Reporting of releases to land in France

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Meeting of the E-PRTR EXPERT GROUP Brussels Reporting of

Ministry for Ecology, Sustainable Development and Energy 03

1 Meeting of the E-PRTR EXPERT GROUP Brussels Reporting of releases to land in France Presentation by the french Ministry for Ecology, Sustainable Development and Energy 03 november 2015 Laure ENJELVIN MEDDE/DGPR/SRT/BNEIPE Ministère de l'écologie, du Développement durable et de l Énergie

2 The challenges faced by MS A big disparity is established about the reporting to land from the different member states. The DG ENV has proposed setting up a working group between MS: to clarify why reports seem to lack completeness : The absence of information about good pratices? Regulatory and legislative complexity? Exclusion of recovery operations such as sludge and manure spreading? Integration of information on storage sites or contaminated site in PRTR? (cf proposition of UNECE for WGP 26/11/2015) 2

3 Historical regulation concerning releases to land 3

4 Historical regulation concerning releases to land Ministerial circular of 13 march 2008 Livestock manure not concerned If industrial plants spread sludges,they only report pollutants without agronomic potential (metals, hazardous subtsances...) 4

5 Differences between european and french regulation Number of pollutants Regulation E- PRTR Ministerial decree 31/01/2008 (annex II de l'am 11/12/14) Additional pollutants land Heavy metals (Al, CrVI, Fe, Mn, Sn, Ti, Tl) + SPFO + PCB indicators et PCB Dioxines-like 5

6 Pollutants reported in France emissions pollutants reported in 2015 in France (emissions 2014) : 2014 Number of reporting above the national threshold Number of reporting under the national threshold Total of reporting Heavy metals (Al, As, Cd, Cr, Cr VI, Cu, Fe, Mn, Hg, Ni, Pb, Ti, Zn) Inorganic substance (Nitrogen, phosphorus, chlorides, asbastos) Chlorinated organic substance (PCB, AOX) Other organic substance (PAHs, naphthalene, nonylphenols)

7 Activities and number of plants reported : 2014 Number of plants reported Heavy metals Inorganic substance Chlorinated organic substance Other organic substance Food industry collection and treatment of waste water paper or paperboard manufacturing Other type of industry

8 Some examples of emissions trends 8

9 Some examples of emissions trends 9

10 Some examples of emissions trends 10

11 Some examples of emissions trends 11

12 Releases to land or off-site transfers? In France, only sludges that have an agronomic potential can be spread. Improving knowledge on substances with no proven agronomic potential for soil or crop nutrition : Facilities performing land spreading or WWTP generating sludge : If the facility has a land spreading permit (its own sludge or sludge from other facility), it reports releases to land (but do not reports the sludge as a waste) : > Pollutant-approach If the facility does not have any land spreading permit, the sludge is spread by an external service provider which has a permit. It is reported as a waste. > Waste approach 12

13 Exclusion of reporting for E-PRTR At the meeting of the E-PRTR Expert Group on the 6 june 2012, an analysis of soil data was presented by the European Environment Agency s European Topic Centre Air and Climate Change ETC/ACM. France reported 75 % of releases to soil (emissions in 2009) of all MS. 13

Exclusion of reporting for E-PRTR Following the discussion during this meeting and the conclusion of Time series analysis, & in accordance with the point 9 of «whereas» of regulation 166/2006 E-PRTR,

14 Exclusion of reporting for E-PRTR Following the discussion during this meeting and the conclusion of Time series analysis, & in accordance with the point 9 of «whereas» of regulation 166/2006 E-PRTR, it was decided to exclude reporting for E-PRTR for 2014, emissions to land from the following activities : 5.f - Urban waste-water treatment plant 5.g - Independently operated industrial waste-water treatment plants (...) 6.a - Industrial plants for the production of pulp from timber or similar fibrous materials 6.b - Industrial plants for the production of paper and board and other primary wood products (such as chipboard, fibreboard and plywood) 8.a - Slaughterhouses 8.b - Treatment and processing intended for the production of food and beverage products from: Animal raw materials (other than milk) / Vegetable raw materials 8.c - Treatment and processing of milk 14

15 Selection criteria for keeping releases to land Facilities are used to reporting their releases to land for several years, Pollutants without any agronomic potential (hazardous or toxic substances) may be considered as a source of pollution with an significant environmental impact, Releases to land may affect groundwaters, The french administration is willing to know about all the sources of pollution, including about the land spreading of sludge, Releases above the notification threshold are reported in the national register make the knowledge on releases of pollutants to land available to the public. We will re-start the reporting of our data into the soil for the E-PRTR regulation, as soon as the other MS do the same. 15

16 Thank you for attention 16

17 Questions for discussion What are the treatment practices for sludge from the food industry / paper industry / WWTP? (standarts?) What are the identified activities that generate emissions to soil in your MS? What causes might explain the lack of completeness : lack of information on the releases to land, a unwillingness to publish data, other cause? Do you have a website for public information about the soil contamination of former industrial sites? Does pollution relating to contaminated site should be published on the national register? On E-PRTR? 17

Revision of Fertilisers Regulation (EC) No 2003/2003

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