Preparation Of Pollution Abatement Action Plans PDF

EXECUTIVE SHORT-TERM COURSES IN ENVIRONMENTAL STANDARDS TRACK B: PROFICIENCY CERTIFICATE IN ENVIRONMENTAL STANDARDS MODULE 1 DAY 5 SESSION 2 PREPARATION OF POLLUTION ABATEMENT ACTION PLANS PRESENTED BY: Prof. BORYO DORIS EZEKIEL AMIN. ADOPTED FROM: Dr. Sherif Arif, Ph.D. Senior Environmental C...

EXECUTIVE SHORT-TERM COURSES IN ENVIRONMENTAL STANDARDS TRACK B: PROFICIENCY CERTIFICATE IN ENVIRONMENTAL STANDARDS MODULE 1 DAY 5 SESSION 2 PREPARATION OF POLLUTION ABATEMENT ACTION PLANS PRESENTED BY: Prof. BORYO DORIS EZEKIEL AMIN. ADOPTED FROM: Dr. Sherif Arif, Ph.D. Senior Environmental Consultant The Environment Global Practice of the West and Central Africa - SAWE4 March 2022 Course Content  Justification for Pollution Abatement Action Plans  Pollution Abatement Action Plans  Compliance Action Plan  Waste Management Plan  Integrated Pest Management Plan for Obsolete Pesticides Why is a Pollution Abatement Action Plan is Required  To comply with national legislation in the Country  To decease pollution loads of the pollutants at their source  To improve ambient air and water quality  To protect human health at the workplace and in the communities Tools for the Pollution Abatement Action Plans  The Compliance Action Plan  The Waste Management Plan  The Integrated Pest Management Plan The Compliance Action Plan (CAP)  A Compliance Action Plan (CAP) is a tool to achieve compliance with environmental legislation. A CAP differs from a legislative approach as it gives enterprises the opportunity to make and implement an action plan, rather than that the authorities describe mandatory measures that a non- compliant enterprise has to obey. CAP’s are used all over the world in environmental policy to achieve compliance in a smooth way.  CAP is a practical alternative for legal procedures and prosecution. It also makes clear what actions an enterprises needs to take, and which investments are involved. It may prevent closure of industries and therefore loss of employment and income. It also is a better way than legal prosecution as this does not guarantee that after prosecution and payment of fines the enterprise will be in compliance, whereas a CAP is actually focussed on compliance. ECO ConsServ, DHV, and FCG, Industrial Pollution Control in Egypt, 2009 Purpose and Scope of a CAP  The purpose of the CAP is to  support pollution prevention and integrated pollution control. The companies must establish a self-monitoring system and report the results to th environmental authorities. To the extent possible, pollution transfer to other media should be avoided (cf. EU’s IPPC Directive), and dilution is not permitted  compare the factory environmental indicators (air emissions, waste effluents and solid waste) with the maximum regulatory limits of the Egyptian Environmental law and its Executive regulation.  understand the link between the environmental audit and CAP and how to use the audit data in preparing CAP.  develop a compliance action plan for their factory on the basis of a standard form Ref: EcoConServ, DHVm and GCG, Analysis of the Implmentaion of the CAP in Egypt , May 2009 Purpose and Scope of a CAP (ctd..)  The CAP is an official document for each enterprise with a clear commitment on the financial and human resources to be allocated over a period of realistic duration, on conditions and implementation schedule as well as on a monitoring program based on parameters useful to check plant performance as well as environmental performance.  The CAP is a “dynamic NEGOTIABLE document” that could be updated to reflect progress towards improved compliance and that could be reviewed and amended after consultation between the parties. In that respect the CAP is similar to the EMS (ISO-14,000 ser). The both schemes are aiming at supporting continuous development in the environmental performance – not only to achieve the compliance.  The enterprises should plan their own environmental investments in the CAPs without receiving technical specifications from the environmental or industrial authorities. The enterprises should have independence concerning their economy and they should plan the technologies they want to use by themselves using any available knowledge and technical assistance from other sources. The authorities can provide knowledge on such services and on possible financial opportunities. Ref: EcoConServ, DHVm and GCG, Analysis of the Implmentaion of the CAP in Egypt , May 2009 CAP Benefits  Environmental Benefits  Compliance with the legal requirements.  Improving environmental performance.  Increase staff environmental awareness.  Achieve environmental sustainability.  Economic Benefits  Reduce environmental liabilities.  Reduce material and energy losses.  Increase competitiveness and productivity. Ref: S.Massoud, EWATEC, Practical Compliance Action Plan Guidelines , November 2009 Links between an Environment Audit and a CAP Environmental Audit CAP Audit is a legal requirement. CAP is not a legal requirement. Conducted for complying and no- complying A strategy to face defect points indicated in industries. Environmental Audit limited to the companies not complying with regulations. Main objectives are waste minimization, Main objective is to comply with cleaner production and cost saving and Environmental regulations regardless cost saving or recovery. recovery. Look for improvement opportunities is a prime Consider mainly legislation, standards and objective. regulation compliance. Audit should be conducted before CAP. Good CAP relies on information obtained from good audit. Efficient self monitoring system is a prerequisite. Efficient self monitoring system is a prerequisite. Preparation Steps for the CAP  General information about the  Liquid wastes (end pipe) factory  Hazardous Material  Main production processes  Solid Waste  Process description  Hazardous waste o Existing pollution –  Process flow diagrams  Abatement units  Products  o Available licenses  Raw Materials & Utilities  Pollution abatement action plan  Description Water consumption  o List of Projects o  Energy consumption o Material, water& Energy balance \  Sub Project Requirements  o Surrounding are Current  Time-table for Implementation of the sub– environmental status Air emission project o Environmental management responsibilities o Investment planning o  Stack emissions for boilers, furnace Cost and benefits and electrical generator. Dust emissions  Financing of investments and operation  Work environmental emissions  Follow up and monitoring plan for sub-project after implementation o Performance Indicators Ref: Punkari, Dr. Mikko, 2008, “Draft, Policy Review: Compliance Action Plans”, Institutional Strengthening of the EEAA to Improve its Environmental Policies Formulation and Environmental Management Capabilities, November 2008 Format for a CAP Report  General information on the company.  Steps implemented to achieve compliance.  Production processes.  Current status for environmental  Description of production processes. compliance.  Raw materials, products and utilities.  Liquid waste.  Material & energy balances  Air emissions.  Surrounding Environment.  Hazardous materials and handling  Future plans. procedures.  List of environmental studies conducted  Solid and hazardous waste. in the company (last 3 years).  Work Environment. Ref: S.Massoud, EWATEC, Practical Compliance Action Plan Guidelines , November 2009 Format of a CAP Report (ctd)  Available control measures.  Environmental management.  Waste effluent treatment  Work team responsible for CAP systems. implementation.  Air pollution control systems.  Distribution of Responsibilities.  Solid and Hazardous Waste handling and disposal  Resources of work team.  Planned activities to achieve  Action plan environmental compliance.  Time schedule  Liquid waste.  Financial plan  Air emissions.  Work Environment.  Cost/benefits analysis.  Hazardous materials &  Possible source of finance. hazardous wastes.  Follow-up and Monitoring Plan  Monitoring of industrial pollutants. Waste Management Plan  The purpose of the Waste Management Plan (WMP) is to ensure that all waste streams generated during the Project are managed in accordance with all national requirements in an environmentally sound manner.  The WMP will provide direction for practical and cost-effective management of waste generation through “cradle-to-grave” systems, including storage, transportation, treatment and final disposal of waste. This is a flexible document and amendments will be incorporated if and when changes or other information require inclusion. Waste Management Hierarchy  The waste management will be implemented with due regard to the Waste Management Hierarchy, as illustrated which prioritizes waste management techniques. Each potential waste stream generated from the Project will be managed according to the hierarchy of techniques, in which the technique chosen will be the first in the hierarchy that is safe and practicable Source: OGP. (2009). Guidelines for waste management with special focus on areas with limited infrastructure Waste Management Hierarchy  Waste minimization should be applied whenever possible, by ensuring waste management activities utilize the following hierarchy:  Generation of waste should be prevented or reduced at the source whenever feasible;  Waste that cannot be prevented should be reused or recycled in an environmentally safe manner, whenever feasible;  Waste that is not prevented or recycled should be treated in an environmentally safe manner, whenever feasible;  Finally, disposal should be employed as a last option and when employed, it should be conducted in an environmental responsible manner Content of a Waste Management Plan Responsibilities: a) Describe the tasks, roles and responsibilities of the Generator of waste, the Project Manager of the Generator representative, the site Manager, and the environment and social specialist. b) Describe the institutional framework related to the hazardous waste management system , the tole and responsibilities of the ministry of the environment, the licensing authority and the inspection authority (ies) at the national and local level c) Waste Stream identification  Describe in a table the main waste streams , the type of waste, the quantity that will be generated during Project activities , along with the potential impacts they can cause if not adequately managed  Waste Management Methods  Discuss the measures and procedures that will be taken to manage waste generated by the Project. The following waste management procedures are discussed throughout this section: Waste Classification; Waste inventory; Waste handling and collection; Waste segregation; and Waste storage Content of a Waste Management Plan (ctd..) d) Waste Labelling Ensure that all waste receptacles (e.g., drums, bins, ) will be clearly labeled in accordance with the appropriate color coding to inform which waste stream it is appropriate for (e.g., hazardous liquids versus nonhazardous waste). e) Waste Transfer Indicate how the hazardous or nonhazardous waste waste will be transferred from on sire or off site aeras, by whim and the responsibility of such transfer Provide information on the routes by truck or trains, for transporting the hazardous waste to the treatment facilities f) Emergency Response Prepare an Emergency Response Plan in case of fires in the storage areas; accidental spillage, and mishandling of hazardous waste and leaking from the storage containers and accident collision Content of a Waste Management Plan (ctd..) g) Training  Provide training to all staff involved in the collection, handling, storage, transport and treatment of hazardous waste using th following topics at minimum  Waste Management Practices and Environmental license requirements (if any);  Potential waste streams that will be generated;  Waste segregation, bin colors and waste collection points;  Waste minimization opportunities;  Hazardous waste and associated risks;  Identification, classification, and labeling of hazardous and non-hazardous waste;  Technical training on handling, segregation, and storage options, with particular focus on hazardous waste to ensure safety of personnel and environment  Personal Protective Equipment (PPE) required for different waste streams  Waste management during normal operating conditions as well as emergencies  Install placards, brochures and posters in visible public areas to encourage awareness of various waste management practices Content of a Waste Management Plan (ctd..) h) Monitoring and reporting are required on a bi-monthly basis to cover:  Proper waste segregation, handling, labeling, and storage;  Percentage of waste inventories completed;  Number, volume, and type of unauthorized releases to the environment;  Percentage of waste inventories completed;  Percentage of waste inventories completed correctly.  Number and types of accidents  Problems and solutions provided Integrated Pest Management Plan (IPMP) for Obsolete Pesticide  T  Allow the government to make decisions on the strategy to be adopted for the safeguarding of obsolete pesticides (repackaging, transport and storage);  Allow the country to select the most appropriate disposal strategy for the waste identified at the inventory stage based on an assessment of national capacity to treat wastes in an environmentally sound manner;  Factor in any social issues as determined during the assessment of the inventory data and identify any locations where resettlement of inhabitants may be required (temporary or long term). Content of the IPMP 1) Analysis of the Policy, Institutional and legal framework related to a) The ability to manage the procurement, transportation, storage, use and disposal of the products used in pest control and their packages; b) The ability to monitor and forecast the occurrence and extent of diseases and insect pests, propose scientific management methods, and correctly select obsolete pesticides 2) Base Line Data should include:  A summary of any previous waste management and pesticide disposal initiatives;  A statement on the causes of accumulation as identified by previous studies;  All data related to the pesticide stores in the country, including the plot of  Environmental and Pesticide Risk Factors  A preliminary register of all contaminated sites;  An assessment of national management capacity to complete a national safeguarding operation;  An assessment of current disposal capacity in the country to determine the potential for local treatment of the wastes as identified at inventory. Content of IPMP (ctd..) 3) Environmental and Social Impacts will be assessed on the basis of:  A list of the high-risk locations with a summary analysis of the principal factors which make them a risk to either public health and / or the environment;  An assessment of the potential impacts from the locations based on their proximity to and inter-relationship with the broader environment;  Indication of any locations where permanent or temporary resettlement may be needed to allow the safeguarding operation to proceed. 4) Obsolete Pesticide Use and Impacts:  A detailed analysis of the waste streams to be dealt with  An assessment of national capacity to deal with waste streams;  Selection of preferred disposal options based on the waste streams and their respective volumes / amounts, current national capacity to deal with each waste stream and barriers to implementation of a national disposal option Content of the IPMP (ctd..) 5) Mitigation, Monitoring and Institutional strengthening Plan will include  Mitigation Plan which will address the (a) the potentially significant risk associated to the critical activities (repackaging, transport, storage and disposal) (b) the proposed mitigating actions; (c) when the action is to be taken (start and finish dates or ongoing); (d) who will be responsible for implementing the mitigating action during project operation; and (e) associated costs for the mitigation measures.  The Health, Safety and Environment Plan (HSE Plan) aims to provide the detailed methodologies and process to be completed to safely eliminate the problem. In short, the HSE Plan will:  Provide a detailed, site-specific methodology for the safe handling of the stocks as identified at inventory;  Make objective decisions regarding worker and environmental protection during field operations-based analysis of the inventory;  Detail the system of worker supervision and training to ensure all field operations are completed to the highest standards of Health, Safety and Environment 6) The Monitoring Plan would include a combination of indicators and milestones will need to be developed to ensure that the overall effect of the OP reduces risks on the environment and on public health. Typical indicators include;  Tracking of the national risk factor from obsolete pesticides (as defined in the FAO Environment Management Tool kit EMTK Volume 1);  Reporting on spills, leakages, accidents, injuries during safeguarding and disposal Ref: obsolete-pesticides/resources0/en/ Content of the IPMP (ctd..) 7) Environmental and Social Management Training include strengthening the institutions and facilities (e.g., laboratory facilities and training for pesticide trace/residue analysis, implementation of Resettlement Plans). 8) Grievance Redress Mechanism should describe in detail the grievance resolution process especially with inhabitants living nearby by stocks of obsolete pesticides 9) Consultation and participation will take place at a national level with the key stakeholders. For high-risk sites and any sites where input of local communities will be important, e.g., sites with resettlement or significant social impacts, consultations will also take place at the local level. NGOs and civil society organizations (CSO) will be involved in facilitating the process. At all sites with inhabitation and along sensitive transportation routes, the project will carry out an information and awareness campaign to enhance public safety, again involving NGOs and/or CSOs as much as practical. 10) Disclosure; The ESMP, the HSE Plan would be disclosed in country at the national and local levels whenever obsolete pesticides in large quantities are available Thank you for your Patience and Attention Any Questions ?