Reporting to the EPRTR in the UK Alex Hole Assessment & 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 UK England & 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 - PPC PPC (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 28 th 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 – 1 st year only Report using electronic system (not available for non-PPC in 1 st 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 activities Intensive Agriculture - emissions Calculation 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 activities Intensive 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 activities Intensive 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 data Several levels of QA are carried out following the submissions of data to us 1. 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 data

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

Non PPC activities Mines & Quarries 2 Identifying 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 3 Problems 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 5 Guidance 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 activities IOWWTWs - 1 Key issues/problems Identifying sites What is a treatments works? Which pollutants? QA of data

Non PPC activities IOWWTWs - 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 activities IOWWTWs - 3 Which 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

Discussion / Questions

Reporting of Waste

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

Reporting of Off site waste transfers EPRTR 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 transfers How 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 continued Key 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

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