IPPC implementation in Hungary Points of special interest

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IPPC implementation in HungaryPoints of special
interest

• Ildikó Babcsány
• Head of Department
• National Directorate for Environment, Nature and
  Water
• Directorate for Environment
• 26 April, 2004

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Main objectives of the harmonisation of the IPPC
Directive

• Meeting EU requirements
• High level protection of the environment as a
  whole
• Further implementing integrated approach
• Simplifying the administrative procedure (one
  window system)
• Transparency of the permitting procedure (public
  involvement)

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Legislative background for the integrated
permitting

• Act LV of 2001 on the modification of certain
  acts with environment protection purpose
  (modification of Act LIII of 1995 on the general
  regulations of the environment protection)
• Introduces the new definitions
• Sets the place of the new permit
• Gov.Decree 193/2001 (X.19.) on the detailed
  regulations of the integrated permitting
  procedure
• Determines the detailed procedures
• Framework regulation, the details are in the
  media-specific legislation
• (Amended by the 47/2004 (III. 18.) Gov.Decree)

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Scope of the new legislation

• Annex I as defined in the IPPC Directive
• Additional activity Mining
• 13.1. Coal mining from 100 000 t/year, also in
  case of open-cast mining where the surface of the
  site is at least 25 ha
• 13.2. Extraction of petroleum and natural gas
  where the amount extracted is at least 500 t/day
  in the case of petroleum and 500 000 m3/day in
  the case of gas
• 13.3. Uranium ore mining where the amount
  extracted is at least 100 000 t/year
• 13.4. Metal ore mining in case of iron ore from
  1 million t/year, in case of non-ferrous metals
  100 000 t/year extracted, also in case of
  open-cast mining where the surface of the site is
  at least 25 ha

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Fitting the new permitting into the existing
permit system

• Installations that are obliged to EIA ?
  environmental permit
• Installations that are obliged to IPPC integrated
  permit ? integrated permit for the use of the
  environment
• Installations that are obliged to EIA and
  integrated permit ? integrated permit for the use
  of the environment
• Environmental audit ? environmental operation
  permit or integrated permit
• REIs other decisions, expert authority
  statements are integrated into the permits of
  other authorities

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Main requirements of the legislation

• Permitting authority is the regionally competent
  environmental authority
• Construction of the installation can only be
  started after receiving such permit
• In case of IPPC permit, all permits to be issued
  by the environmental authority shall be
  considered as issued
• In case the target state of the environment
  requires, requirements stricter than BAT can be
  specified
• The statements of EIA and Safety Report and
  Analysis has to be considered during permitting
• Procedure takes 90 days, can be extended by 30
  days
• 6 months test operation period

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Integrated permitting procedure
New installations

• (in case of EIA, decision on the entitlement to
  environmental permit )
• ?
• Application for permit (ex officio)
• ?
• Involving competent authorities
• ?
• Involvement of the public
• ?
• Permit

Existing installations
authority obligation for comprehensive
environmental audit
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Scope of the new integrated permit

• EIA permitting unit - site
• IPPC permitting unit - activity
• boundaries geographic, economic and technical
• list of IPPC installations in Hungary (January
  2004)
• less than 10 where installation ? site
• decision on the boundaries on case by case basis
• 74 permits so far
• approximately 1100 installations

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Authorities in IPPC enforcement

• REIs - at present 12, areas by water catchment
  areas, issuing all environmental permits (and the
  IPPC permit)
• Water Directorates - at present 12, areas more or
  less the same, issuing water permits
• under reorganisation, after the merge of the two
  tasks in one ministry
• IPPC permit covers all environmental media
  aspects, energy efficiency, EMS, decommissioning
• IPPC permits dont contain water permits, all
  safety issues and building permits

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Experiences from issued IPPC permits and the list
of installations

• Most usual cases
• IPPC activity large combustion plant
• IPPC activity WWTP or landfill technically
  connected
• cement kiln nearby limestone quarry (not the
  operation, but noise, dust and the remediation
  activities)

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Complex chemical site
ethylene
ethylene
LDPE-1 55 kt/y
LDPE
LDPE-2 65 kt/y
ethylene
naphta
Cracker 370 kt/y Ethylene 185 kt/y Propylene
HDPE 200 kt/y
HDPE
ethylene
PP-2 50 kt/y
gas oil
polypropylene
PP-3 105 kt/y
propylene
PP-4 140 kt/y
propylene
C4 C6 C7 fractions, conversion oil, hydrogene
propylene
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Pharmaceutical factory
basic pharmaceutical products
research and development
formulating
RD
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Factory for producing electrical equipment
2.6
WWTP
?
hazardous waste storage
production of electrical equipment
painting with pulverised paint and heat hardening
air polluting point source
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Disintegration of large industrial sites

• mainly chemical and iron and steel production
  installations
• usually different owners (economical boundary)
• if one owner and more installations,
  consultations are needed (technical boundary)
• Other sensitive issue
• one owner, more installations (but for the same
  activity) geographically on the areas of
  different REIs

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Involvement of the public in the permitting

• Methods were already in place, taking into
  account the principle of subsidiarity
• Permitting procedure
• The application for the permit and the
  permitting documentation is open for the public,
  the received comments are evaluated by the REI
  -together with the other competent authorities-,
  and included in the justification part of the
  decision
• Permit
• The REI and the municipality notary publishes
  the decision for 15 days for the public
• Green NGOs rights are set in law, they can act
  as client in environmental procedures

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Actual needs and developments

• Authority side
• Institutional background (ministry, technical
  background institute, permitting authorities) was
  already in place, but it needed enlargement in
  staff
• Still need of development in staff (importance of
  technological knowledge)
• Multicountry PHARE project, industrial site
  visits organised by NDENW
• Information on new aspects diffuse emission
  sources, energy efficiency, cost-effectiveness,
  cross-media effects

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Actual needs and developments

• Software development - preparation for data
  supply (EPER, ART 16), register of IPPC
  installations and permits
• Publishing technological national BAT guidances
• Finalisation of the application form for the
  integrated permit applications
• Industry side
• Costs of complying with BAT requirements is a
  primary aspect for new member states
• They have to invest in order to being able to be
  competitive on the international market

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Decision on BAT is supported by

• The requirements of the Gov.Decree Annex 2
• The requirements of the media specific
  legislation
• The NDENW IPPEA Department
• The development of national guidances based on
  the BREFs and the national characteristics
• Consultation between authorities and applicants

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Thank you for your attention!