Guidance Note Environmental Performance Reporting

Transcription

1 Guidance Note Environmental Performance Reporting REP LS October 2014 Definitions: ARWA Advanced Regulatory Wiki Application (produced by SEU) BAT Best Available Technique BRC Beyond Regulatory Control Bref BAT reference document CA Competent Authority EIA Environmental Impact Assessment EMP Environmental Management Plan EPR Environmental Performance Report ER GT Environmental Review Gasturbine H1-2 Half yearly report starting at half year 1 of a specific year IPPC Integrated Pollution Prevention and Control LDAR Leak Detection and Repair M1-12 Monthly report January December of a specific year MECA Ministry of Environment and Climate Affairs NOL PM10 No objection letter Partical Matter (dust) PQL Practical Quantitation Limit Q1-4 Quarterly report starting at quarter 1 of a specific year SEU Sohar Environmental Unit SFZ Sohar Free Zone W1-52 Weekly report starting at week 1 of a specific year 1. Objective and approach Environmental Performance Reporting is a requirement that a permit holder has and that allows the Competent Authority to keep track of the environmental issues on all the relevant environmental compartments. The SEU likes to harmonize the reporting on the environmental issues in order to have a more effective compliance control. A secondary objective of the EPR is to make companies more aware of the impacts to the environment. REP LS Guidance Note Environmental Performance Reporting page 1 of 11

2 Compliance Environmental Performance of a company is the level of compliance to the imposed environmental requirements. The Environmental Performance Report (EPR) must include the standards and the source of the standard for verification of the compliance with the permit or other requirements. In addition to the regulatory requirements, a company is required to adopt state-of-art techniques... and to use clean production techniques to prevent pollution of the environment. 1 The conditions of the environmental permits also contain obligations to use BAT. Compliance to BAT must be demonstrated in the EPR. Covered environmental compartments The EPR covers the regulated environmental compartments that are selected from (but additional reporting requirements might be present) the following list. Air Industrial Waste Water Climate Noise Radio Activity Industrial Safety Ambient air quality, emissions Construction, hazardous, non-hazardous, Marine quality, discharge to marine, discharge to WWTP, Zero Discharge policy, sewage, deep excavation, irrigation water As per Climate Affairs requirements On-site, at boundary Focused on Radio Activity check gates Incident/accident reporting, actions related to safety management You are advised to integrate the reporting requirements into the Environmental Management Plan. 2. General requirements on reporting Who All companies that have an environmental permit. An EPR must be submitted by the company that holds the permit. Background information is only to be provided in annexes (e.g. lab reports, subcontractor reports). Subcontractors (e.g. during construction) are reporting through the permit holder and it is the permit holders duty to make sure that subcontractors are compliant with the reporting requirements. 1 Article 10, RD 114/2001 REP LS Guidance Note Environmental Performance Reporting page 2 of 11

3 When At the moment an Environmental permit is issued, the receiving company has an obligation to start reporting. If report must cover a period project preparation without any activities, a letter stating the project status (yearly) has to be submitted. If the report covers a period of construction, an EPR has to be submitted based on the construction EMP and obviously the EPR will not contain any process data. The EPR must be submitted to the SEU with the agreed frequency and directly by the permit holder or explicitly on behalf of the permit holder and must mention the name of the responsible person in the company. The covered period must be clearly mentioned. The period numbering convention is that notations start at the beginning of the calendar year (e.g. Q means covering the second quarter in 2014 and does not mean the second submitted quarterly report). The reporting frequency is Monthly, Quarterly, Half yearly, Yearly or any other period if so found necessary by the CA. Reporting frequency can be adapted (less frequent, more frequent) based on historical data, process control history and environmental risk. Note that at least once a year a report has to be submitted. Companies that do have a permit but claim that they have nothing to report (as per requirements in this document), have to (re)state that yearly. The EPR is due within the indicated weeks after ending of the reporting period as mentioned in the next table. Table 2: Submission date schedule Frequency Monthly Quarterly Half year Yearly Delay of submission 3 weeks 4 weeks 6 weeks 6 weeks In case of exceeding the deadline a warning and after repetition a fine will be issued. EPR Submission enforcement schedule that will be used by SEU is as follows: One week exceedance of EPR due date: reminder mail. Two weeks exceedance of EPR due date: warning mail. Three weeks exceedance of EPR due date: warning letter. Four weeks exceedance of EPR due date or repetition exceedings: fine as per article (13) and (31) RD114/2001. Note that implementation of this rigid control schedule will depend on SEU capacity. Not receiving a reminder does not change the obligation to report as scheduled. REP LS Guidance Note Environmental Performance Reporting page 3 of 11

4 If a company works on project basis (e.g. rig repair or infrastructure projects) the EPR must be adopted to the specifics of the project with respect to EPR chapters, parameters and frequency. How The EPR format is not regulated, but the data information could be submitted using the SEU excel sheets. The EPR is then completed with a textual report with references to the data files. Using the excel sheets is not obligated. The EPR is to be submitted as soft-copy that is send to meca.seu@gmail.com with subject starting with SEU_EPR. Not using these requirements will result in failure to register. Hard copies will not be accepted if they are not accompanied with an copy. reception date will be the submission date and acknowledged by a reply . EPR processing by SEU On reception of an EPR, SEU will register reception, forward a copy to MECA Muscat office (Environmental Affairs and CA) and review the content. If so deemed necessary SEU will comment or ask for clarifications. If non-compliances are identified, SEU will consider enforcement as follows: administrative enforcement for non-compliances with this Guidance Note and providing wrong or incomplete data and information and regulatory enforcement for non-compliances with standards for concentrations, quantities, etc. Enforcement for non-compliances with standards will be assessed on a case by case basis. If any circumstances occur that prevents timely submission of the EPR, the company must request suspension of the enforcement and specify the reasons for delay to the SEU before the due date. Exceptions Exceptions on EPR reporting (combining reports, changing frequency, parameters etc.) are permitted only after explicit acceptance by the SEU. 3. EPR content overview In this chapter an overview of the content of the EPR is given. This concerns the textual part and the data part of the report. It is appreciated that in the reports the same order is used as in this overview. In case an item is not applicable the company can decide to skip that chapter. REP LS Guidance Note Environmental Performance Reporting page 4 of 11

5 General info Report summary The summary of the report contains a summary of the data (non compliances), special circumstances etc. which are important to understand the report. Non-limited items are listed below: Explicit statements have to be made concerning compliance and non-normal situations (e.g. in reporting period no standards were exceeded, no non-compliance situation were encountered, no accidents/incidents occurred ). point to any specific non-compliance situation or special circumstances that are not business as usual. These include spills, leaks, accidents, etc. non normal operation conditions like: lower capacity, one-off emissions, emergency shutdowns/start-ups; General information Background information on the reported data is very much appreciated, however repeating the same background information (e.g. method description, equipment description, location layout, etc.) in consecutive reports will not be accepted. Description of changes in production techniques, improvement projects etc. is of course allowed, because it gives SEU insight in what is going on. Production and raw material data Production data are to be reported in order to relate the performance to operational parameters like: on-stream time, gas consumption, product tonnage or volume, energy consumption. Production data are reported in a table in ton/period. Secondary raw material use of the most important substances is reported. This means that small amounts of e.g. lab chemicals and cleaning chemicals are not reported. The amounts are reported in table in ton /period and ton/product when applicable. In specific cases the composition of raw materials have to be reported (e.g. sulphur content, ash content). SEU will point that out to the company when applicable. Specific emission (e.g. g per kg product) or yearly emissions (actual or prorated) for key components that are relevant for IPPC compliance are to be reported. As key components are considered: NOx, SO2, PM10, CO, CO2, VOC. Typically to be reported: key component in ton/yr and in g/kg product. REP LS Guidance Note Environmental Performance Reporting page 5 of 11

6 Regulatory The following items are reported in a table. All current permits, licenses, No Objections, waivers and other environmental regulatory documents; Info: Type, date of expiration, date renewal request; Example: Env. Permit no 12345, expiry date: 1 Aug 2011, renewal request submitted on 1 Jul 2011; Evaluation A separate evaluation chapter or paragraph is added to the report. In this paragraph not only the (non)-compliance of emissions are mentioned, but also, when applicable, an evaluation of the emission patterns, notable peaks in emissions, notable exceptions of data (i.e. data not used in average calculations), explanation on exceeding non compliance, the effect of non normal operations conditions etc. Air emissions In this environmental compartment three items are to be reported: stack emissions, fugitive emissions and ambient air quality. Stack emissions Reporting air emission is required to check the (non) compliance of emission standards. This means that the emissions must be reported under the same normalized conditions as used in the regulatory. The data must be reported under the IPPC/BAT conditions as described in the GN Data collection and processing. Emissions from all stacks are reported as follows for all applicable substances. The SEU excel sheet can be used for this purpose: Average concentration on reported period in mg/nm3 standard conditions; Minimum and maximum in reported period in mg/nm3 standard conditions; Method of sampling CEMS or random grab sampling. In case of grab sampling the number of samples are reported; Average flow rate in Nm3/hour measured; Total load (ton) in the period; Cumulative load (ton) in the covering year; Percentage validated values; 95% confidence interval for the measurement instrument REP LS Guidance Note Environmental Performance Reporting page 6 of 11

7 Companies that generate information from CEMS also report all the measured daily average data over the period including parameter vs time graph in an Annex of the report, or according the SEU excel sheet. For the emissions to be reported the following rules apply: Burners and GT s using natural gas report NOx and CO. Reporting SO2 and PM is not required; On other processes the applicable substances are reported, like NOx, SO2, PM, CO, VOC. SEU will give instructions to companies in case others emissions, due to the specific production, must be reported; Fugitive air emissions Depending on the production process and the used (raw) material, fugitive emissions of PM10 and VOC occur and must be reported. In general the following fugitive emissions can occur: Emissions from (VOC) storage tanks due to breathing and working losses; Emissions resulting from (un)loading ships; Emissions from process equipement like, pumps, seals, connection etc. Reported are estimates, calculated or measured emissions of PM10 and VOC when applicable. The method of compiling the data is reported and the data cover the reported period. For emission from tanks the software TANKS from EPA can be used. When LDAR is carried out this is mentioned including the date of the last measurements and an overview of the repair actions taken in the period. Ambient air quality Ambient air quality can be measured continuous and periodically. For continuous ambient air measurements the following is reported: Average ambient concentration (µg/m3) for the applicable substances; Minimum and maximum concentrations for the applicable substances; Meteo data during reporting period: Graphically parameter (daily average) vs time; The averages are compared with the provisional Oman ambient air quality regulations, and/or USEPA regulations and/or EU-regulations; Non continuous ambient air measurements are not required. However, in special circumstances (i.e. specific substances) SEU will ask to perform measurements. REP LS Guidance Note Environmental Performance Reporting page 7 of 11

8 Water emissions Related to water, the following discharges can be applicable: (treated) process waste water stream discharged to the WWTP of MISC, sea water for cooling purposes discharged to the SWIRS, sewage discharged to MISC. When sewage is discharged separately to a WWTP, no data of this waste water have to be reported. Discharge cooling water The prominent factor for this discharge is the temperature rise and (when using chlorine) the free chlorine content in the water. The following data are reported: Temperature incoming cooling water in grade Celsius, daily average; Temperature discharged cooling water in grade Celsius, daily average; Temperature rise, daily average; Free chlorine in discharged cooling water, daily average; Flow of cooling water in m 3 per time frame. The method of measurement is reported (grab sample, continuous etc). Mind that in case of grab sampling the temperature in and out are measured in the same hour. Discharge (treated) waste water to WWTP MISC Beside the measurement requirements from MISC measurement of the discharged water has two objectives: following the performance of the company and information for process control for in the company.the measurements for process control are, in general, not analyzed in a lab, but using rapid test kits. The results have a lower confidence interval and are not feasible for compliance purposes, however provide a good impression of the discharge. The following is reported per measured substance: Sampling method: grab sample, time proportional sample, volume proportional sample; Date of sampling (in case of grab); Analytical method: rapid test (plus method), lab-test (plus method) 95% confidence interval of method; Concentration Cx (mg/l or µg/m3) and PQL; Flow of discharged water per time frame; Use a different table for the analysis in the lab and result of the rapid test. In some cases, and more to come, treated water will be recycled as process water or re-used as irrigation water. Add a water balance in the report. REP LS Guidance Note Environmental Performance Reporting page 8 of 11

9 Waste The following data must be reported; the SEU excel sheet can be used: Industrial waste generated per period, per waste stream in ton; Industrial waste storage on site on the end of period per waste stream in ton; Different tables for non-hazardous and hazardous waste are used; Industrial waste disposed or otherwise managed has to be reported in relation to the Consignment Note, No Objection, Basel Convention and other regulatory frameworks. Waste destination (name of disposal company, disposal site); Cumulative generated waste in the covered year per waste stream and in ton. Industrial safety Safety deserves daily attention from management. The EPR will show incidents but also actions taken to lift safety awareness and safety management to a higher level. The following items are reported: Incidents/accidents with impact outside the battery limits have to be reported directly as part of the emergency response requirements. The EPR contains an overview of the incidents with estimations of released components (type, quantity) to air, water, soil (including firefighting water if applicable), with reference to the GN Incident Reporting; Accident generated products (e.g. waste absorbent, firefighting water); Implementation progress of the Safety Management System (SMS); Actions taken related to safety awareness like training, incident evaluation, adapting procedures and instructions etc. Soil Under normal operations conditions nothing has to be reported related to soil and groundwater. In case (spill) incidents have occurred in the covered period, following must be reported: Contamination details (origin, components, concentrations). Sample location, time/period. Total amount involved, treatment or disposal details. Sampling method (composite sampling details). In case an incident report, according the GN Incident Reporting is already submitted, only notification of the incident and referring to the incident report is required. Noise Noise levels resulting from industrial sources tend to be stable in time. In case of replacements of equipment or an overhaul, the total noise emission can change. For this reason measuring noise emission on the site boundary is only required in these circumstances. Measurements are carried out in the following circumstances: REP LS Guidance Note Environmental Performance Reporting page 9 of 11

10 The first two report after commissioning a new site; The first report after a major extension of the site or site activities; The first report after the replacement of noise relevant equipment; The first report after an overhaul. The measurements are carried out according the GN Data collection and processing in three periods (day, evening and night) following the timeframes in regulation during representative operation. The following must be reported and the SEU excel sheet can be used: All measured noise levels; Calculated average per point and per period; Date of measurements; Noise levels on site boundary or unit battery limit; Used measurement equipment; Comparison with the Oman regulation. Radioactivity The following is reported and only when applicable: Identification of the qualified radiation protection officer; Any over-exposure incident or near over-exposure incident; Any relocation (temporary or permanent) of sources in process equipment (typical level sensors); Scrap metal radio active check gate: number of checks and number of pass and non-pass results. Note: non-pass results require immediate informing the authorities (SEU, Port Authority); Calibration details. Climate Reporting requirements for Climate Affairs are described in detail in Form No 2 issued by DG Climate Affairs. 4: Identifying and reporting exceedance Exceedance of a standard and non-compliance are two different events. There are several mechanisms that cover the difference like a waiver condition, insignificance with respect to environmental risks or an agreement with CA. An incidental spike that results in standard exceedance will in general not be considered as a non-compliance. Structural exceedance will obviously result in non-compliance. This also REP LS Guidance Note Environmental Performance Reporting page 10 of 11

11 depends on the average period of the applicable maximum emission level. Most BAT emission levels are daily averages, but in few processes others periods are used, like monthly or hourly. For continuous monitoring results or other data in time series, the exceedance of a standard can be registered as number of exceedance or as time fraction exceedance. In the example: standard 95 is exceeded 1 time, standard 85 is exceeded 2 times and 10% of the reporting period. Grafiektitel Data averaging must be based on the standard (e.g. yearly average, 24h average, 8 hour average as per USEPA ambient air quality standards). So this depends on the specific process In the absence of a defined averaging period, a good practice representation is expected. A non-compliance can be based on Article (10) of RD114/2001 concerning the use of state-ofthe-art techniques (Best Available Techniques as per IPPC as described in the applicable BREF) and Article (7) of RD114/2001 concerning polluting the environment in general. In one-off situations (e.g. discharge of hydrotesting water) exceedance of the discharge standard is directly a non-compliance. Ambient quality parameters (ambient air quality and marine quality) that are not directly attributable to a specific company will not lead to non-compliance but will give a more general concern. Additional information is provided in the IPPC Reference Document on the General Principles of Monitoring ( REP LS Guidance Note Environmental Performance Reporting page 11 of 11