November 2003
To IPPC or Not To IPPC?!
As the Integrated Pollution Prevention and Control (IPPC) regime continues to be rolled out, the position of the smaller surface engineering companies is still under debate.
The new Integrated Pollution Prevention and Control (IPPC) regime is designed to control the current and future environmental effects of various industrial activities.
The original systems for preventing and controlling emissions under Part 1 of the Environment Protection Act are:
- Integrated Pollution Control (IPC)
- Local Air Pollution Control (LAPC)
The new regime, Pollution Prevention and Control (PPC), will eventually replace the existing legislation and implement the EC Directive on integrated pollution prevention. It is a system following the European Community Directive (96/61) that introduces a more integrated approach to controlling pollution from industrial sources, across England and Wales. Nearly 7,000 installations will be covered by the Regulations, which are being phased in across a number of industrial sectors on a rolling schedule ending in October 2007.
Regulated activities fall under three different categories, depending on the processes carried out:
Category of Process |
Acronym |
Regulated by |
Part A1 |
IPPC or PPC |
Environment Agency |
Part A2 |
LA-IPPC or PPC |
Local Authorities |
Part B |
APC or LAPPC |
Local Authorities |
LA-IPPC - Local Authority Pollution Prevention and Control
APC - Air Pollution Control
The regulations state that any applicable installation or mobile plant (as defined in the Regulations) operating after the prescribed date must obtain a permit and comply with the conditions in that permit. Such operations must apply to the Regulator (Environment Agency or Local Authority) within the timescale appropriate to the sector.
Some of these deadlines have already passed and companies in these sectors should have already made an application. These include sites which carry out operations in ferrous and non-ferrous metals, cement and lime, glass and glass fibre, paper, pulp and board manufacturing, and coating, printing and textile treatments.
Most sectors are still yet to make applications. These include:
Combustion |
Gasification and Refining |
Surface Treatment of Metals and Plastics |
Asbestos |
Ceramics |
Organic Chemicals |
Inorganic Chemicals |
Chemical Fertilisers |
Plant Health Products and Biocides |
Pharmaceuticals |
Explosives |
Activities using Carbon Disulphide or Ammonia |
Disposal of Waste by Incineration or Landfill |
Recovery of Waste |
Production of Fuel from Waste |
Carbon Activities |
Tar and Bitumen |
Timber |
Treatment of Animal and Vegetable Matter and Food Industries |
Intensive Farming |
The position of surface treatment facilities under IPPC has been surrounded by some confusion. The latest news from the Surface Engineering Association is that surface treatment processes may actually fall under two different sections. It was originally thought that only those facilities with treatment vats larger than 30m³ would be covered under the IPPC regulations, Section 2.3. The 30m³ figure appears to be a fairly arbitrary and was viewed by many larger electroplating operations as creating an unfair financial advantage to the larger number of smaller capacity operations in existence.
The Regulations are now being interpreted differently by the EA and DEFRA meaning that all surface treatment facilities with less than 30m³ volume will fall under Section 4.2 of the Regulations, under the use of hydrogen halides in a manufacturing activity. This would have serious implications for a large number of companies that had not intended to make any type of IPPC permit application. It now appears that such companies may be required to apply and would have a notice served on them to cease activities if they fail to do so. The Scottish Environment Protection Agency (SEPA) contacted surface treatment companies in October expressing the same view. We believe that the interpretation of metal finishing companies as falling under the use of hydrogen halides is spurious. There are two reasons for this. Firstly, this section refers to the manufacture of chemicals and secondly, hydrochloric and hydrofluoric acids are n o t generally referred to as hydrogen halides. The hydrogen halides such as hydrogen chloride and hydrogen fluoride are toxic gases. These are not utilised by surface treatment companies.
Assuming that this matter is resolved in time for duly made applications to be presented, there remain certain fundamental issues to be considered. An example is the European Integrated Pollution Prevention and Control Bureau (EIPPCB) Sector document describing Best Available Techniques (BAT) for reducing water consumption. Some of the figures quoted for use of town water give a measure of water consumption as a function of the surface area of work plated. This must be open to some debate since in most cases the geometrical area of the work will differ greatly from the electro-active work piece area (maybe by a factor of as much as several orders of magnitude). It is not clear what is meant by the figures quoted and this is not something that most platers measure or are likely to be able to measure in the future.
Related sectors such as Hot Dip Galvanising seem to be suffering from the same type of confusion. DEFRA wrote to the Local Authorities in October in order to clarify the situation. Some UK operations falling under Part A (2), section 2.1 or 2.2 are now operating without a permit.
Consideration of the need for permitting needs to be on an installation-by-installation basis. Unless the European Bureau, DEFRA, the EA the LAs and the Trade Associations provide more clarity, many companies may find themselves in a difficult position and in some cases unable to continue to operate their installations legally.
Making an application is no small matter and can be very time consuming. Pro Enviro can help companies make a successful application across multiple industry sectors, allowing our clients to maximise time spent running their business.
We can manage and coordinate all aspects of the application on your behalf, working closely with the regulators. The focus of the regulations is 'prevention', meaning detailed assessments of management techniques, raw material inputs and waste outputs and environmental impacts need to be carried out.
Pro Enviro has considerable experience working with companies, regulators and government bodies and are up-to-speed with technical guidance and sector-based (BAT). Regulators look closely at the preventative measures taken against pollution through the employment of BAT and any departures from these must be justified. By keeping you informed of all developments through update meetings you can continue your business activities leaving the application and monitoring processes to us.
For an informal discussion about IPPC permitting, or to arrange a site visit from one of our consultants, contact Richard Whitaker on 024 76 279000.
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