
7. Lead a management review of the EMS and establish the continuous improvement cycle.

EMS Continuous Improvement Cycle diagram

Best Available Techniques
An essential aspect of the PPC Permitting process involves the operator in determining how Best Available Techniques (BAT) are or will be applied to prevent or minimize pollution from the installation. Our industrial regulation specialists have a thorough knowledge of BAT across the range of PPC sectors and can help you put together your Permit application. We can also help you to comply with subsequent Permit conditions by justifying BAT where appropriate.

The spirit of BAT is that the selection of techniques to protect the environment should achieve an appropriate balance between the environmental benefits they bring and the costs to implement them. It is important that the Operator presents relevant costs and environmental information to justify the BAT selected.

Environmental regulators across the UK have produced guidance on BAT, referred to as Horizontal Guidance Note H1, ‘IPPC Horizontal Guidance Note for Environmental Assessment and Appraisal of BAT’. This guidance provides a structured approach which addresses the specific requirements of the PPC Regulations. The methodology employed consists of two basic components – the assessment of environmental impacts and the balancing of environmental impacts against costs.

Demonstration of BAT
The H1 Guidance methodology is pictorially described opposite. Each of the separate modules is a step towards justifying BAT in a clear and consistent manner.
For a range of options, the effects of emissions on the environment are quantified, taking into account:

• emissions to air and water;
• deposition to land of airborne emissions;
• the risk of impacts from accidents;
• effects of noise and odour on local receptors;
• visual impacts associated with operating the process;
• the potential to cause global warming by indirect effects;
• potential to cause photochemical ozone by indirect effects; and
• indirect effects of waste hazard and disposal.

An assessment of the impact of these emissions is made with respect to the effects on human health, quality of the environment, offence to human senses and damage to material property or amenity value. After this is completed, the option which represents the lowest impact on the environment may be identified. The final step is a cost evaluation if more than one option is available. A cost evaluation is unnecessary if there is only one option.

Permit Application
The operator needs to provide all the information necessary to demonstrate that the assessment has been fulfilled. This would typically consist of emissions data and information on the local environment together with results of the assessment of environmental impacts and costs. It is also important to include a description of the interpretation, assumptions and qualitative judgements made in reaching decisions regarding selection of BAT or environmental assessment. The regulator needs this information in order to understand the justification for the decisions made.

Environmental emissions may be quantified using a supplementary H1 software tool, which determines whether these emissions are significant. The input data, comments and output pages (e.g. histograms) of the software tool can be used to provide much of the information. These must be submitted to the regulator, together with any supplementary information used in the assessment process (e.g. dispersion modelling reports, etc).

Our industrial regulation specialists can use their extensive knowledge of the Permitting process to put together your Permit application for consideration by the regulator.

Illustration of the BAT Process

PPC Horizontal Guidance: Noise
Noise

One of the emissions regulated by the PPC Regulations is Noise and Vibration. The PPC Permitting process requires the use of Best Available Technology (BAT) to minimise these emissions. It is important to note that the granting of a Permit can represent just the first step of an operator’s management of noise emissions. Permit conditions often require the formulation of noise management plans as well as comprehensive noise monitoring programmes as part of the active management of this issue.

Environmental Regulators across the UK have produced guidance on noise, referred to as Horizontal Guidance Note H3, ‘Horizontal Guidance for Noise’. This helps applicants in their assessment of what constitutes BAT for minimising noise emissions from their installation. It is extremely important to take into account individual Sector Guidance Notes and European BAT Reference (BREF) Notes and recognise that noise issues tend to be very site specific. Justifications can be made for deviations from national standards on grounds of the technical characteristics of the installation, its geographical location and local conditions.

Your obligations relating to Noise under PPC
In order to be granted a PPC Permit an operator must demonstrate that noise emissions from the installation are minimised using BAT. In determining BAT across the installation, noise must be considered and balanced within the wider context of other releases to different media (air, land and water). This must also take into account issues such as usage of energy and raw materials. Noise cannot therefore be considered in isolation from other impacts on the environment. The aim of the BAT assessment is to achieve the underpinning of good practice, the prevention of creeping ambient noise levels, and the prevention of reasonable cause for annoyance to sensitive receptors.

The granting of a Permit to an operator represents only the beginning of their regulatory obligations relating to noise. Permit conditions often require the generation and implementation of noise management plans, comprehensive noise monitoring programmes and the identification of noise abatement options.

How We Can Help
ISL Praxis can offer you a wide range of noise related services including:

• Gap analysis of your installation relative to BAT;
• Formulation of noise management plans;
• Full monitoring of noise emissions; and
• Identification of how noise emissions can best be mitigated.

Our industrial regulation specialists are fully familiar with PPC Regulations and have a practical knowledge of regulatory interpretation and compliance issues.
PPC Horizontal Guidance: Odour

Odour
The IPPC Permitting process requires the use of Best Available Technology (BAT) to minimise odorous emissions. The field of odour measurement and control is very wide in scope and is continually developing. The point at which pollution in the form of offence to the sense of smell is occurring is taken to be the point at which there is “reasonable cause of annoyance”. The aim of BAT should be to ensure that there is no reasonable cause of annoyance.

Environmental Regulators across the UK have produced guidance on odour, referred to as Horizontal Guidance Note H4, ‘Horizontal Guidance for Odour’. This helps applicants to assess what constitutes BAT for minimising odorous emissions from their installation. Individual Sector Guidance Notes and European BREF Notes are also available which outline odour control activities for the specific activities within each sector. An odour impact assessment needs to be undertaken and in the case of installations with a history of odour complaints a detailed odour assessment needs to be submitted. It is important to note that the granting of a Permit represents just the first step in the management of odorous emissions by an operator. Permit conditions often require the formulation of odour management plans as well as comprehensive odour monitoring programmes.

Your obligations relating to Odour under PPC
In order to be granted a PPC Permit, an operator must demonstrate that odorous emissions are minimised using BAT. In determining BAT across an installation, odour must be considered and balanced within the wider context of other releases to different media (air, land and water), and take account of issues such as usage of energy and raw materials. The aims of BAT are:

• to keep the exposure to odour at sensitive receptors below the level at which it would give reasonable cause for annoyance;
• to prevent the generation of odour where possible;
• to contain the odour and use effective treatment techniques, or other means of minimising emissions, where prevention is not possible; and
• to promote the use of good practices for the control of odour, including adequate maintenance and cleaning, storage, containment etc.

The granting of a Permit to an operator represents only the beginning of their regulatory obligations relating to odour. Permit conditions often require the generation and implementation of odour management plans, comprehensive odour monitoring programmes and the identification of odour abatement options.

How We Can Help
ISL Praxis can offer you a wide range of odour related services including:

• gap analysis of your installation relative to BAT;
• formulation of odour management plans;
• full monitoring of odorous emissions and dispersion modelling; and
• identification of how odour emissions can best be prevented or treated at the end of pipe.

Our industrial regulation specialists can offer guidance as they are fully familiar with PPC Regulations and also have a practical knowledge of regulatory interpretation and compliance issues.

PPC Energy Assessment

Energy
The PPC Regulations specifically require that an installation should be operated in such a way that energy is used efficiently. They also require a description of the energy used in, or generated by, the installation to be included in the Permit application. In addition to this, energy efficiency is one of several considerations that must be taken into account when considering BAT for the prevention and minimisation of pollution.

Our specialists have experience in compiling Energy Audits and appraising energy efficiency measures for compliance with the PPC Regulations. We can apply our experience to appraise your energy usage and make recommendations for savings.

Energy use
The starting point for a PPC application is to review the existing in-house energy management procedures in accordance with Horizontal Guidance Note H2, ‘Energy Efficiency’. This involves identifying the energy used and generated on site with reference to the different types of fuel used. An appraisal of energy efficiency measures is required by reviewing:

• energy recovery;
• efficiency from building services; and
• energy efficiency plans.

All installations must meet a set of defined basic energy requirements for energy efficiency, which are based on the implementation of generic low-cost measures designed to address gross inefficiencies. Those installations that participate in either a Climate Change Agreement or Emissions Trading Scheme Direct Participant Agreement, do not have any other energy efficiency requirements. Those installations that do not participate have additional Permit conditions set by the Regulator to deliver additional energy efficiency requirements.

How We Can Help
Our specialists can work with you to produce an energy audit as required by the PPC Regulations. This will identify areas where savings can be achieved, make recommendations to achieve the savings and estimate the cost implications of delivery (including pay-back times). We will produce cost savings per tonne of CO2, and in this way we can produce an energy audit to support climate change levy reduction strategies.

We can help you to fulfil Permit conditions set to deliver energy efficiency requirements by working with you to produce an energy plan that is relevant to your operations at your installation.

PPC Emissions to Air, Land & Water

Emissions to Air, Land & Water
The PPC Permitting process considers emissions from the installation to specific environmental media identified in the regulations as air, land (including groundwater) and surface water. Depending upon the toxicological nature of a discharge, emissions to sewer may also require specific controls.

The measurement and assessment of these emissions is an important part of the application for a permit and for future compliance with permit conditions. Our industrial regulation specialists have expertise in taking measurements and assessing these emissions within the context of appropriate abatement complying with BAT.

Your emissions obligations under PPC
In order to be granted a PPC Permit an operator must demonstrate that the emissions from the installation will not cause degradation nor harm to sensitive human or ecological receptors and habitats. Where emissions are inevitable, an operator can mitigate the degree of emission by demonstrating the use of abatement techniques that comply with BAT.

An operator must report emissions to the Regulator on a prescribed timescale. Reporting may involve emission monitoring requirements, with measurements taken under MCERTS accredited and/or standard reference systems.

Emissions to Air

• Gases potentially harmful to human health, either short-term or long term;
• Gases that cause acidification or eutrophication of surface waters once deposited;
• Gases of climatic concern such as ozone or carbon dioxide;
• Dust emissions, which can potentially smother flora or impact on local air quality;
• Dust emissions that cause visible plumes; and
• Odour (see separate sheet) Must comply with Solvent Emissions Directive.

Emissions to Water

• Direct discharges to controlled surface freshwaters, estuaries and coastal water are assessed with reference to, for example biological oxygen demand and toxicological impacts; and
• Must comply with Dangerous Substances Directive.

Emissions to Sewer
Discharges to sewer are assessed with respect to the levels of toxics and potential breakdown products. Although these discharges are by definition treated by a Sewage Treatment Works (STW), the loading caused by the effluent is also considered. The operator is responsible for demonstrating that off-site STW represents BAT for the specific site effluent constituents. Industrial sectors which produce high loadings will often have an Effluent Treatment Plant located on-site.

Emissions to Land
Direct or fugitive contamination of land is assessed with particular emphasis on the scope for transmission through permeable soils and rocks into aquifers, with reference to the Groundwater Regulations 1998. Deterioration of land contamination is prevented with a view to maintaining the land quality after site closure.

How We Can Help
Our specialists understand BAT and corresponding indicative emissions. We can work with you to identify whether pollutants are captured by the abatement equipment and where they are not we can work with you to provide the necessary justification or to develop an improvement programme. We can take measurements to the required standards and interpret and report these results on your behalf. We have a thorough understanding of harm from emissions and this assessment process. We can carry out measurement and modelling work on your behalf to ensure compliance with Permit conditions.

Assessment of Harm from Emissions
The potential for harm from emissions is considered in terms of their toxicity and/or scope for causing damage to the receptor. Toxic substances considered include mercury, cadmium and a range of pesticides listed in the EC Dangerous Substances List 1 and List 2. The potential for harm to human health of a range of gases are identified in Horizontal Guidance H1 Appendices C and D.

The quantity of emission is considered with reference to the net effect on the receiving environmental medium. This requires the measurement of emission concentrations and flow rates. This information is used to model the net contribution to a particular environment after dispersion. Models used include the H1 software tool and Air Dispersion Modelling Systems. Model outputs are used in combination with considerations of proximity to sensitive receptors (including habitats) in the Permit determination to set Emission Limit Values (ELV), with reference to defined Environmental Assessment Levels (EAL) or Environmental Quality Standards (EQS).

PPC Protection of Land

Protection of Land
There is a framework for the protection of land under the PPC Regulations. This involves the production of an Application Site Report (ASR) prior to the issuing of a Permit. It also requires the implementation of a Site Protection & Monitoring Programme (SPMP) within 2 months of receipt of a Permit as well as site monitoring to the SPMP for the lifetime of the installation. Finally, a Site Closure Plan is required to demonstrate protection after closure of the installation.

Our specialists are familiar with the production and implementation of an ASR and SPMP for a range of industrial sectors. We understand the precise requirements that the Regulator has for the format and design of these activities. We can work with you to understand your specific site requirements and produce an ASR and SPMP for you

Application Site Report
The objectives of the ASR are to undertake a Desk Top study on the activities and substances used at the installation that may provide a pollution risk to land now or in the future. This is a critical report as it provides information on the ground conditions of the site to enable the Regulator to set Permit conditions to protect the land. It involves the collection of information to:

• identify environmental setting and pollution history;
• identify substances that may lead to pollution of the land; and
• identify preventative measures to protect the land.

The operator must state in the ASR whether there is either:

• little likelihood that pollution or leaks to land will occur during the lifetime of the installation.

OR

• a reasonable possibility of current or future pollution of the land from the installation.

Site Protection & Monitoring Programme

The Permit will normally have conditions requiring the operator to implement an SPMP to ensure protection of the land throughout the lifetime of the installation. This involves:

• SPMP submitted to the Regulator within two months of the permit issue;
• reporting of reference data to the Regulator where this is required;
• collection and reporting of data in accordance with the SPMP for the lifetime of the installation; and
• assess effectiveness of prevention measures.

The SPMP will normally require the operator to assess the continued effectiveness of the pollution prevention control measures involving the collection and analysis of samples and/or the inspection of site infrastructure. The scope of the SPMP is determined by the Regulator’s assessment of ‘little likelihood’ or ‘reasonable possibility’ of future pollution, which may agree or disagree with the operator’s assessment given in the ASR. If ‘little likelihood’, then the SPMP will only require a testing, inspection and maintenance programme to ensure that the site’s pollution prevention measures are maintained and continue to be effective. If ‘reasonable possibility’, then the SPMP will be far broader in its scope and will include the collection of reference data. If the potential for ongoing pollution is not removed, long term environmental monitoring is required.

Site Closure Plan
Under the PPC regime, a Site Closure Plan is needed to demonstrate the prevention or minimisation of any pollution risk arising from closure and decommissioning. Particular attention should be paid to the design of new plant or equipment, the keeping of appropriate maintenance records and the maintenance of a Site Closure Plan, which should be fully reviewed at least every 4 years.

How We Can Help
Our specialists will work with you to prepare an:

• ASR - for your site to the standards and format expected of the Regulator. Specific reference will be made to the Technical Guidance IPPC H7, ‘Guidance on the Protection of Land under the PPC Regime: ASR and SPMP’. This will involve the following activities:
• desk top review of all available reference information and reports
• site reconnaissance to record site based observations
• assessment of existing pollution prevention measures
• production of ASR
• SPMP - design a SPMP that is relevant to your site, using the standards and format expected of the Regulator. Specific reference will be made to the Technical Guidance IPPC H7, ‘Guidance on the Protection of Land under the PPC Regime: ASR and SPMP’. This will involve the following activities:
• design of an investigation to collect reference data (if required)
• design of a monitoring programme
• design of an information and data management reporting programme
• reporting the information
• Site closure plan - prepare a Site Closure Plan on your behalf and provide ongoing support to ensure that you fulfil your regulatory obligations.

PPC Raw Materials & Waste

Raw Materials & Waste
The PPC Permitting process requires an installation to assess and minimise its use of raw materials (including water) and production of waste. A PPC Permit application requires the submission of information to demonstrate this. This should include an action plan to improve the efficiency of raw materials use and the minimisation of waste streams. The Regulator may additionally require the operator to produce an improvement plan as a condition of their Permit.

Our specialists have experience in compiling Water Audits and Waste Audits and associated Improvement Plans. We can apply our experience to review your specific installation and produce a Plan relevant to your site and the needs of the Regulator.

Raw materials
In order to reduce emissions, consideration of the nature and quantity of raw materials used in the production process must be regularly reviewed by the operator. This is part of the BAT compliance process, and entails:

• maintenance of raw material inventories;
• periodic review of the end fate and environmental impact of raw materials, with a view to replacing them with less environmentally damaging substances where possible; and
• review of the control of impurities in certain raw materials which may be unsuitable for emission.

We can support you by undertaking these reviews and we will apply the relevant sector guidance to your specific site to produce a Raw Materials Audit. We will incorporate cost benefit analyses to validate improvements or justify retaining existing practices.

Water use
A Water Audit is a tool which enables an assessment of utilisation efficiency to be determined. A formal Water Audit should be conducted every 2 to 4 years but may be required within 1 year of the issue of a permit if no previous audit has been conducted. Efficiency may be reported in the form of annual water use relative to production quantity. Water use can be reduced by means of appropriate recycling, separation of unused roof- and surface-drainage to minimise water transfer to on-site effluent treatment plant, or technological solutions for cleaning and washing.

Our specialists can prepare a Water Audit for you, using sector specific guidance and efficiency objectives. We will provide cost benefit analyses to validate improvements or justify retaining existing practices.

Waste Minimisation
Waste minimisation may be defined as “a systematic approach to the reduction of waste at source, by understanding and changing processes and activities to prevent and reduce waste”. This covers a range of techniques from basic housekeeping through statistical measurement to the application of cleaner technologies.

Key operational features of waste minimisation include:

• ongoing identification and implementation of waste prevention opportunities;
• active participation and commitment of staff; and
• monitoring the use of materials and reporting against key performance measures.

Where waste is produced it should be recovered unless ‘technically and economically impossible’ as stated in the IPPC Directive. If waste is to be disposed of, the operator must ensure that the chosen disposal route avoids, or reduces, any impact on the environment. Waste minimisation, and selecting the best environmental waste disposal option, are of primary consideration in the PPC Permitting process.

Waste avoidance may in part be implemented by reducing raw material used or by recycling waste into processes where feasible. Some wastes can be used to produce energy, with Combined Heat & Power plants frequently being used in this respect.

Indicative BAT guidance suggests a Waste Minimisation Audit should be undertaken at least every 4 years but may be required within 1 year of the issue of a permit if no previous audit has been conducted.

Our specialists can use their expertise to undertake a Waste Minimisation Audit on your site for you. We will analyse your use of raw materials, assess opportunities for reductions and provide an action plan for improvements. We will follow a basic three-step process:

• process mapping;
• materials mass balance; and
• action plan

We will use this information to identify and assess opportunities for improved efficiency, changes in process and waste reduction.

IPPC PPC Useful Links

www.defra.gov.uk/Environment/ppc/policy.htm
This website contains a links to a variety of information sources on various aspects of industrial pollution control, including the EU Directives, Regulations and Guidance documents

www.environment-agency.gov.uk
Guidance information on the PPC Regulations is available from the Environment Agency’s website

www.netregs.gov.uk
A full listing of all PPC legislation is listed from this part of the Environment Agency’s website

www.sepa.org.uk/ppc/
The Scottish Environment Protection Agency is the main environmental regulator in Scotland and provides detailed information on legislative requirements, guidance for business, and technical guidance on waste treatment and disposal.

www.ehsni.gov.uk/environment/industrialPollution/ippc.shtml
The Environment and Heritage Service is the largest agency within the Department of the Environment in Northern Ireland. It takes the lead in advising on, and implementing, environmental policy in Northern Ireland.

www.eippcb.jrc.es/
The European Integrated Pollution Prevention and Control Bureau provides information on best available techniques, including BREFs.

Information Sheets
Below are a number of documents that contain useful information on the Pollution Prevention Control Regulations (PPC) and how ISL Praxis can support you:

• Integrated Pollution Prevention & Control
• Environmental Management Systems
• PPC Horizontal Guidance: BAT Assessment
• PPC Horizontal Guidance: Noise
• PPC Horizontal Guidance: Odour
• PPC Energy Assessment
• PPC Emissions to Air, Land & Water
• PPC Protection of Land
• PPC Raw Materials & Waste

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