Requirements that have to be Met
Pre application guidance[x] provide a hint to perspective permit holders that things are not going to be easy, the flow chart below shows the various stages to be completed before application;
We will follow the guidelines from the view point of opening a large intensive pig farm.
A: Operate a big pig farm (more than 2000 animals).
A: The EA will be the Regulator
A: Yes I will need a permit
A: Yes - Section 6.9 of Schedule 1 Activities .
A: Apply for a Standard Permit.
So Farmer Ted applies for his permit and it is granted it but what will that mean for him. . .
When viewing a Permit[xi] we can see the requirements that have to be in order to remain in compliance. Spread over 126 pages in this case there are great many of them;
General Management: A written EMS must be maintained, Records to be kept proving compliance, and a copy of the permit should be kept by anyone who has EP responsibilities.
Operations: Improvement programme, Pre-operational conditions (ie. base lines)
Emissions and Monitoring: Sets out emissions limits where limits exist, and expectation for controls on emissions where no limits exist. Specifies that monitoring must be maintained for following factors:
“(a) point source emissions specified in tables S3.1, S3.2 and S3.3;
(b) surface water or groundwater specified in table S3.5;
(c) noise specified in table S3.6;
(d) ambient air monitoring specified in table S3.7;
(e) process monitoring specified in table S3.8;
(f) land specified in table S3.9”
Information: Sets outs the standards that monitoring records should meet (they should be legible and up to date), it also details expectations for reporting, and reminds the operator that wording in any reports will be taken to have the same meaning of the wording in the permit. So they will have to careful how they write it!
The permit then spells outs how things should be done in a series of annexes;
Annex 1 - Waste management:
Expected treatment of WEEE (Waste Electrical & Electronic Equipment) waste is outlined (right), it is specified that BAT (Best Available Technique) should be used.
BAT can be deduced using the relevant BAT Ref Document sourced from the Europa Website in this case[xii]
BAT Ref Document “Waste Treatments Industries” contains 600 pages of information on dealing with waste, so there is no shortage of information.
Each Annex is broken down in to four main chapters as with the main Permit layout;
1. General Management
3. Emissions and Monitoring
Annex 2 – Waste Mobile Plant not using a deployment form
Basically states that say a mobile soil washing plant, comes under the same regulations as a static one.
Annex 3 – (Part A) Low Impact Installations
Interesting things crop up here under general management;
1. Energy efficiency
2. Efficient use of raw materials
3. Avoidance, recovery and disposal of wastes produced by the activities
These are the kind of things you may expect to see under a Environmental Management System Such as ISO 14001.
The permit points the operator to the relevant part of the EP Regulation in the Case of Energy Efficiency above;
“For the following activities referenced in schedule 1, table S1.1 (A1 to A4 etc.) The operator shall:
(a) take appropriate measures to ensure that energy is used efficiently in the activities;
(b) review and record at least every four years whether there are suitable opportunities to improve the energy efficiency of the activities; and
(c) take any further appropriate measures identified by a review. “
So we look at for Schedule 1 table S1.1 and . . . . its not even in EPR 2007, 2009 or 2010 so now what? Is it in the IPPC directive? No. Mass Confusion. So I presume from this that table S1.1 must be specified in a genuine permit?
There are a further 34 Annexes in the template permit covering every aspect of the operation, obviously in this case the EA have included lots of Annexes so as to cover a broad range of information. In real life the Permit would only have Annexes Relative to the Activities on site.
[ix] Personal Experience