Industry environmental self-monitoring and reportingUK experience with reference to the Pollution Inventory

Dr Ian WhitwellThe Environment Agency of England & Wales(www.environment-agency.gov.uk/pi)

IntroductionThe Environment Agency is the main competent authority for regulating large industrial activities in England and WalesPollution Inventory established in 1998 - a Pollutant Release and Transfer Register or PRTR. Not compliance checkRio Agenda 21, US Toxic Release Inventory, UK Chemical Release InventoryRecords annual mass releases and transfers from the industrial activities that we regulateOther PRTRs in UK - not fully integrated yet

ObjectivesTo satisfy the needs of stakeholders requiring information on releases to the environment (includes UNECE, EC, UK government, citizens, NGOs, industry). To do this we:

Provide data and information on releases to the environment and their possible impact in a scientifically valid and transparent way, with easy access, set in its proper context, to a general audience

Use the information to evaluate regulatory policies and the benefits of regulation

Provide feedback on environmental performance and contribute to industrial benchmarking

Collect data in a consistent and cost-effective way (proportionate to the objectives)

Principles Mandatory requirement to report industrial releases for

specified substances Reporting requirements should be clear and open and

should not be a back-door route for requiring additional monitoring

The best information to be provided without causing excessive burden

Industry consulted when changes are to be made Operator responsible for providing information, not the

regulator, ie self-monitoring Include international PRTR requirements

Development of the Pollution Inventory

Environmental issues

Activities (sources) and locations

Contextual information NOT just data

Data(releases and

transfers)

Drivers include:•National PI•EPER/E-PRTR•UNECE PRTR

Coverage includes:-substance information-burden measures-risk-based information-site-specific commentary

Coverage includes:-process industries: mainly IPPC-wastewater works-radionuclide sites

Driven by

legislation

e.g. Aarhus, IPPC

Public and

stakeholde

r expectatio

n

Scope Most IPPC Annex 1 activities Large wastewater treatment works Sites with releases of radionuclides Around 170 reportable substances or groups - multimedia Reporting threshold set to capture 95% of emissions from the

activities we regulate releases below reporting threshold defined as ‘brt’ no release is defined as ‘not applicable’ (n/a)

Measured, calculated, estimated Data collected, entered and verified locally; some centralised

checking Some commercial-in-confidence and national security issues

Air

Wastewater treatment

Land Off-site waste transfers

Other disposal

Sewer

Water

Reportable media

Air

Activities reporting

0

1000

2000

3000

4000

5000

2000 2001 2002 2003

Year of reporting (Emissions)

Num

ber

of a

ctiv

itie

s

RSR

STWs

WML

PPC

IPC

Legal and institutional issues Reporting mainly from activities permitted under IPPC Pollution Prevention and Control (PPC) Act and

Regulations determines competent authorities and the activities required to report

Competent authority determines specific sites for permitting Reporting requirements defined in Information Notices

rather than in the permit itself - flexible Notice issued every 3 years Can change requirements without varying permit conditions Pollution Inventory Advisory Group

Electronic reporting screen

Reporting guidance and tools Concerns over lack of reporting Assist by producing guidance and reporting tools:

recommend measurement techniques MCERTS certification (www.mcerts.net) Operator Monitoring Assessment (OMA) scoring define alternative calculation and estimation methods (emission

factors, mass balance etc) General and sector specific Jointly funded working groups (industry and regulator) Highlights most relevant substances, but operator has responsibility

to report all relevant releases Currently use of the guidance is not obligatory Available from our website (www.environment-agency.gov.uk/pi)

Guidance and tools - eg landfills

Landfill leachate estimator tool

Landfill gas emissions estimation tool - GasSim

Quality assurance and checking

26 Areas Three levels of checking

Area Inspectors using site-specific knowledge Centralised using trend analysis Operators have opportunity to view and amend prior

to publication Some experience must be built up before QA methods

can be fully developed

Public information - WIYBY

PI data published annually on website

‘What’s in Your Backyard’ - WIYBY

Easily accessible by stakeholders

Downloadable Maps Comparisons ‘Spotlight on industry’ report

Contextual information

Substance information sheets

Burdens - Global Warming Potential for releases from activities we regulated in 2000

Contextual information

Lessons learnt Monitoring not obligatory for PI Legal clarity needed. What and by when? Consult with industry Guidance and tools

- joint funding- consistency

Context Regulation by information Advisory Group with stakeholders Highlight benefits to industry - public image