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Notes of EA/ESA Pollution Inventory Meeting
24 January 2003
ESA industry representatives met with Dr Ian Whitwell of the Environment Agency·s Pollution Inventory Unit on 24 January 2003 to discuss issues of concern regarding reporting to the Pollution Inventory (PI) raised by Members at an industry meeting on 7 January. The issues of concern and the EA·s responses are summarised below.
1. Inconsistencies in the dissemination statutory notices
Clarification was required from the EA that any sites which did not fall under the PPC regime would not be required to report to the PI and that any notices issued to such sites by the EA would be revoked.
EA's response:
The EA acknowledged that its databases were inaccurate and would be relying on information from operators to correct existing errors. In instances where revocation of incorrect notices was required, operators were requested to email the details to Rachel Cooper. A letter confirming the error would follow, rather than a formal revocation from the EA. Where an operator genuinely believed that a site would not fall under the PPC regime, the EA confirmed that it would generally accept this on receipt on an email to Rachel Cooper. The EA stressed that operators should adopt a common sense approach to reflect the emissions of a site. Ideally therefore, sections of closed landfill, adjacent to active sections, should be required to report because these sections are still active in their release of emissions. The EA explained that the expectation was for operators to report to the best of their ability and if a few anomalies arose, they would not force the issue at this stage. It was stressed that operators should report against the license numbers issued to sites.
2. RGN16
Clarification was required from the EA regarding the definition of installation under RGN16 since uncertainty regarding boundaries and separation of closed areas might remain until after the PI reporting deadline has passed. Clarification was also required on the volume of waste which could be excluded from PI reporting.
EA's response:
The EA reported that it was not focussing on the RGN16 issue in detail and acknowledged that this was beyond the expertise of the EA·s PI group. It was suggested that this issue be taken up with Cyril McQuillan in the EA. (Note: ESA is already in discussions with Cyril McQuillan and colleagues on RGN16).
3. GasSimLite model
A common position with the EA was required regarding the limitations of the GasSimLite model. Operators had experienced a significant underestimation in the volume of gas generated using GasSimLite compared to in-house models.
EA's response:
The EA stated GasSimLite was being offered as a tool but that there was no requirement on operators to use this as a model. The EA accepted that the operator knew best which model to use to most accurately report gas emissions from a particular site. Operators were invited to submit comments on problems experienced with the EA·s models. (Note: It was agreed that this should be extended to include operators· collective views on the PI reporting process, after the reporting deadline had passed.)
4. Leachate estimator
Operators required the latest version of the EA·s leachate estimator.
EA's response:
The EA provided the latest (final) version, which is now available on the PI website and includes 26 substances as opposed to 15 substances previously.
5. Electronic reporting
Operators appreciated the advantages both for the EA and industry of electronic PI reporting but agreed that this would be a company-specific choice.
EA's response:
The EA reported that electronic reporting would be available on the PI website but accepted that there were some limitations, especially where operators were reporting on multiple sites. The EA reassured operators that this process was secure in that it was password protected and company specific. Should a company have difficulty with the XML format, the EA suggested that if the required IT expertise were available, a form could be devised using the XML specification. Alternatively, a paper copy could be printed and submitted manually. Operators were reminded that the forms could not be emailed because signed duplicate copies were required.
6. EA vs SEPA reporting requirements
Operators were concerned that the EA·s PI requirements appeared to be far more stringent than those of SEPA, which seem to be based on EPER requirements. Clarification was required from the EA on why the reporting requirements for England and Wales were so onerous.
EA's response:
The EA explained that there had been a much longer history (four years under IPC) of PI reporting in England and Wales, whereas SEPA had had no reporting requirements in the past and its immediate aim was therefore to achieve the minimum in meeting the EPER reporting requirements. It was likely however that SEPA would report more fully in the future. The EA surmised that emissions reporting in Northern Ireland would also most likely be based on the EPER requirements at this stage.
7. Double counting
Clarification was required from the EA on whether PI reporting for civic amenity sites and solid waste transfer stations was required and if so, whether this would result in double counting. There was currently no programme for the passage of these facilities into the PPC regime. The same issue could apply to liquid waste transported off-site.
EA·s response:
In the case of transfer stations, the EA stated that these facilities had the potential to fall under PPC if more than 10 tonnes per day hazardous waste was received · operators were advised to email their views to Rachel Cooper for consideration by the EA. In the case of tankering liquid wastes off-site or discharging down sewers, the EA advised that sewage treatment works were required to report to the PI in their own right.
8. Data processing
Clarification was required from the EA on how the data provided by operators was to be processed and whether operators would have the opportunity to review and correct any errors prior to the data being published.
EA's response:
The EA clarified that the data provided by operators would be captured. The EA expected to notify ESA in May/June that the data was available for a period of 2-4 weeks for checking by operators and they estimated that this data would then be available live on the PI website around August.
9. Context in which information would be used
Clarification was required from the EA on how the data would ultimately be used. Operators were concerned about the context in which the PI data submitted by the industry would be placed and the level of auditing the data would be subjected to.
EA's response:
The EA explained that the data would appear on the PI website against the relevant company. There would be no restricted access. The EA was trying to place the data in context on the website using data fact sheets. In addition, companies were welcome to submit their own weblinks. The data currently served the purpose of an information tool, for example, the data could be aggregated by the EA to establish trends or used to inform answers to Parliamentary Questions.
10. Voluntary questions
Clarification was required on how the EA would use the information provided in response to the voluntary questions in the PI reporting form.
EA's response:
The EA explained that the voluntary questions originated from the EPER reporting form. The EA thought that the information might be beneficial to the industry in terms normalisation of data for example, substantial emissions might result from a very large site. The EA would clarify whether this information would appear on the PI website.
Participants:
David Savory (Chairman) · Biffa
Simon Rutledge · Biffa
Jim Rushen · SITA
Graham Watson · WRG
John Weetman · Shanks
Debbie Dorin · ESA
Ian Whitwell · Environment Agency
Apologies:
Charlie Corbishley · Environment Agency
Annette Martin · Norfolk Environmental Waste Services
Contact:
The primary point of contact in the Environment Agency Pollution Inventory team is Rachel Cooper. 
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