Hellenic Ministry for the Environment, Spatial Planning and Public Works

TRAINING WORKSHOP- IMPLEMENTATION OF THE IPPC DIRECTIVE BANSΚΆ –BYSTRICA-12-03-2004-SLOVAK REPUBLIC

EPER REPORTING 2003-THE GREEK CASE

Greek Experience on the Implementation Greek Experience on the Implementation of EPER REPORTING IN GREECEof EPER REPORTING IN GREECE

Η ΕΛΛΗΝΙΚΗ ΕΜΠΕΙΡΙΑ ΣΤΗΝ ΕΦΑΡΜΟΓΗ ΤΟΥ Η ΕΛΛΗΝΙΚΗ ΕΜΠΕΙΡΙΑ ΣΤΗΝ ΕΦΑΡΜΟΓΗ ΤΟΥ EPEREPER

ALEXANDROS KARAVANASALEXANDROS KARAVANAS - -Chemical EngineerChemical Engineer

Hellenic Ministry for the Environment, Spatial Planning and Public Works

TRAINING WORKSHOP- IMPLEMENTATION OF THE IPPC DIRECTIVE BANSΚΆ –BYSTRICA-12-03-2004-SLOVAK REPUBLIC

EPER REPORTING 2003-THE GREEK CASE

1. According to the DECISION 2000/479 Member States shall report to the Commission on 1. According to the DECISION 2000/479 Member States shall report to the Commission on emissions from all individual facilities with one or more activities as mentioned in Annex I of emissions from all individual facilities with one or more activities as mentioned in Annex I of Directive 96/61/EC.Directive 96/61/EC.

The report must include the emissions to air and water for all pollutants for which the threshold The report must include the emissions to air and water for all pollutants for which the threshold values are exceeded; both pollutants and threshold values are specified in Annex A1.values are exceeded; both pollutants and threshold values are specified in Annex A1.

What is the EPER

Hellenic Ministry for the Environment, Spatial Planning and Public Works

TRAINING WORKSHOP- IMPLEMENTATION OF THE IPPC DIRECTIVE BANSΚΆ –BYSTRICA-12-03-2004-SLOVAK REPUBLIC

EPER REPORTING 2003-THE GREEK CASE

1.1. Member States shall report to the Commission every three years.Member States shall report to the Commission every three years.2003-2006.2003-2006.

2.2. The successor of EPER from 2007 and onwards is the EUROPEAN The successor of EPER from 2007 and onwards is the EUROPEAN POLLUTION AND TRANSFER REGISTER E-PRTR.POLLUTION AND TRANSFER REGISTER E-PRTR.

3.3. ““Guidance Document for EPER implementation”Guidance Document for EPER implementation”

4.4. Member States shall provide all reported data by electronic data transfer.Member States shall provide all reported data by electronic data transfer.

5.5. The Commission assisted by the European Environment Agency will make the The Commission assisted by the European Environment Agency will make the reported data publicly accessible by dissemination on the Internet.reported data publicly accessible by dissemination on the Internet.

What is the EPER

Hellenic Ministry for the Environment, Spatial Planning and Public Works

TRAINING WORKSHOP- IMPLEMENTATION OF THE IPPC DIRECTIVE BANSΚΆ –BYSTRICA-12-03-2004-SLOVAK REPUBLIC

EPER REPORTING 2003-THE GREEK CASE

GUIDANCE DOC. (1)

IDENTIFICATIONIDENTIFICATION of FACILITY of FACILITY

1.Identify each facility with Annex I activities1.Identify each facility with Annex I activities 2.Select for the facility the NACE code, source 2.Select for the facility the NACE code, source

categories and corresponding NOSE-P codescategories and corresponding NOSE-P codes 3.Select the main activity and its NOSE-P code3.Select the main activity and its NOSE-P code 4.Report the facility if at least the emission of one 4.Report the facility if at least the emission of one

pollutant exceeds the threshold valuepollutant exceeds the threshold value

Hellenic Ministry for the Environment, Spatial Planning and Public Works

TRAINING WORKSHOP- IMPLEMENTATION OF THE IPPC DIRECTIVE BANSΚΆ –BYSTRICA-12-03-2004-SLOVAK REPUBLIC

EPER REPORTING 2003-THE GREEK CASE

GUIDANCE DOC. (2)

EMISSION DETERMINATIONEMISSION DETERMINATION 1.Select all pollutants released from the Annex I 1.Select all pollutants released from the Annex I

activities (by use of sector-specific sub-lists)activities (by use of sector-specific sub-lists) 2.The emissions include all facility releases, but non-2.The emissions include all facility releases, but non-

Annex I releases can be excludedAnnex I releases can be excluded 3.3. Report the emission data for all pollutants Report the emission data for all pollutants

exceeding the threshold values as releases to air, exceeding the threshold values as releases to air, direct and/or indirect releases to waterdirect and/or indirect releases to water

4.4. Report each of the emission data (in kg/year) Report each of the emission data (in kg/year) with its determination method (M, C, E)with its determination method (M, C, E)

Hellenic Ministry for the Environment, Spatial Planning and Public Works

TRAINING WORKSHOP- IMPLEMENTATION OF THE IPPC DIRECTIVE BANSΚΆ –BYSTRICA-12-03-2004-SLOVAK REPUBLIC

EPER REPORTING 2003-THE GREEK CASE

GUIDANCE DOC. (3)

INDIVIDUAL REPORTINGINDIVIDUAL REPORTING

1. Report for each facility individually according to the 1. Report for each facility individually according to the (electronic) format of Annex A2(electronic) format of Annex A2

2.2. Specify the main Annex I activity and corresponding Specify the main Annex I activity and corresponding NOSE-P codeNOSE-P code

3.3. Report the emission data for the facility as totals for Report the emission data for the facility as totals for all pollutants exceeding the threshold values of all pollutants exceeding the threshold values of Annex A1Annex A1

Hellenic Ministry for the Environment, Spatial Planning and Public Works

TRAINING WORKSHOP- IMPLEMENTATION OF THE IPPC DIRECTIVE BANSΚΆ –BYSTRICA-12-03-2004-SLOVAK REPUBLIC

EPER REPORTING 2003-THE GREEK CASE

GUIDANCE DOC. (4)

AGGREGATED REPORTINGAGGREGATED REPORTING

1. Specify the source categories according to Annex 1. Specify the source categories according to Annex A3 and select the NOSE-P codesA3 and select the NOSE-P codes

2. Sum all individually reported emission data for 2. Sum all individually reported emission data for identical main Annex I activities and also for identical main Annex I activities and also for identical main NOSE-P codesidentical main NOSE-P codes

3.3. Report the national emission totals for all pollutants Report the national emission totals for all pollutants by source category as aggregated by Annex A3 by source category as aggregated by Annex A3 category and NOSE-P codecategory and NOSE-P code

Hellenic Ministry for the Environment, Spatial Planning and Public Works

TRAINING WORKSHOP- IMPLEMENTATION OF THE IPPC DIRECTIVE BANSΚΆ –BYSTRICA-12-03-2004-SLOVAK REPUBLIC

EPER REPORTING 2003-THE GREEK CASE

IMPLEMENTATION

The EPER Decision legally implemented in GreeceThe EPER Decision legally implemented in Greece

Type of legislation : Ministerial Decision and Note Type of legislation : Ministerial Decision and Note by the General Secretary of the Ministry for the by the General Secretary of the Ministry for the Environment.Environment.

a) Ministerial Decision KYA 11014/703 /F 104/2003, article a) Ministerial Decision KYA 11014/703 /F 104/2003, article 12.3.i.”Environmental appraisal ,Evaluation and permitting 12.3.i.”Environmental appraisal ,Evaluation and permitting procedure.Environmental Conditions Decision contents.”.procedure.Environmental Conditions Decision contents.”.

b) Note by the General Secretary 117266 /27-5-2003, Implementation of the b) Note by the General Secretary 117266 /27-5-2003, Implementation of the provisions of article 12 .3 of provisions of article 12 .3 of τηςτης KYA 11014/703 /F 104/2003 regarding the KYA 11014/703 /F 104/2003 regarding the obligation of sending information to the responsible authorities for releases obligation of sending information to the responsible authorities for releases (emission and wastes).(emission and wastes).

Hellenic Ministry for the Environment, Spatial Planning and Public Works

TRAINING WORKSHOP- IMPLEMENTATION OF THE IPPC DIRECTIVE BANSΚΆ –BYSTRICA-12-03-2004-SLOVAK REPUBLIC

EPER REPORTING 2003-THE GREEK CASE

Data Collection

Identification of IPPC facilities from Environmental Identification of IPPC facilities from Environmental PermitsPermits

Pathway of EPER data collectionPathway of EPER data collection was directly from was directly from facilities to the Ministry for the Environment.facilities to the Ministry for the Environment.

BetweenBetween 7./.2003.and7./.2003.and 11./2003., on paper and 11./2003., on paper and partially by e mail.partially by e mail.

The checking of the data the correction validation The checking of the data the correction validation and all the necessary procedures was made by the and all the necessary procedures was made by the Chemical Engineer’s Scientific and Educational Chemical Engineer’s Scientific and Educational Centre under a contract with the Ministry for the Centre under a contract with the Ministry for the Environment).Environment).

Hellenic Ministry for the Environment, Spatial Planning and Public Works

TRAINING WORKSHOP- IMPLEMENTATION OF THE IPPC DIRECTIVE BANSΚΆ –BYSTRICA-12-03-2004-SLOVAK REPUBLIC

EPER REPORTING 2003-THE GREEK CASE

PROCEDURE-ΔΙΑΔΙΚΑΣΙΑ(1)

The approach we have taken relied heavily on The approach we have taken relied heavily on submission of data by the sites themselvessubmission of data by the sites themselves..

existing environmental condition permits data existing environmental condition permits data and previous data and previous data compilations compilations to identify to identify potential IPPC facilities.potential IPPC facilities.

Out of an initial database of 556 potential IPPC Out of an initial database of 556 potential IPPC sites, (321 ) were identified finally as IPPC sites, (321 ) were identified finally as IPPC facilities. (at the moment)facilities. (at the moment)

82 82 reported.reported.

Hellenic Ministry for the Environment, Spatial Planning and Public Works

TRAINING WORKSHOP- IMPLEMENTATION OF THE IPPC DIRECTIVE BANSΚΆ –BYSTRICA-12-03-2004-SLOVAK REPUBLIC

EPER REPORTING 2003-THE GREEK CASE

PROCEDURE-ΔΙΑΔΙΚΑΣΙΑ(2)

The report has been assembled according to the The report has been assembled according to the specific rules set out in the “Guidance Document specific rules set out in the “Guidance Document for EPER Implementation”. for EPER Implementation”.

The Guidance Document DOES NOT REFER The Guidance Document DOES NOT REFER TO METHODOLOGY OF REPORTING FROM TO METHODOLOGY OF REPORTING FROM FACILITIES TO AUTHORITIES FACILITIES TO AUTHORITIES

However, certain Annex I Activities have been However, certain Annex I Activities have been deliberately omitted from the report.deliberately omitted from the report.

Hellenic Ministry for the Environment, Spatial Planning and Public Works

TRAINING WORKSHOP- IMPLEMENTATION OF THE IPPC DIRECTIVE BANSΚΆ –BYSTRICA-12-03-2004-SLOVAK REPUBLIC

EPER REPORTING 2003-THE GREEK CASE

Procedure (3) . Checking the data submitted

PermitsPermits InterviewsInterviews Federations-UnionsFederations-Unions Additional data and detailsAdditional data and details

Hellenic Ministry for the Environment, Spatial Planning and Public Works

TRAINING WORKSHOP- IMPLEMENTATION OF THE IPPC DIRECTIVE BANSΚΆ –BYSTRICA-12-03-2004-SLOVAK REPUBLIC

EPER REPORTING 2003-THE GREEK CASE

PROCEDURE(4). Verification , completion of the data

Completion with calculations using emission factors Completion with calculations using emission factors and permit data.and permit data.

Comparison of the data submitted with Comparison of the data submitted with determination using calculation with approved determination using calculation with approved emission factors.emission factors.

CORINAIR-IPCC, BREF CORINAIR-IPCC, BREF Notice to all the facilities for any objection on the Notice to all the facilities for any objection on the

corrections and acceptance of the data.corrections and acceptance of the data. Notice to the 82 reported facilities for their reported Notice to the 82 reported facilities for their reported

emissions to the Commission. emissions to the Commission.

Hellenic Ministry for the Environment, Spatial Planning and Public Works

TRAINING WORKSHOP- IMPLEMENTATION OF THE IPPC DIRECTIVE BANSΚΆ –BYSTRICA-12-03-2004-SLOVAK REPUBLIC

EPER REPORTING 2003-THE GREEK CASE

PROCEDURE(5). VALIDATION - REPORTS

We use We use Commission’s toolsCommission’s tools The contractor in contact with CDRThe contractor in contact with CDR Final reportsFinal reports Reports to the Reports to the ComissionComission Uploading to CDRUploading to CDR EPER EPER SITESITE Future CorrectionsFuture Corrections

Hellenic Ministry for the Environment, Spatial Planning and Public Works

TRAINING WORKSHOP- IMPLEMENTATION OF THE IPPC DIRECTIVE BANSΚΆ –BYSTRICA-12-03-2004-SLOVAK REPUBLIC

EPER REPORTING 2003-THE GREEK CASE

PROCEDURE(6). Database of the results

Excel Data base Excel Data base Update of our existing Access data Update of our existing Access data

base with the resultsbase with the results

Hellenic Ministry for the Environment, Spatial Planning and Public Works

TRAINING WORKSHOP- IMPLEMENTATION OF THE IPPC DIRECTIVE BANSΚΆ –BYSTRICA-12-03-2004-SLOVAK REPUBLIC

EPER REPORTING 2003-THE GREEK CASE

Main Problems and findings(1)

Often usage of the results for other purposesOften usage of the results for other purposes The determination of the releases. Lack of The determination of the releases. Lack of

Knowledge.Knowledge. The contractor very often (more than 70% ) The contractor very often (more than 70% )

had to contact the facility operators in order had to contact the facility operators in order to clarify missing data or other detailsto clarify missing data or other details

Hellenic Ministry for the Environment, Spatial Planning and Public Works

TRAINING WORKSHOP- IMPLEMENTATION OF THE IPPC DIRECTIVE BANSΚΆ –BYSTRICA-12-03-2004-SLOVAK REPUBLIC

EPER REPORTING 2003-THE GREEK CASE

Main Problems and findings(2)

Time enough for the preparation and Time enough for the preparation and compilationcompilation

Way of the submission of the dataWay of the submission of the data Lack of InformationLack of Information Training of the responsibles of the reporting Training of the responsibles of the reporting

facilities facilities

Hellenic Ministry for the Environment, Spatial Planning and Public Works

TRAINING WORKSHOP- IMPLEMENTATION OF THE IPPC DIRECTIVE BANSΚΆ –BYSTRICA-12-03-2004-SLOVAK REPUBLIC

EPER REPORTING 2003-THE GREEK CASE

Main Problems and findings(3)

Poultry and swine intensive farmingPoultry and swine intensive farming

a very large number of small, personal and family businesses with a very large number of small, personal and family businesses with limited resources , for the most of them , to provide elaborate data at limited resources , for the most of them , to provide elaborate data at request. and moreover, we have found that the IPPC capacity threshold request. and moreover, we have found that the IPPC capacity threshold for these sectors is far lower than justified by the quantities of for these sectors is far lower than justified by the quantities of pollutants actually emittedpollutants actually emitted

Landfill sitesLandfill sites

Most of the landfill sites now operating, were only at development Most of the landfill sites now operating, were only at development stage or less in year 2002. Therefore, pollutant data for the sector stage or less in year 2002. Therefore, pollutant data for the sector would be non-representative and best not reported.would be non-representative and best not reported.

Hellenic Ministry for the Environment, Spatial Planning and Public Works

TRAINING WORKSHOP- IMPLEMENTATION OF THE IPPC DIRECTIVE BANSΚΆ –BYSTRICA-12-03-2004-SLOVAK REPUBLIC

EPER REPORTING 2003-THE GREEK CASE

FUTURE ACTIONS for 2004

Correction of the submitted dataCorrection of the submitted data Reexamine and completion of the IPPC facilities list for the next Reexamine and completion of the IPPC facilities list for the next

Reporting. New thresholds.Reporting. New thresholds. Methodology and Tools for the Reporting from facilities to the Methodology and Tools for the Reporting from facilities to the

AuthorityAuthority Methodology for assessing the quality of the dataMethodology for assessing the quality of the data Better Information and Collaboration Better Information and Collaboration

Hellenic Ministry for the Environment, Spatial Planning and Public Works

TRAINING WORKSHOP- IMPLEMENTATION OF THE IPPC DIRECTIVE BANSΚΆ –BYSTRICA-12-03-2004-SLOVAK REPUBLIC

EPER REPORTING 2003-THE GREEK CASE

FUTURE ACTIONS for 2004 (2)

Development of an electronic system including the Development of an electronic system including the monitoring of the permits an the eper emissionsmonitoring of the permits an the eper emissions

Starting Preparation for the E-PRTR obligationsStarting Preparation for the E-PRTR obligations ( ( 86 pollutants,56 activities, annual reporting, 86 pollutants,56 activities, annual reporting,

releases to land, off-site transfers of waste,diffuse releases to land, off-site transfers of waste,diffuse sources(voluntarily),public participation in decision sources(voluntarily),public participation in decision

makingmaking). New Regulation.). New Regulation.