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ENVIRONMENTAL PERFORMANCE ENHANCEMENT PROGRAMMES AND MANAGEMENT SYSTEMS OF INDUSTRIAL ENTERPRISES
Abstract
In Russia, the national Integrated Pollution Prevention and Control (IPPC) Act introducing the concept of Best Available Techniques (BAT) was adopted in 2014. Since then, applying BATs and complying with BAT-associated Emission Levels (BAT-AELs) has become an issue of great importance for the industries concerned and has implied obligations at two levels. Firstly, the Ministry for Industry and Trade (MIT) and the Ministry for Natural Resources and Environment (MNRE) had to set out the appropriate process for drawing up and reviewing sector-specific and inter-sectoral Reference Documents on BAT (BREFs) and respective sector-related BAT-AELs. Secondly, regional environmental authorities (MNRE units) and operators have to compare performances of industrial installations with the information contained in BREFs and established in special MNRE orders approving sectoral BAT-AELs. In total, there are over 7,000 IPPC installations in Russia (called Category I installations); 300 of them (largest polluters) have to demonstrate the compliance with the new IPPC/BAT legislation in 2019-2022. It is expected that at least 120-130 installations of 300 are not fully compliant with the new BAT-AEL requirements and will therefore be obliged to work out and implement Environmental Performance Enhancement Programmes (EPEPs). EPEPs contain sets of technological (primary), technical (end-of-pipe) and organisational solutions aimed at achieving applicable BAT-AEL requirements. According to the legislation, an EPEP has to be implemented in 7 years maximum; during this period the installation concerned can be operated under ?softened? requirements; after 7 years operators have to demonstrate that their emission limit values (ELVs) are compliant with sectoral BAT-AELs. At the installation level, the decision on working out an EPEP is made as the result of the self-assessment (internal technological audit and Environmental Management System audit for which applicable BATs and BAT-AELs are used as the priority criteria). BAT expert support is needed at this stage since most operators are not yet experienced in BAT-related requirements. When a draft EPEP is formed, it has to be submitted to the Inter-Departmental Commission managed by MIT. This Commission (consisting of the representatives of interested authorities and supported by BAT experts) makes decisions on the quality of EPEPs and thereby issues ?semi-permits? for not fully compliant installations. These documents should be included in the applications for integrated environmental permits (IEPs) and in order to prove that operators are prepared to implement EPEPs and achieve full compliance with BAT-related requirements in time.
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