Experience in the UK in implementing E-PRTR and Data Validation Bob Boyce, Senior Environmental Assessment Officer, Environmental Quality Department, Edinburgh

Introduction UK competent authorities 2007 EPRTR reporting summary UK and regional PRTRs Quality Assessment Guidance

The UK Bunkerland England Wales Northern Ireland Scotland

UK – 5 competent authorities Numbers in brackets refer to the number of 2004 EPER reporting installations. All CA except DTI will have an increase the number of installations reporting under E-PRTR. DEFRA is often the lead organisation representing the UK and the Environment Agency representing the environment agencies/competent authorities within the Commission. Scotland and Northern Ireland have different legal systems which is why they have implemented different Regulations under the IPPC Directive. One “volunteer” from SEPA or EA is appointed to collate the UK data return and submit it to the EEA. SEPA collated 2007 report.

Distribution of facilities in UK according to EPER website

UK National and Regional PRTR The UK-PRTR went live in early 2009. Public and industry consulted in PRTR development. DECC, DEFRA and NI do not have PRTRs. SEPA and the England and Wales Environment Agency (EA) have regional PRTRs. The EA-PRTR started in 1998 and SEPA’s Pollutant Release Inventory in 2002. Similar electronic data capture and public access systems. Use a common list of 215 pollutants, thresholds (much lower than E-PRTR) and activities (some capacity thresholds lower and additional activities). A UK National Atmospheric Emissions Inventory is available for a few pollutants. (http://www.naei.org.uk/) BRT = a company must report if they have releases above zero but below the reporting threshold, they do not report a value but BRT. A UK wide public consultation will take place in the summer of 2007 to determine what is in the UK PRTR and how it looks.

Regional PRTR The EA, SEPA and NI PRTR collect data from: All large IPPC sites, similar to E-PRTR; Sewage treatment works > 15K PE; All marine fin fish farms (no capacity limit); Major sites that use radioactivity, e.g. nuclear power plants, hospitals, research centres, universities; Off-site transfers of waste by weight. Over 5500 sites report – only half report to EPRTR. DECC, NI and DEFRA do not collect data beyond E-PRTR

Quality Assessment Procedure

Quality Assessment – Online validation Release value must be greater than threshold Last year’s release > 50% or < -50% this year AND/OR > 5 years data then > 2x standard deviation Operator must supply explanation if above is true. Operator must explain if a pollutant is added or removed or increased or decreased wrt threshold. Use of indicative lists at EC and local level Pre-populate return with indicative pollutants for new sites and last year’s submission for old sites Below Reporting Threshold (BRT) must be reported BRT we do this for three main reasons: It helps with identifying sources of pollutants It helps us determine if threshold is set correctly

Quality Assessment - Site Inspector Annual on-site inspection: check some details of PRTR reporting: Full PRTR audit when necessary. Check release data based on process equipment, production type and volume. Are any increases/decreases in reported values accurately and properly justified? Was the correct methodology used for that type of process in any measurement methods for producing release values? Was the correct methodology and parameters used in calculations or estimations for that type of process? Comparison with historical values (trends). Are all pollutants reported as BRT correct? Are there any missing pollutants? At least one annual on-site inspection will include checking of at least some aspects of PRTR reporting. A special full PRTR audit is carried at some installation each year.

Quality Assessment – Public validation Revealed: Scotland's 17 serious polluters General public includes: Other operators in sector Local pressure groups Other Local and National Government departments Non Governmental Organisations (NGO’s) Public service organisations (e.g. ENDS - Environment News Daily) and local newspapers DO NOT underestimate the passion and effectiveness of this validation group (at least in UK) Environmental Data Services (ENDS) has been a leading provider of environmental intelligence in Europe since 1978. A UK based company.

Guidance - sector specific tools and guidance Landfill: ConSim leachate estimator tool and GasSim model for estimating landfill gas emissions (free “lite” versions available) Waste water estimation tool (developed and funded by regulators and UK Water Industry) Guidance (available on website - http://www.sepa.org.uk/spri/guidance.htm) Waste Treatment, Transfer and Storage: non-landfill waste activities Combustion Activities Petroleum Activities Food & Drink Cement & Lime Chemicals Incineration Metals (ferrous and non ferrous) Paper & Pulp Quarrying and mining (in development) Waste Water – a collaborative approach between industry and regulators.

Penalties No penalties have been issued to date. UK uses Notice under IPPC Regulations to require reporting. These are separate from permit enforcement penalties. IPPC notice can be used to cover non-IPPC activities for purposes of an inventory. The Notice is served against a company, the company named on the authorisation, the chief executive is usually responsible.

Penalties UK uses an Information Notice under the PPC Regulations to collect data, penalties for non-compliance are: Under a summary conviction: Max fine of about £5,000 (7,000 euros) or Upon conviction on indictment: a fine or up to 2 years imprisonment, or both

The End Thank you