THE GREEK EXPERIENCE IN IMPEL PROJECTS

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SEMINAR, Nicosia,7-8/6/2001 Integrated Control of
Industrial Pollution and Chemical Substances in
Cyprus
THE GREEK EXPERIENCE IN IMPEL PROJECTS Presentatio
n by Katerina Iacovidou-Anastasiadou
Division of Industries, Directory for Air and
Noise Pollution Control, General Directory for
the Environment, Hellenic Ministry for the
Environment, Physical Planning and Public Works
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EU IMPEL NETWORK PROJECTS EXECUTED BY GREECE

• 15th EXCHANGE PROGRAMME FOR EU INSPECTORS,
  GREECE, November 1999
• IMPEL FOOD PROJECT Integrated pollution control,
  compliance and enforcement of EU Environmental
  legislation to Industries (IPPC and non IPPC) of
  the food production/processing sector,
  9/2000-4/2001 (Workshop in Athens, 29-31/3/2001)
• Both Projects co-funded by the European
  Commission (DG Environment) and the Hellenic
  Ministry for the Environment, and executed by the
  National Observatory of Athens, on behalf of and
  in collaboration with the Ministry (Division of
  Industries).

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15th EXCHANGE PROGRAMME FOR EU INSPECTORS,
GREECE, November 1999Background (1/2)

• The last one of a series of such Programmes that
  were initiated by the EU IMPEL Network and had
  been organised by the competent Authority of each
  European Union Member State.
• Host The Hellenic Ministry for the Environment,
  Physical Planning and Public Works (MEPPPW). All
  technical matters were organised by the
  technical committee of the Ministry's Division
  of Industries.
• Organisation National Observatory of Athens
  (NOA).
• The Programme took place in Greece, November
  15-21, 1999.

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15th EXCHANGE PROGRAMME FOR EU INSPECTORS,
GREECE, November 1999Background (2/2)

• Duration of grant agreement (for EC funding)
  4 months (1.9.1999- 31.12.1999)
• Signature of grant agreement (between NOA and
  EC), by the Commission on 9.8.1999 agreement
  received by NOA approximately 1 month later.
• Final report and financial statement to the EC by
  31.3.2000 (3 months after end of grant
  agreement).
• Budget 108,565 (eligible cost some additional
  cost for AC)
• Funding 86,852 (80 of eligible cost)

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15th EXCHANGE PROGRAMME Scope of the Project

• The scope was for participants to
• learn about environmental permitting and
  environmental inspection and enforcement of
  environmental legislation in the Greek industry,
  and
• exchange information and views on these issues.

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15th EXCHANGE PROGRAMME Participation

• Two representatives from each EU Member State
  (MS) and
• One representative from each AC were invited to
  participate in the Exchange Programme.
•  In total, 35 EU and AC participants came to
  Greece
• 20 participants from 12 EU countries
• 13 participants from the AC countries (all 11
  countries participated, 3 participants from
  Cyprus),
• IMPEL Secretariat (Terry Shears)
• European Commission (Susan Hay)

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15th EXCHANGE PROGRAMME Activities

• One full week stay in Greece
• arrival-welcome reception on Monday, 15.11.1999
• cultural event-departure on Sunday, 21.11.1999
• 2 days outside Athens (3 plants visited between
  Athens Delfi Patras Athens)
• Conference (1-day) presentations by Greek and EU
  officials
• Visits to industries 12 plants involved
• Workshops (3) presentations on the visits,
  exchange of views and presentations by persons
  from the Ministry.
• Cultural events visit of the archaeological
  sites of Delfi and Acropolis.

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15th EXCHANGE PROGRAMME Presentations (1/3)

• EU AC
• George Kremlis "Implementation of EU
  Environmental Law the role of IMPEL"
• Terry Shears "IMPEL - a brief survey"
• Athanassios Balodimos "The adoption by the
  applicant countries of the environmental acquis
  in the framework of the future enlargement state
  of play and next steps"

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15th EXCHANGE PROGRAMME Presentations (2/3)

• Greek system
• Katerina Iacovidou "Legal Framework,
  Environmental Impact Assessments", "Environmental
  permitting procedure, and Procedure for public
  hearing of the Environmental Impact Assessments
  ", "Inspections"
• Nontas Toleris "Implementation of EU Directives
  85/337/EC and 97/11/EC", "Structural Organisation
  of Greek Services (MEPPPW, Regions, Prefectures)"
• Representative from Ministry for Development
  "Integrated approach to issuing permits for
  industrial activities".
• Representative from Ministry for Health
  "Industrial wastewater Treatment and Disposal"
• Dimitris Lalas (Director of NOA) "Monitoring
  Enforcing Agency for Environmental Compliance in
  Greece (Inspectorate)"

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15th EXCHANGE PROGRAMME Presentations (3/3)

• Technical issues
• Presentations by persons from the Division of
  Industries on
• The metallurgical industry and environmental
  inspection in Greece
• Environmental aspects of electricity production
  in Greece the case of Greek lignite
• Industrial solid waste management
• The implementation of 96/61 Directive in Greece

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15th EXCHANGE PROGRAMME Visits to industries

• 5 common visits, 4 of which to big plants
• ALOUMINIUM OF GREECE
• ACHAIA CLAUSS WINE COMPANY SA
• TITAN CEMENT COMPANY SA
• Psytalia Wastewater Treatment Plant
• Metamorfosis Wastewater Treatment Plant (smaller
  plant)
• 2 visits by groups (choice between 3-4
  alternative plants the industries were typical
  of Greece food sector)
• oil margarine processing factory
• milk yoghurt, milk fruit juices
• storage of liquid fuel
• brick manufacturing
• meat processing
• bottling of soft drinks and juices

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15th EXCHANGE PROGRAMME Evaluation by the
participants (1/2)
Did the programme live up to your expectations?
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15th EXCHANGE PROGRAMME Evaluation by the
participants (2/2)
Organisation of the programme of today?
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15th EXCHANGE PROGRAMME Results of the
Evaluation by participants

• The Programme lived up to the expectations of
  practically all participants.
• The organisation of the Programme was considered
  to be good by the vast majority of the
  participants.
• The Programme was considered as informative and
  useful, but rather heavy (with late lunches and
  late dinners!).
• Subject coverage was good. The selection of
  industries to be visited and the visit agenda
  seemed to be good.
• The cultural event at Delfi was appreciated by
  all participants.
• Overall evaluation a useful exchange Programme,
  at the right level.

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IMPEL FOOD PROJECTBackground (1/2)

• One of a number of such Projects initiated by the
  IMPEL Network.
• The purpose of the Project was to exchange
  information between EU Member States and
  Accession Countries in order to develop options
  for integrated pollution control, compliance and
  enforcement for food production/processing
  industrial activities (IPPC and non IPPC).
• Three food sub-sectors of interest were
  identified during the initial phase of the
  project milk industry, meat processing, and
  breweries.
• Data on those sub-sectors were collected using a
  Questionnaire that was circulated among the IMPEL
  and AC-IMPEL Network (National Coordinators).
• Workshop, March 29-31, 2001 in Athens, to discuss
  results and exchange views.

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IMPEL FOOD PROJECTBackground (2/2)

• Duration of grant agreement 8 months (1.9.2000-
  30.4.2001)
• Signature of grant agreement (between NOA and
  EC), by the Commission on 18.7.2000 agreement
  received 23.8.2000.
• Final report and financial statement to the EC by
  30.7.2001 (3 months after end of grant
  agreement).
• Budget 114,180
• Funding 68,508 (60 of eligible cost)

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IMPEL FOOD PROJECTScope

• Collection exchange of information for
• Comparison of legal requirements and their
  implementation, and of licensing and enforcement
  practices in the EU MS and AC, for the 3 selected
  food sectors.
• Comparison of these food sectors in MS and AC
  with respect to classification (e.g., size, type
  of units), effect of the IPPC Directive
  (96/61/EC), Clean Technologies used/ potential
  BATs, etc.
• Identification of common problems or country
  peculiarities, and suggestions for appropriate
  approaches.
• Results will be shared with the TWGFOODMILK of
  the IPPC Bureau in Seville (started work in
  January 2001).

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IMPEL FOOD PROJECTProject overview (1/2)

• Selection of 3 food sectors and preparation and
  circulation (among IMPEL Network) of a
  Questionnaire.
• Preparation distributing of a Selection Form
  to EU NCs.
• Draft Questionnaire prepared (help of Greek
  Expert Group)
• Preparatory project meeting (Paris, 8/12/2000,
  views of EU)
• Final Questionnaire circulated by 31.12.2000.

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IMPEL FOOD PROJECTProject overview (2/2)

• Collection and processing of data and Workshop
• Deadline for receipt of data 16.2.2001 (extended,
  in practice).
• Workshop in Athens, March 29-31, 2001.
• Final Report with the results of the
  Questionnaire
• and the minutes/conclusions of the Workshop.

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IMPEL FOOD PROJECT Participation

• Questionnaires completed by 12 EU and 9 AC
• EU Belgium, Denmark, Finland, Germany, Greece,
  Ireland, Italy, Portugal, Spain, Sweden, The
  Netherlands, United Kingdom
• AC Bulgaria, Cyprus, Czech Republic, Estonia,
  Latvia, Lithuania, Poland, Slovak Republic,
  Slovenia.
• 60 participants at the Workshop 27 national
  representatives from countries other than Greece
  and from the European Commission

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IMPEL FOOD PROJECTConclusions (1/4)

• Meat processing and Milk industry are among the
  most important food industry sub-sectors in the
  majority of the MS and AC. The Brewery sector is
  relatively smaller, but it is still considered
  as very important in most countries. So, these
  food sub-sectors could be considered to be among
  the priorities for the establishment of BREFs.
• The transposition of the IPPC Directive
  (96/61/EC) is fully completed in 8 of the MS and
  is expected to be completed by year 2002 in the
  remaining of the MS. Transposition by year 2003
  is also expected in at least 7 of the AC.
• For the milk and meat industry, the plants that
  fall within IPPC represent a small fraction of
  the total number of plants in each country
  (generally less than 10 exceptions, notably
  Nordic countries). The opposite is the case for
  breweries, where the IPPC plants generally
  represent at least 10 of the total number of
  plants (only 2 in Germany).

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IMPEL FOOD PROJECTConclusions (2/4)

• Out of the 21 countries, only 6 use a single
  permit system for any food industry (plus UK has
  a single permit for milk industries). Lithuania
  the only AC among this group. The authorities
  usually involved in permitting are the Ministry
  for the Environment, local authorities and
  regional authorities.
• Generally, no special provisions exist for the 3
  food sub-sectors (the applicable
  permitting/inspections/compliance legislation is
  that applicable to any industry). The IPPC
  Directive limits ( gt200 tn milk/day gt75 tn meat
  product/day gt300 tn beer/day) are used (or will
  be used) by all countries.
• References on national standards or guidelines
  for Clean Technologies or BATs for the three food
  sub-sectors of interest (existing or under
  preparation in EU countries) were recorded.

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IMPEL FOOD PROJECTConclusions (3/4)

• There are generally no toxic and hazardous
  substances associated with these three food
  sub-sectors, neither in terms of raw materials
  used nor in terms of emissions.
• Therefore, the need to emphasize prevention in
  BATs (adoption of the best operation practice,
  the improvement-modification of the production
  processes etc.) as opposed to treatment
  techniques and benchmarking as part of BATs,
  especially for water, energy, raw material
  consumption, etc. was identified.
• However, solid waste management is an important
  issue for part of the meat industry due to the EU
  decision about the ban of by-product reuse. It
  seems that guidelines from the EU Commission
  regarding acceptable methods of disposal of
  by-products from meat processing are essential.
• Self-monitoring is considered to be essential for
  all industrial plants of the three food
  sub-sectors.

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IMPEL FOOD PROJECTConclusions (4/4)

• High consumption of water and energy are among
  the common problems encountered in some
  industries of all three food industry
  sub-sectors, along with the absence of sufficient
  recycling, material recovery and reuse, weak
  supervision of discharges to municipal sewers,
  and solid waste management.
• It is generally acknowledged that the main
  problems are from the non-IPPC industries
  (re-think about mini-IPPC Directive?).
• Dissemination of the know-how in BATs and
  exchange of the information is important and
  should be done through main channels such as
  IMPEL. It was also proposed that a) the EU
  Commission bears the costs of the BREFs
  translation (for the AC) b) a "BAT Helpdesk" be
  established and operated at an EU level, so that
  all countries, MS and AC, can consult for help
  and, c) educational and training meetings be
  organized.

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IMPEL FOOD PROJECT Lessons learned

• Members of the EU and AC IMPEL Networks welcome
  such Projects.
• Most useful part is considered to be the Workshop
  (opportunity for exchange of information and
  discussion and for establishment of good personal
  relationships/networking).
• Combination of presentations/Working Groups and
  site visit(s) is preferred.
• Diversity is highly encouraged in the
  presentations (different points of view
  administration, scientists/experts, industry).
• Working Groups best for active participation/
  expression of views.
• A clear target with respect to the dissemination
  of the project results is important (an
  appropriate body or national authorities)
• In the case of the IMPEL Food Project, the fact
  that the results would be communicated to the
  EBIPPC was viewed favourably.

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IMPEL FOOD PROJECTAdministrative issues -
technicalities

• TOR approval IMPEL Plenary Meeting in Helsinki
  (11/1999)
• Revised TOR IMPEL Plenary Meeting in Porto
  (6.2000)
• Draft proposal for funding to IMPEL Secretariat
  12.5.2000
• First Proposal submission 19.5.2000
  (re-submitted in June 2000)
• Unofficial notification (IMPEL Secretariat) on
  approval 4.7.2000
• Signing of the grant agreement by EC 18.7.2000
• Receipt of the agreement by NOA 23.8.2000
• Project duration 1.9.2000 30.4.2001
• Overtime in terms of work until preparation
  and distribution of Final Report (submitted for
  adoption in Falun IMPEL Plenary meeting)
• Financial statement submitted with the Final
  Report to the EC by 30.7.2001 includes
  supporting documents (invoices) contract budget
  should be respected (deviation of 10 for
  individual headings travel, consumables, )

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SOME GENERAL POINTS FOR IMPEL PROJECTS

• Evaluation forms are useful for getting feed-back
  from the participants.
• Review of the final Report by participants is
  needed. This should also facilitate the adoption
  of the final Report by IMPEL (at a Plenary
  Meeting).
• Dissemination activities should be foreseen
  (early decision needed as to whom and how e.g.
  contacts, CD-ROM, home page-).
• Flexibility in the organisation and personal
  contact are important (IMPEL members have busy
  schedules and, to some degree, they are investing
  personal time for the network activities).

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OVERALL EVALUATION OF THE GREEK EXPRERIENCE FROM
IMPEL PROJECTS

• A very useful experience highly recommended!
• Administrative issues are very important, both
  before and after signature of a grant agreement
  with the European Commission
• Project executor, TOR approval, preparation and
  submission of the proposal using appropriate
  procedure/forms, national funding.
• The role of the IMPEL Secretariat is critical.
  Terry Shears was a BIG help in both occasions!!!
  
• Review/useful comments, information on the
  funding procedure, contact with the financial
  Unit, IMPEL contacts, advise during the project
  (use his experience!), etc.
• Proper project planning and cost estimation are
  essential.
• Take into consideration potential delays in
  submitting for funding, signing/receipt of the
  agreement getting participants to react
  (confirmation of attendance, review of documents,
  etc.), and review.
• Some costs depend on the time-schedule (travel,
  hotel, etc.) or participation need to plan
  activities well (at the stage of the proposal),
  but also allow some flexibility (unforeseen costs
  of program changes!).

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CONTACTS FOR MORE INFORMATION

• Katerina Iacovidou, Division of Industries,
  Directory for Air and Noise Pollution Control,
  Hellenic Ministry for the Environment, Physical
  Planning Public Works, kiakovidou.dearth_at_edpp.gr
  , fax./tel. [phone]
• Natasha Kotronarou, Institute for Environmental
  Research Sustainable Development, National
  Observatory of Athens, natasha_at_env.meteo.noa.gr,
  tel. [phone], fax. [phone]
• For information on the IMPEL Food Project
  http//www.meteo.noa.gr/IMPEL/index.htm.

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Terms of Reference (TOR)

• There has to be a Lead Country, and a Project
  Manager (for the financial subjects of the
  Project)
• the Project proposal, during the Plenary meeting
  of IMPEL must be supported, at least, by 3-4
  countries, in order to be adopted
• the legal base of the Project has to be a
  Directive, a Regulation, etc
• the funding by the Commission is about 50, of
  the eligible cost, with some exceptions (up to
  80).