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Activities requiring an environmental permit and their classification

The European Union’s Industrial Emissions Directive (IED) (2010/75/EU) requires the following categories of activity to operate in accordance with a permit:

  • energy industries (in particular power plants);
  • production and processing of metals;
  • the mineral industry (including the production of cement and asbestos and manufacturing glass);
  • production of organic and inorganic chemicals;
  • waste management (ie, the disposal and recovery of waste); and
  • other activities, including the production of pulp, paper and cardboard, pre-treatment and dyeing of textiles, tanning of hides and skins, disposal or recycling of animal carcasses, and intensive rearing of poultry or pigs.

A detailed list of activities falling within each of these categories may be found in Annex I of the IED.

Procedural and documentary requirements to obtain a permit

Article 12 of the IED requires operators to provide a description of the following when applying for a permit:

  • the installation and its activities;
  • the raw and auxiliary materials, other substances and the energy used in or generated by the installation;
  • the sources of emissions from the installation;
  • the conditions of the site of the installation;
  • where applicable, a state of soil and groundwater contamination baseline report;
  • the nature and quantities of foreseeable emissions from the installation into each medium, as well as identification of significant effects of the emissions on the environment;
  • the proposed technology and other techniques for preventing or, where this is not possible, reducing emissions from the installation;
  • measures for the prevention, preparation for re-use, recycling and recovery of waste generated by the installation;
  • any other measures planned to prevent pollution, waste, inefficient energy use, accidents (and to limit their consequences);
  • measures planned to monitor emissions into the environment; and
  • the main alternatives to the proposed technology, techniques and measures studied by the applicant.

The permit application must also include a non-technical summary of the above.

Consequences of violating permit rules and decisions (non-compliance)

Article 8 of the IED provides that in the event of a breach of permit conditions, the operator must:

  • immediately inform the competent authority;
  • take the measures necessary to ensure that compliance is restored within the shortest possible timeframe; and
  • take any further complementary measures that the national competent authority considers necessary to restore compliance.

Where the breach of permit conditions poses an immediate danger to human health or threatens to cause an immediate significant adverse effect upon the environment, and until compliance is restored, the operator must suspend operating the installation.  In addition, Article 79 of the IED requires member states to impose effective, proportionate and dissuasive sanctions for violating permit rules and decisions.

EPA National Priority Sites

The EPA has developed a system to rank industrial and waste licensed sites in order of priority for enforcement. The National Priority Sites List is used to target enforcement effort at the poorest performing sites in order to drive improvements in environmental compliance.

A score is assigned to each facility based on enforcement factors such as complaints, incidents, compliance investigations (CIs), and non-compliances (NCs) with the licence. The National Priority Sites list is updated on a quarterly basis.

Verde Environmental Consultants works with our EPA licenced clients to achieve compliance according to their licence conditions in the most economical way possible. We have a proven track record of successfully reducing many of our clients’ expenses in this area by securing reductions in monitoring requirements and by the easing of licence conditions where appropriate.

We currently represent a range of licenced companies from smaller Irish companies to large multinationals in the pharmaceutical, food, manufacturing, extraction and waste sectors.

Services of particular interest to the IE/IPC Sector include:

  • Perpetration of licence application, review/amendment, site plans and reports (AER, ELRA, CRAMP & Firewater).
  • Compliance Monitoring and Reporting (surface water, groundwater, noise etc).
  • Waste Classification and Reporting.
  • Environmental Management System and EHS implementation and support.
  • Risk Assessment, Contamination Management and Appropriate Assessment.
  • Troubleshooting and negotiation on your behalf with the Agency.

Our expertise in this area, combined with our local knowledge, has been of assistance to clients in better managing their IE/IPC licence requirements and to this effect we also enclose a brochure giving some additional information on the range of services we provide.

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