Reasons to be fearful: IPPC
Joel Priest, business advisor at Synergetic Business Solutions, discusses the unresolved issues surrounding the metalfinishing industry's IPPC permitting.
Many of the topics addressed separately in this issue of IEM can also be viewed as elements of one subject: Integrated Pollution Prevention and Control (IPPC).
Introduced in the UK in 2000 to replace the previous permitting regime of Integrated Pollution Control, much of the metalfinishing sector will be new to this form of industrial process regulation. In addition to activities relating to the production of ferrous and non-ferrous metals, the Pollution Prevention and Control Regulations 2000 introduce a new section regarding ‘Surface Treating Metals and Plastic Materials’. Businesses carrying out electroplating and other such activities will need to apply for a permit to operate in 2004 (see Table 1).
Despite the relative proximity of the application period, there are several unresolved issues. Firstly, guidance on what are considered the Best Available Techniques (BAT) to avoid or reduce harmful emissions is yet to be published. In August of this year, the European IPPC Bureau issued a first consultation draft of the BAT Reference Note (or ‘BREF’) for surface treatment activities. In turn, the Environment Agency hopes to have a draft UK version of the guidance document (the main source of information for preparing an IPPC application) in October 2003.
From an industrial point of view, the main cause for concern is the threshold of production vats, set at 30m3. Businesses below this will escape being regulated as a Part A1 or A2 installation (though emissions to air may be regulated by the local authority under Part B – (see Table 1), while those exceeding the threshold will be faced with high costs. Estimates of the cost of preparing and submitting the application range from £8.5-35k, with between £6-7k of this forming the Environment Agency’s application fee. The thresholds are currently under review by the European Commission, but it is unclear at present how this review will affect the 30m3 threshold for surface treatment operations – whether it will be reduced, increased, or changed altogether (e.g. to a ‘single tank’ threshold rather than aggregate production capacity).
With the application period looming, metalfinishing businesses should be aware of their possible obligations under IPPC. Previous experience with other sectors has shown that IPPC applications are often more costly and time-consuming than the applicants first thought. Synergetic Business Solutions aims to reduce such delays by using a structured IPPC tool, which ensures that all necessary elements of BAT are addressed within the application, helping to ensure that the application is deemed ‘duly made’ on first submission to the regulator. We are also able to keep costs to a minimum by using a one-stop shop of specialists to complete elements such as energy, water and waste audits, noise and vibration assessment, dispersion modelling of emissions and the site condition report.
One element of an IPPC application is the management systems that are in place to prevent or reduce harmful emissions. Irrespective of whether your business will be regulated under IPPC, one key tool for managing its environmental impacts is an environmental management system, or EMS.
Managing your operations with a view to reducing adverse environmental impacts and continually improving your environmental performance can bring dividends: improved controls over releases to the atmosphere, sewer or surface waters; cost savings resulting from materials substitution, waste minimisation or energy efficiency measures; and ensuring legal compliance to name but a few.
In fact, there are many motives for implementing an EMS. It may be an element of the ‘improvement plan’ that forms part of a company’s obligations under IPPC and reduce IPPC application and subsistence costs. It may stem from a desire to improve operating efficiency and realise cost savings. One Sheffield-based firm specialising in the heat treatment and shotblasting of steel has implemented ISO 14001, the international environmental management system standard, in order to facilitate trade with US-based customers – an example of pressure from ‘upstream’ in the supply chain. A different approach has been taken by a West Midlands electroplating firm, who is moving towards ISO 14001, from a desire to be seen as a responsible, environmentally aware operation. It hopes to be better-placed to win contracts and to reduce the risk of enforcement visits from the Environment Agency and local authority inspectors.
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