The Brussels Institute for Management of the Environment

1. The Brussels Institute for Management of the Environment Prioritisation of inspections (inspection plan) • Gulledelle 100 • 1200 Brussels • BELGIUM • Tel 02/ 775 75 01 • Fax 02/ 775 75 05 • www.ibgebim.be Jean-Pierre JANSSENS Director Head of Division Inspection & Ecomanagement

2. European “legal” context IMPEL // minimum criteria on inspection: • Every Member State must have an inspection plan Depending on: • Type of activities to be controlled • Risks of the relevant emissions • Environmental effects of the emissions Bearing in mind: • The specificity of the location/type of controlled installations • Reports from the operators to the authorities • Self monitoring data • Data on environmental audit / reports • Results of prior inspections • Reports on monitoring of environmental quality that lays down routine inspections and frequency. • Brussels has devised a single inspection procedure in terms of: • Control necessity • Control frequency • Dutch Impel project on the prioritisation of inspections of companies needing an environmental permit based on objective and relevant criteria (see above)

3. Brussels environmental permit system • European context environmental permit for IPPC (+) (± 150 000 installations) • Legal basis: environmental permit ordinance • Ordinance of 22/04/1999:list of the class IA classified installations • Decree of the Brussels Region of 04/03/1999:list of the class IB, II and III classified installations • Decree of the Brussels Region of 20/05/1999: obligation to obtain advice from the Brussels City Service for Fire Protection and Emergency Medical Aid • Objective: prevention of pollution/ risk concerning all environmental aspects: water, noise, air, soil, waste, etc. -> Integrated approach • Scope: industrial activities (SMEs), incineration plants, etc. • Instruments: • Environmental permit • Notification ( for class III installations only)

4. Classified installations (1) • Company activities were categorised as “classified installations” (=categories) in the environmental permit -> some 200 categories • In turn these classified installations were divided into 4 classes: Ia, Ib, II en III • The highest class determines the environmental permit procedure Municipality Level Regional Level III II IB IA (> 25,500) (> 100,000) > 7,500 • less hazardous:(nuisance is more local) • simple procedure • hazardous • more complex procedure notification environmental permit

5. Classified installations (2) • Categories: • Production activities/ production installations (e.g.: chemical plant, slaughterhouse) • Storage activities (hazardous waste) • Supporting activities (enabling main activity, for instance a heating oil cistern) • Classes within a category dependent upon: • Headcount • Power/storage capacity used • Surface area -> NB: The class is not always a correct reflection of the expected environmental impact.

6. Examples of classified installations * Advice of fire protection service required

7. Complexity of the company: How >  number of separate processes, how > environmental risk + more effort for environmental permit Risk-index Impact on environment and health (residential areas, natural areas, water surfaces, vulnerability of the groundwater, etc.) Emissions Persistent, of an eco-toxicological nature and relevant observed environmental impact Environmental management Eco-management Control necessity and frequency is measured by means of scores assigned in accordance with (1):

8. Control necessity and frequency is measured by means of scores assigned in accordance with (2):

9. Complexity of the company (1) • Permit classes: not always a correct reflection of the expected environmental impact - Correction factor according to: • Production installations and activities • Storage activities • Supporting activities • Correction factor depending on safety risk (=advice from fire protection service required)

10. Complexity of the company (2) • Significant risk • Number of industrial water discharge points x5; max. x15 • Number of diffuse and guided emissions flows in air x5 • Number of storage tanks underground and above ground (soil) x10, x5, respectively • Production of hazardous waste, correctly or not eliminated (obligation of notification of the collected waste streams)  Traceability • Oil waste x5, x10, respectively • Machines containing PCBs x10, x20, , respectively • Hazardous waste (acc. to EURAL) x20, x40, , respectively • Surface area of the company • Process activities at ground level • Headcount: NB: not in environmental permit, but via social security registration

11. Risk index  Degree of presumed risk on account of: • Type of activity (soil): • duration of the activity • substances used in the process -> calculated via a risk index • Sensitivity of the location (soil): • surroundings  residential area  industrial area  natural site • geology of the site (groundwater captures(?)) -> calculated via a score • NB: inventory of potentially contaminated ground (GIS-data base)

12. Emissions By means of European Pollutant Emission Register Directive: • 37 relevant parameters for air • 26 relevant parameters for water Emission index =  ( total emission per parameter/ threshold value) • Of air (guided emissions only) • Of water -> high score: important source • Quantity • Eco-toxicity

13. Environmental management • Environmental management system, certified or not • Compliance with environmental provisions in force By means of the number of warnings, formal notices and prosecution reports / 5 years: • Permit background (recent application) and validity (refusal)

14. The scores are given a weighting percentage depending on the risk expected that can be estimated with the different characteristics:

15. Control necessity and frequency -> Final sum provides an indication of the expected environmental impact = indication of inspection necessity

16. Control necessity and frequency: examples