Capacity Building in Implementation of the Environmental Acquis at the General training programme Local and Regional Level This Project is funded by the IPPC EU

26 April 2004

Our ref: 80.4184.01

EU Ref: EUROPEAID/116215/C/SV/PHA

To : Country Teams of IPPC Experts

From : Vibeke Burchard

Copy to : Project web

Introduction The objective of this “General Training Programme (GTP) for IPPC is to give guidance for the design of the national training programme for IPPC. The GTP is based on the training subjects and training objectives identified for IPPC.

The GTP outlined in this document should serve as basis for the design of the national training programmes. Depending on the results of the training needs assessment, some subjects may be deleted or some dealt with in more details or in more training sessions that this GTP is suggesting. The programme is meant as inspiration but all subjects should be dealt with, unless there is a specific reason not to do this (for instance that another training programme just dealt with the issue or the trainees already are experienced). The “duration” column is only meant as a suggestion. It will all depend on the needs in each region and country. It is the intention to specify further which already developed is relevant for specific sessions and also it is the intention throughout the project to develop common presentation material. Until then, consult the CD ROM with materials.

In the Procedures Manual, guidance is given to all international and national trainers concerning the national training programmes and the material gathered. Please read the guidance before this GTP. A template has also been developed – to be used for the national training programmes

1 Session 1 May – June 2004 General IPPC issues, Application and BAT

SESSION 1, DAY 1 – General IPPC issues Training Topic Methodology Time Material 1 Outputs2 Remarks Area objectives

Trainees are Do we Discussion on the main 1 Optional PPT - Flip over sheet - integrated approach updated remember objectives of the IPPC directive hour - IPPC with the main - best for the environment as IPPC? as an introduction: general vbu objectives and a whole - IPPC specific issues of - pollution prevention and directive the IPPC scheme BAT (including use of raw introduction mat, energy and water) pl waste minimisation - ELV and EQS IPPC update - monitoring - regular review of permits . transboundary pollution . prevention of accidents - closure of installation - public access to report from operator).

1 Whenever there is reference to PPT files (PowerPoint), relevant files are listed. This means that you might find relevant slides for re-use – it does not mean that the complete files can be used. This is unlikely. 2 In all cases national guidelines must be used if present 2 SESSION 1, DAY 1 – General IPPC issues cont. Training Topic Methodology Time Material 3 Outputs4 Remarks Area objectives

- Can determine Threshold Case study and other Legislation if an values of the national cases as basis for a 1 transposing the Use national examples installation is IPPC dialogue with the trainees on hour Annex 1, national falling under installation; interpretation of the threshold thresholds What is a site – when is it the IPPC rules. The SITE in the Annex 1 of the National/international two sites? (is able to specific permit Directive and interpretation of examples on interpret the a site handouts (e.g. DETR Aggregation rule of Annex I threshold and Tannery values for examples (Morten Determination of capacity Thresholds capacities set Guld) (cf. 5.3 of COM(2003) 354) in Annex 1 in Annex 1; and - understands “site” the site specific approach and knows when equipment is “technically connected” and thus part of the same site.

3 Whenever there is reference to PPT files (PowerPoint), relevant files are listed. This means that you might find relevant slides for re-use – it does not mean that the complete files can be used. This is unlikely. 4 In all cases national guidelines must be used if present 3 SESSION 1, DAY 1 Application Area Topic Training Methodology time Material Outputs Remarks objectives

Content of - Knows the Case study; 2 Real Check list for Use of EIA application requirements - discussion on the content of hours application reviewing for content of an application, producing own Legislation, completeness of Content and style of the non- an application check list or reviewing existing application application technical summary check list §§

Dialogue with - Understands Discussion; -, how has the 1 1/2 Practical procedure (Extremely important!) Applications operator before, the dialogue been in the concrete hour for dialogue with during and after importance of case, recommendations for operator in the application and a proper proper dialogue in the concrete concrete case draft permit dialogue with case written together the operator with the trainees before and (writing, meetings, during the site visits, etc) application phase (and later the permit review phase) Confidential - Is able to Presentation and discussion 1/2 §§ of act, information - determine hour examples on procedures and which material handout handling of can be Actual case if confidential deemed available information confidential and can carry out the right procedure in relevant cases

4 SESSION 1, DAY 1 Application Area Topic Training Methodology time Material Outputs Remarks objectives

Abnormal - Is able to Case study – text in the 1- 2 Sections in List of questions for (Seveso directive is not a key operation and evaluate if the application used as basis for hours the case operator (if component of this project and accidents information in discussion of the issue, other study feasible) can only be treated including the application national examples. application; - own suggestions superficially. Focus therefore obligations for is adequate Present the national legislation legal for supplement to on abnormal operating Seveso and can give transposing the Seveso requirements; the application (for conditions.) Abnormal 5installations: guidance to directive; Handouts the sake of the operation and - and threshold the operator with national exercise) accident values as to the examples. prevention - safety report adequate National - safety level of legislation management information - emergency plans

5 Control of Major Accidents Hazards 5 SESSION 1, DAY 2 Application cont. Area Topic Training objectives Methodology Time Material used Outputs Remarks

Application Closing down Is able to evaluate if the Case study; 1 hour Legislation List of questions Text in the the installation information in the requirement, for operator (if application application is adequate and national feasible) used as basis can give guidance to the examples on - own for discussion operator as to the adequate handouts suggestions for of the issue, level of information supplement to other national the application examples (for the sake of the exercise) Application Completeness Is able to check compliance Case study; checking if all issues List of additional go in depth with of application of an application with the have been addressed properly in 4 – 6 info needed the issues - are all requirements in the the actual application; hours pointed out by issued legislation the trainees as covered? the difficult part

6 SESSION 1, DAY 3 Best Available Technique Area Topic Training objectives Methodology time Material Outputs Remarks

- What is BAT Can define BAT and can Detailed discussion and Minimum - Slides and handout (Cf. 5.1 and 5.2 - departures determine BAT for a interpretation 1 – 1 1/2 with definition from of from BAT; specific installation taking hour national legislation; COM(2003) 354) - EQS and BAT into account local condition Presentation, re-capitulating what - handouts with “what - new and and EQS is BAT to take into existing consideration”, installation - BAT and EQS etc. - Handout with Concept interpretations from of BAT e.g. UK General Sector Guideline (IPPC SO.01) p. 1.2 and 5) PPT: - BAT united_uk The BREFs Can find information in Presentation of objective of the 1 - 2 - List of content of BREFs relevant for a BREFs hours selected BREFs, How BREFs are specific case, knows the including the trans developed, how objective of the BREFS, sectorial ones to use them, knows which BREFs are - Executive summaries their content and available, their structure of relevant BREFs in structure and how to use them national language Trainees use the BREFS (different in each country) - at least 1 complete BREFs brought BREF in two copies (if by the trainer, possible it should be get familiar with the one relevant for the the structure case) (basically the same structure in all)

7 SESSION 1, DAY 3 BAT cont. Area Topic Training objectives Methodology Time Material Outputs Remarks

- Where to find Is able to find information Exercise on internet, 2 hours VBU overview of - List of Use computers with BREFs and on BAT when no BREF is Exercise 1: find BAT sources, relevant BAT access to internet other BAT info; available, familiar with the relevant BAT internet; exercise documents - what to do good BAT web sites, information for this or descriptions and links TWG members on BAT when there is another application - List of BAT EIPPCB site Sources no BREF relevant for the sources trainees, make where favourites, print out information relevant pages, list of can be found contents etc. Exercise 2: trans sectorial issue (e.g.: where to find information on BAT for treatment of oily waste water) - Evaluation of Is able to evaluate the Case study; 2 - 6 Case study - Note with non Discuss the BAT; information in the hours application; handout compliance operator’s - Best for the application related to BAT, with relevant §§ on issues not information and the environment as is able to set up table of “Best for the addressed by compliance with a whole concordance environment as a the operator: BAT, his Evaluation (comparison table) whole - BAT compliance of BAT PPT: evaluation - schedule (non IPPC BAT comparison compliance list/time assessment (pick table table for and choose) (application improvement). versus BAT) Write BAT evaluation table (list of comparison between BAT and the application)

8 Session 2 Sep /Oct 2004 Permits and permit conditions

SESSION 2, DAY 1 Permit and permit conditions Area Topic Training objective Methodology Time Material Outputs Remarks Content of permit Discussion with 1/2 - 1 hour Legislation, national Permit trainees on the content templates. of the permit, common PPT: understanding - Permit.ppt - - Setting conditions in Is able to elaborate an Presentation of 2 hours Handouts from Examples of Discuss Permit general, integrated permit with objective of conditions, presentation on conditions of different types - enforcement rules and conditions that are enforcement and how conditions (objective, different type of conditions procedures precise, unequivocal, to formulate conditions how to formulate (figures, mg/h; and enforceable, – (precise, unequivocal mg/Nm3, and enforceable); kg/produced Examples. unit, tonnes/y, Hands out: National construction, enforcement rules and BAT, operation, procedures abnormal operating conditions, monitoring, no prescription of specific BAT in permit etc. Case study group work Setting conditions on Is able to critically Discussion on 1 - 3 hours - List of dangerous List of needed Optional: Permit use of resources, evaluate the use of necessary and optional substances, danger and optional Presentation - raw materials, energy resources as applied for conditions. classes, - conditions on and water usage incl. by the operator and is - EU list of priority conditions for “dangerous saving measures able to set conditions substances; case study substances; - substitution following the “pollution - List I and II in WFD or - What is it and - reduction programmes prevention principle” – 76/464 how to - investigations and phasing out the use of - Danish list of evaluate if a reporting the result of dangerous substances “unwanted substance is the investigation on and reducing to the substances” dangerous? substitution extent possible - WFD - where to find - EU and priority list of priority_haz_substanc information substances; es.pdf 9 SESSION 2, DAY 1 Permit and permit conditions Area Topic Training objective Methodology Time Material Outputs Remarks - List of dangerous substances

10 SESSION 2, DAY 1 Permit and permit conditions cont. Area Topic Training objective Methodology Time Material Outputs Remarks General issues for Is able to decide (design Present requirements from - handout with Example including Permit setting ELV; conditions) on the emission national legislation and the 2 hours presentation on from case - different types of limit values; regulations which have ELV; general ELV study on ELVs Is able to set “equivalent Discussion on possibilities in issues “equivalent - stepwise parameters” and “technical the country (which - List of relevant parameters” improvement if measures” in stead of room/possibilities do I have national legislation relevant at emission limit values when according to the legislation) with limit values, existing feasible; - National permits. installations; Is able to take local and - Use of geographical conditions into “equivalent consideration when parameters” and deciding the ELVs; “technical Knows how to deal with measures” in “better than BAT” if so stead of limit required in order to fulfil values local norms - art. 10; - Taking local conditions into consideration; EQS and ELV - Annex III – ELVs for which pollutants? (“significant quantities”); - National limit values, BAT and permit limit values - If applicable: the use of general binding rules – how to ensure that EQS are respected

11 SESSION 2, DAY 2 – Permit and permit conditions Area Topic Training objective Methodology Time Material Outputs Remarks Requirements from Has an overview of Discussion on requirements 1/2 - 1 - National Own list of Permit other directives (read: all relevant legislation from other pieces of legislation hour + legislation relevant other pieces of national and is aware of the which it is necessary to take home transposing legislation to legislation) - Annex II need to consult this into account. work directives on take into of the directive + VOC, legislation as relevant VOC, LCP, account Landfill Dangerous substances, Landfill and others?, sector laws (water, waste, air) - Extract from VBU summary on requirements in other directives PPT: - Other directives.zip Conditions in the permit Is able to put together Evaluation of case study 2 – 3 -Application Conditions Could be stepwise Permit related to compliance and negotiate the compliance schedule (in hours - compliance more strict ELV, schedules compliance application); schedule and requirements for /Improvement schedule(time table Case study: defining the permit action plan for sending in a project schedules with the operator; conditions improvements description solving Is able to set a problem, conditions related to deadlines for compliance construction of schedules. treatment plant, replacement of old technology etc.

12 SESSION 2, DAY 2 – Permit and permit conditions continued Area Topic Training objective Methodology Time Material Outputs Remarks - Conditions for air Can set appropriate Review national examples from 2 hours Relevant BAT note; Permit emissions and air site specific issued permits; Discuss options + home ELV in actual monitoring; conditions; (different types of conditions) work PPT : Kemira case case, - Air spreading models, Is able to set proper Case study: Set selected limit monitoring - EQS; ELV, monitoring and values for actual case study, conditions - Emission trade (CO2) reporting review existing ELV in permits, and and IPPC6 requirements; write monitoring and reporting conditions for Knows the conditions the reporting consequence for the related to Air IPPC permit of the emissions emission trade scheme for CO2; Knows the national air spreading models and the principle

6 Guidance will be given later on this issue 13 SESSION 2, DAY 3 – Permit and permit conditions continued Area Topic Training Methodology Time Material Outputs Remarks objective Conditions on soil, Introductory presentation on Handouts of Conditions (design, Permit ground and ground the necessity of setting 1-2 presentation maintenance/control, water protection; proper conditions for hours Sections from case monitoring) storage tanks and protection of ground and study application underground pipes ground water; Case study: setting conditions Conditions on Can set appropriate Review national examples 2 ELV in actual case, Permit - water discharges site specific from issued permits; Discuss hours - relevant BAT monitoring - water discharge conditions options (different types of + note; conditions and monitoring; Is able to set proper conditions) home condition for the ELVs, monitoring Case study: Set selected limit work reporting - Water dispersion and reporting values for actual case study, models; requirements; review existing ELV in - EQS Knows the national permits, write monitoring and water dispersion reporting conditions models,principle Conditions for noise Knows the national Presentation of national 1 hour Handout with Noise conditions Permit rules and limit rules; discussion on options national rules for values for noise; in the actual case; external noise from Is able to set “pragmatic” conditions – not industry; list of appropriate setting actual limit values (in national/regional conditions. cases where no national firms carrying out rules is implemented) noise measure- Case study: setting ments; examples conditions on noise conditions;

14 SESSION 2, DAY 3 – Permit and permit conditions continued Area Topic Training objective Methodology Time Material Outputs Remarks Conditions on odour Knows the national Presentation: Which Handout with Conditions if Permit when relevant rules and limit values substances are likely to give national rules, if relevant for odour; Knows how rise to odour; how to determine any; UK guidance to limit odour and emissions, how to set note on odour how to set conditions conditions Conditions on “closing Understands the Presentation of the objective 1 hour Handout with the Conditions Permit down the installation”. back ground for the and the national rules; objective and the requirement; Is able examples §§ from legislation Financial security to set proper Case study: Conditions for the and national /other conditions; Knows for actual case examples. which activities financial security is required (if any) Conditions on waste Is aware of the need Produce with the trainees a list 1-2 IMPEL report (to be Waste Permit management for and options of of waste minimisation options at hours produced in 2004) minimisation waste minimisation an industrial site. Case study: options for an and off-site recovery Set conditions for the actual industrial site, and disposal; Is able case installation (e.g., off-site to give operator programme for waste recovery and guidance and can set minimisation options) disposal conditions as options appropriate Permit Conditions on energy 1 hour IMPEL report (Horizontal BREF efficiency to be produced in 2004-2006)

15 Session 3 Nov/Dec 2004 Permit, monitoring and permit procedures, review of own draft permit conditions

SESSION 3, DAY 1- Permit procedures and prevention of accidents Area Topic Training objective Methodology Time Material Outputs Remarks Permit procedure from Knows in detail the Discussing the national rules Handout with the Own regional Whom to Permit A -Z, including procedure for IPPC; Case study: How comments of 2 hours national rules procedure involve, when, procedures involving other Has own regional the public were considered and home collected from from A -Z and in which authorities (including written procedure. taken on board work different acts cases), inspectors) and the produce a public procedural scheme Temporary derogation Knows the rules on Present and discuss the 1/2 Handout with the List of Permit from limit values and temporary national rules hours objective and the possible other conditions derogations and can §§ from legislation derogations set conditions if and national /other for the actual necessary examples case (or another more relevant case) Prevention of Is able to set Case study: Based on the 1/2 – 1 Permit accidents, emergency conditions in operators application, define hour Application Conditions plans, abnormal prevention of conditions for operation accidents, reporting - prevention of accidents, and emergency safety management, reporting planning near misses and accidents, emergency planning

16 SESSION 3, DAY 1 Monitoring and reporting

Area Topic Training objective Methodology Time Material Outputs Remarks Monitoring and - Is able to put A) 3 hours - Examples on Result of A) Monitori reporting; environment together or review a Discussion - What is and handouts of discussion: what - surveillance of the ng and management and suggestion from the monitoring home monitoring is monitoring; production and or reporting training operator for a self B) work programmes Monitoring abatement units, monitoring Discussions: Key from national conditions for the defining key parameters - why programme stages in “best permits; reports; case installation for monitoring - who covering all aspects; practice” monitoring; - UK guidance, performance, - ELV that can be - Knows the value of conditions on - EU BREF on Sample content - measuring/following monitored proactive monitoring monitoring of Monitoring of regular and actively usage and - how contrary to “end of emissions : place, annual report generation (raw - judging compliance pipe methods (including (form and material, water and measurements”; specification of content) for the energy, waste), - Is able to define analysis method), case installation - measuring flows and conditions for frequency, reporting content of selected monitoring and and evaluation streams (air or water) reporting; procedure - IMPEL: Best - measuring flow and - Is able to set C) practice in content of air emission conditions in Good management is compliance and water discharges management also good monitoring (including self (requirements for production;, EMS and monitoring and internal procedures, EMAS PPT: independent training etc) - procedures for - air monitoring). -The goal is to have - Is able to guide the maintenance, measurements pro-active actions operator as regards surveillance, - water inside the production reports (content and monitoring use of measurement “you cannot manage or abatement units as format) resources, - monitoring and what you do not monitor” main priority instead measurements, reporting of costly analysis, internal and - ELV compliance monitoring/measuring external reporting, evaluation activities) training

D) Discuss scope and format for regular and annual (or periodic) reports

17 SESSION 3, DAY 2 Feed back on own permit conditions and substantial change Area Topic Training objective Methodology Time Material Outputs Remarks Feed back on own Trainees have Reviews of own 1 – 1/2 Permit conditions and home received feed back permit conditions, day work and the quality of the feed back, revision. draft permits have risen Substantial change Is able to judge if a Presentation and 1 hour (96/61 + 35/2003 Procedure in Substantial change is substantial discussion; definition + national case of change and therefore needs and examples from legislation; substantial amended permit own IPPC handout with change installations; discuss definitions national procedures IMPEL report for changes at IPPC installations

18 SESSION 3, DAY 3- Review of own permit conditions, regular permit review Area Topic Training objective Methodology Time Material Outputs Remarks Feed back on own Trainees have Review of own permit 1/2 day Good quality Permit conditions and home received feed back conditions, feed back, conditions work and the quality of the revision. draft permits have risen Review of permit, co- Is able to carry out Discuss the national 1-2 Handout: Permit operation with the procedure for procedures hours Summary of the inspectors review of permits (frequency, method, national procedure, re-action procedures and obligations

19 Session 4 - for further development later by the national teams, after inspiration from Core Team Common issues - EIA and IPPC

This table is only included to show the national trainers what the topics of common interest could be. The Core team will, based on inputs from the national team give a suggestion for the work shop at a later stage.

Possible Topics Methodology What is IPPC An IPPC trainee explains to the EIA expert, what is IPPC and its main procedures and scope What is EIA An EIA expert explains what is EIA and its main procedures and scope Producers on IPPC and EIA Group work: Trainees investigate the obligations of the national legislation and writes procedures/flow for a case where an IPPC installation needs an EIA - new installation - expansion of existing Public participation How to organize public participation. How to take comments into consideration. Habitate directive Present Art 6 of the habitate directive, as transposed in the country; discuss relevant cases Transboundary pollution Presentation and dialogue; Case study of available, or (other national example if available, other country example Impact on environment Linkage between EIA and Do conditions set as part of the EIA get included in the IPPC IPPC permit? If so how. Why is this important?

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