Reporting to the EPRTR in the
UK
Alex Hole
Assessment & Reporting Advisor
Overview
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EPRTR reporting in the UK
Reporting from PPC activities
Reporting from non-PPC activities
Discussion
The United Kingdom
(UK)
EPRTR reporting in the UK
England & Wales
 PPC (part A) - Environment Agency (EA)
 PPC (part B) - Local Authorities
 Non-PPC activities – Environment Agency (EA)
Scotland/Northern Ireland
 Scottish Environmental Protection Agency (SEPA)
 Northern Ireland Environment & Heritage Service (NIEHS)
 Local Authorities
UK
 Offshore Oil & Gas – BERR
 Diffuse releases (air only) – NAEI (AEA on behalf of Defra
EPRTR reporting in the UK 2
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The EA and SEPA both make their PRTR data
available electronically through their websites
NAEI data available on the web
Compilation of the UK return
 Defra are responsible for ensuring that the UK
complies with the EPRTR regulation
 The EA will compile the data for the UK for
submission to the EU
 A new UKPRTR website will be launched later this
year
EPRTR reporting to EA - PPC
PPC (Part A) sites that we regulate
• Required to report using a Regulation 28 information
notice under the PPC regulations – see pack
• Required to report to our Pollution Inventory which is
more extensive than the EPRTR
• more substances
• lower thresholds
• required to report ‘brt’ releases
• more detailed reporting of waste transfers
• Required to report by 28th Feb of the year following
that which releases relate to
EPRTR reporting to EA
– non PPC activities
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Required to report using a Regulation 28 information
notice under the PPC regulations
Give us power to enforce the requirements even
though operators are required by regulation to
provide information
Report against EPRTR list only
Report by end of April of following year (will move to
Feb)
EPRTR reporting to EA – How do
they do it?
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Complete a paper form – see handouts
Electronic copies available on website to
download
Form sent to all non PPC operators along with
notice – 1st year only
Report using electronic system (not available for
non-PPC in 1st year) – see tomorrow
New PPC activities
– Intensive Agriculture
Key issues and problems
 How to calculate
emissions
 Security issues over
farm locations
 Ensuring notice
reached appropriate
person for completion
New PPC activities
Intensive Agriculture - emissions
Calculation of emissions
 Several sets of emissions factors
available
 Farmers unions involved in
choosing emissions factors
 Disagreement over which factors
to use
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Used a combination of Corinair emissions factors plus
those used on H1
Our IA colleagues involved in discussions
Likely to change next year to ensure all factors used for
IA are consistent across the EA
New PPC activities
Intensive Agriculture – Concerns 1
Concern by Industry that information
submitted to PRTR would be used to
alter permit conditions – assured
them that this is not the case
 Concerns over complexity of form –
separate form has not been provided
as we would be deciding for them
which substances to report
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Guidance note issued to say how to calculate emissions
and how to complete form – again some complaints that
it is too complicated – see pack for copy
New PPC activities
Intensive Agriculture – Concerns 2
Concern by Industry that publication
of names and addresses on web
could lead to security breaches
 Same procedure used to asses
claims for confidentiality as per PPC
application process
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Government Minister for Agriculture confirmed that
names and addresses would have to be published to
allow the UK to comply with EPRTR requirements
Details used on PPC applications used to contact all
farms - although because some sites are run on behalf
of a big company – issues as to who completed form
QA of PPC activities data
Several levels of QA are carried out following the
submissions of data to us
1. Electronic reporting system raises ‘check flags’
where data is significantly different from previous
years reporting or to the threshold
2. Site inspector checks return to see if return is
consistent with their knowledge of site and permit
conditions – see checklist in pack
3. Regional QA – use database tool to look for
‘outliers’ – see tomorrow
4. National QA – check trends to and totals to find any
erroneous data
QA of PPC activities data
Online
validation
Inspector
verification
Entry level
validation
checks.
Operator cannot
submit data that
does not pass
validation
Operator notified to submit (or resubmit) data
Operator submits (or re-submits) data
using electronic data capture
Site Inspector:
Is operator data
acceptable?
NO
Inspector must
agree there is
an issue before
going back to
operator
YES
NO
Quality
validation
Quality Manager:
Is operator data
comparable?
YES
Public
validation
Publish data on website
Non PPC activities
Mines & Quarries 1
Key issues/problems
• Identifying sites
• Interpreting 25Ha requirement
• How to calculate emissions
• How to QA data
Non PPC activities
Mines & Quarries 2
Identifying Sites
• Defra consultation sent to mining and quarrying
trade association to inform them of new requirement
• Used list from BGS – all active mines and quarries
in England and Wales
• List found not to be very accurate
• Decision taken that we will not chase up those that
do not respond – we have gone to our best efforts to
identify them
Mines & Quarries 3
Problems
• Landfills often operate in quarries and this activity is
regulated by us under PPC
• Crushing activity generally regulated by Local
Authority
• Requires double checking with some operators to
make sure they do not report twice
• Most mines and quarries have been <25Ha, but
need to refer the operator to the definition in the
regulation
Mines & Quarries 4
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Most mines and quarries have been
<25Ha, but need to refer the operator
to the definition in the regulation
Onus on them to ensure that they
report as appropriate
Opencast mining and quarrying – where the surface area
effectively under extractive operation equals 25
hectares.
“Surface of the area effectively under extractive operation”
means the surface of the area of the site reduced by the
surface of the rehabilitated area and reduced by the
area of future excavation.
Mines & Quarries 5
Guidance
• Very generic guidance provided for operators – see
pack
• No funding or time for us to develop guidance with
methods for calculation
• Anticipating very few sites to report any values that are
above threshold
• Used indicative sector specific list for EPRTR guidance
document
• No local site knowledge so data will be QAd nationally
– likely to compare data between sites, and with other
sectors. No methodology prepared yet
Non PPC activities
IOWWTWs - 1
Key issues/problems
• Identifying sites
• What is a treatments works?
• Which pollutants?
• QA of data
Non PPC activities
IOWWTWs - 2
Identifying sites
• Used lists of discharge consents
• Issued S28 notices as per other sectors
• Likely to be only 10 or so sites reporting
• Most have/are part of PPC permits
What is a treatments works?
• Site must have some chemical/biological treatment
• Water extracted for cooling at Power Stations does
not counts as treatment (filtering for debris only)
Non PPC activities
IOWWTWs - 3
Which pollutants?
• Due to limited time/budget and number of sites – no
guidance has been issued
• All sites have discharge consents which have limits
set on how much of a substance can be released to
the environment. Loads can be worked out as a
proportion of this limit
QA of data
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Likely that data will be QAd nationally – likely to compare
data between sites, and with other sectors. No
methodology prepared yet
Website
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Contains copies of the Forms (word and pdf)
Link to electronic reporting system (PIEDC)
Copies of generic guidance note
Copies of reporting codes document
Copies of sector specific guidance notes
Details of how to contact us with enquiries
http://www.environment-agency.gov.uk/pi
Discussion / Questions
Reporting of Waste
Overview
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EPRTR requirements
How we do it in England and Wales
Problems/difficulties
Reporting of Off site waste transfers
EPRTR requirements
• Process related waste going off site for Disposal or
Recovery
• Require separate reporting of hazardous and nonhazardous waste
• Thresholds are:
• Hazardous waste 2 tonnes
• Non- hazardous waste 2000 tonnes
• If total sent off site is above threshold then all waste
need to be reported
Reporting of Off site waste transfers
How we do it in England and Wales
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Require sites to report waste according to Waste
type (EWC code) and WFD D or R code
Reporting threshold for PPC sites are:
• Hazardous waste: 0 tonnes
• Non-hazardous waste: 5 tonnes
Reporting threshold for non PPC sites are as per the
EPRTR regulation
Lists of EWC and D&R codes in PI reporting codes
document – see pack
Off site waste continued
Key issues/problems
• Sludge – Agricultural sludge that is spread on land
for the benefit of agriculture needs to be reported in
the waste section
• Other Farm waste e.g. dead animals. Some
confusion as to whether to report D/R as ultimate
fate is often fertiliser or land spreading
• Non-process related waste does not need to be
reported (e.g. municipal office waste, demolition
waste)
Overseas waste transfers
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Operators need to report who they are sending the
waste to, and what it’s final destination is
In the UK it is illegal to send waste overseas for
disposal – so we are only expecting waste sent for
recovery to be reported
Where the waste is taken overseas by a waste
carrier, the producer of the waste needs to report it’s
final destination
If the waste is sent to a waste management facility,
and is sorted and then snet overseas. The waste
management facility must report the overseas waste
transfer
Guidance & tools 1
All available to download from website
• General guidance
• Reporting codes document
• Sector specific guidance for existing PPC sectors
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Waste oil estimator
Landfill leachate estimator
Landfill Gas emissions
estimator (Gassim)
Municipal waste water
treatment works estimator
tool
Combustion activities
Petroleum activities
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Food & Drink
Cement & Lime
Chemicals
Incineration
Metals (ferrous & nonferrous)
Paper & Pulp
Intensive agriculture
Guidance & tools 2
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Guidance and tools developed in collaboration with
industry and other regulators
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Sector specific guidance for new EPRTR activities –
sent with notice and on website
• Mining and quarrying
www.environment-agency.gov.uk/pi
Lessons learnt
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Try to liaise with trade associations, industry
representatives and policy experts in your
organisation when writing guidance and
communicating with industry
Provide guidance and tools so it is clear what is
expected
Use electronic data capture to increase accuracy at
data entry stage (and reduce administrative burden)
Questions/discussion
Alex Hole
Assessment & Reporting Advisor
alex.hole@environment-agency.gov.uk
0044 117 914 2622