Ingen diastitel

1
Coordination of Permitting Procedures and
Conditions
Bjørn Bauer Manager of PlanMiljø

• Danish Inspection Guidelines
• IMPEL Management Reference Book
• AC IMPEL Project
• IPPC and Inspection in Romania (Piatra Neamt),
• Bulgaria, Slovakia, Estonia, Latvia, Poland
• Danish Quality System for IPPC Permits
• Bolivian Inspection System

2
The integrated permit
3

Challenges for accession countries

• New permit procedures - for both authorities and
  enterprises
• Negotiation with operators
• BAT requirements
• The integrated approach
• Public involvement
• Permit to new installations before accession
• and to existing IPPC-installations within a given
  time frame.
• Coordination between authorities

4

IPPC Basic principles

• All new installations must have a permit before
  they can operate (Article 4)
• The installations are responsible for providing
  sufficient data and submitting application
  (Article 6)
• Where more than one competent authority is
  involved then the procedures must be fully
  co-ordinated (Article 7)
• Permits must be periodically reconsidered and
  where necessary the conditions updated (Article
  13)

5
Permit procedure (overall)

Authority Submitted application
Return to enterprise
Distribution to other authorities and public
access
Authority Comments from stakeholders on
application
Draft permit Hearing period
Authority Comments from stakeholders on
conditions
Final permit issued
6
Example on Procedure Plan from Slovakia
7
Conditions Three main types

• General conditions
• Layout and construction of site
• Operation of site
• Emission Limit Values
• Monitoring and control including self
  monitoring

8

Environmental subjects to deal with

• Noise
• Vibrations
• Dust
• Odour
• Air emission

• Water
• Wastewater
• Waste
• Energy consumption

The permit must include all relevant
environmental media. Several authorities can be
responsible for or involved in formulating the
conditions.
9
Directives to consider in IPPC permits

• VOC
• Landfill
• Seveso II
• EIA
• Waste deposits
• Large combustion plants
• Waste incineration
• National emission ceilings for certain
  atmospheric pollutants
• Limitation of emissions of certain pollutants
  into the air
• Discharge of dangerous substances
• Water frame
• Air quality

10
Seveso inspectors
National/regional Inspectorate
Others

National BAT-Centre
Fire
Permit Authority
Mutual interdependence. Need for frequent
communication
Relevant authorities - Integrated permit
Land and Rural Planning
Groundwater. Water supply
Regional/local
Health and safety
Laboratories
11
Procedure for coordination

• The national IPPC legislation does not
  necessarily target coordination in the
  preparatory phase.
• Circular for cooperation between inspectorates
  and occupational health authorities
• Legislation itself does not ensure factual
  coordination human beings do

12
Procedure for coordination

• It is the IPPC authoritys responsibility to
  ensure coordinated formulation of conditions
• The IPPC authority identifies the main problems
  and establishes an IPPC team accordingly,
  typically covering wastewater, air, energy, and
  waste.
• Simultaneously, the Team should identify and
  communicate with other relevant competent
  authorities central, regional and local

13
Procedure for coordination

• The IPPC team formulates the first draft permit
  and forwards the proposed conditions to the
  relevant external authorities
• Especially coordination with authorities within
  water supply, waste treatment, spacial planning
  and health/safety is important
• The external authorities review the draft permit
  and forward suggestions to changes to the
  permitting authority
• The IPPC team considers the comments from
  external authorities and revise the conditions
  where found appropriate