Obtaining an Environmental Permit
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Obtaining an Environmental Permit for a Pulp and Paper Industry
An examination of the past and the present events in the industrial sector indicates that the main driver for industries to improve their environmental performance has been the laying down of specific regulations (Honkasalo, Rodhe and Dalhammar 2005:1). Such environmental regulations (one of which is the issuance of environmental permits to industries that comply with the set rules) have brought about not only the adoption of end-of-pipe technologies (Simila 2002: 1) but also proactive, preventative environmental management and protection strategies (Reijnders 2003). Additionally, when properly designed environmental regulations have also been responsible for increased economic efficiency with environmental benefits, commonly described as eco-efficiency (Ashford 2002).
It is therefore no surprise that members of the European Union came up with the integrated pollution prevention and control decree- known as - “the IPPC directive”- in 1996 in order to harmonize permitting practices in the European Union (EU) and make use of the mentioned benefits of such regulations. The IPPC directive is a practical legislation that makes room for a high degree of flexibility to accommodate diverse administrative styles and application of special scopes as concerns what is included in the permits by member nations (Council Directive 1996).Among the components of the IPPC directive are regulations to ensure eco-efficiency as well as adaptation of best available techniques (BATs) by industrial installations in EU nations (Honkasalo, Rodhe and Dalhammar 2005).
In England and Wales, there are environmental permitting regulations in accordance to sections 2 and 7(9) of, as well as Schedule 1 of the Pollution Prevention and Control Act 1999(a) (Tullo 2010). Environmental Agency acts as the body that oversees environmental regulations in England and Wales along with other supporting bodies and individuals. The previously existing regulations were established in 2007 during which the Pollution Prevention and Control (PPC) and Waste Management Licensing (WML) regulations were combined (The Environment Agency 2011).
However, their scope has since been expanded to encompass radioactive substances, water discharge and groundwater activities in addition to provisions for several directives - the Mining Waste Directive (from 7 July 2009), the Waste Batteries and Accumulators Regulations 2009 (from 5 May 2009) and Discharge Consent (The Environment Agency 2011). On 6 April 2010, the regulations currently in force, Environmental Permitting Regulations (England and Wales) 2010, were introduced (Tullo 2010). According to Schedule 7 part 3 of the Pollution Prevention and Control Act, environmental permitting is aimed at “achieving a high level of protection of the environment taken as a whole by, in particular, preventing or, where that is not practicable, reducing emissions into the air, water and land.”
An environmental permit (EP) is a document prepared by a regulator - either the Environment Agency or one’s local authority (district, borough or unitary council)detailing conditions that have to be followed to prevent one’s business from harming the environment or human health(The Environment Agency 2011). This permit can either be a standard permit or a bespoke permit. There are several of business operations that are described in the EP which lead to a business being described as a “regulated facility” thus warranting the need for the said business to obtain an EP. Examples of such business operations include :Maggot breeding, power generation, incinerators, manufacturing and other industrial activities(food, chemicals, paper, mineral, timber industries), waste management activities, intensive pig and poultry farming, solvent and oil recovery processes and landfill sites just to mention but a few.
The installation activities covered by the environmental pollution prevent control permit can be broadly divided into Part A and part B based on the emissions, capacities and the description of activities undertaken by the installations. These activities covered by environmental permits are classed into three main categories:
- Part A (1) activities: are controlled by the Environment Agency. In this category are waste disposal industries and chemical production.
- Part A (2) activities: are regulated by the local authorities (Borough, district or unitary council) where the installation is based. These activities are similar to those in part A (1) but are characterized by lower threshold sizes which are detailed by the Environmental Health & Licensing Division.
- Part B activities: are similarly regulated by the respective local Council and are typically low scale activities with localized environmental impacts that are covered by the local authorities.
These permits can be acquired from the Environmental Agency website or from the Environmental Health & Licensing Division and all the necessary parts of the form filled in, in addition to the following requirements which are also required in order to get an EP. These are: the application fee, full explanation of the process describing precautions taken to minimise or prevent air pollution, apposite drawings and process diagrams, monitoring, sampling and measurement of air emission techniques plus an assessment of probable environmental consequences of any air emissions, a statement of how the proposal meets the 'Best Available Techniques Not Entailing Excessive Cost (BATNEEC) objectives, and lastly any other specifically requested information.
To facilitate a better comprehension of the EP obtenance process, an in-depth exploration of the techniques involved in this process namely environmental risk assessment, life cycle assessment, environmental management systems and energy management is done. For the purposes of this report, the practical examples of the application of these techniques all refer to the acquisition of an EP for a manufacturing site for a pulp and paper industry. Blazejczak and Edler (2000) observe that the pulp and paper industry is a capital and resource-intensive industry that contributes to many environmental problems, including global warming, human toxicity, eco-toxicity, photochemical oxidation, acidification, nutrification, and solid wastes.
According to information contained in Section 6.1 Part A (1) of Schedule 1 of the Environmental Permitting Regulations(EPR) which is corroborated with information on the Environment Agency website; the activities carried out in a pulp and paper industry (making pulp, paper and board in an industrial plant, as well as associated activities such as de-inking that may result in the release of a substance as specified in paragraph 7 of Part 1 of EPR) warranted the installation to be classified as a regulated facility- Regulatory Guidance series number 2-(The Environment Agency 2011). Consequently, the pulp and paper industry was required to have a bespoke environmental permit to operate its activities. An application for this form to get an EP was obtained from the application forms page on the Environment Agency website. From this same site, technical guidance on how to fill this EP application form in compliance with environmental permitting regulations was obtained.
In accordance to this environmental permitting guidance, a complete set of proposals for all the intended activities of the pulp and paper industry were developed. This included coverage of the quantities, nature as well as the sources of our installation’s foreseeable air, land and water emissions into the environment. This enabled us meet the requirements of Section 6 of the environmental permit application form. Pursuant to this, part 8 of the EP application form required us to conduct a risk assessment that the activities in our pulp and paper industry proposals posed on the environment.
Environmental Risk Assessment
Europa (2009) defines environmental risk assessment (ERA) can be described as the process by which the likely significant effects of a project or development on the environment are identified, assessed and then taken into account by the competent authority in the decision-making process. In this process, a systematic evaluation of the risks posed by the pulp and paper industry’s emissions into the environment (water, land and air) was done. The pulp and industry’s management team contracted EnviroGulf Consulting Company as a competent environmental consultant to help in the environmental risk assessment. This ensured the assessment was done in using techniques approved by the Environment Agency increasing the chances of a positive review necessary for the obtenance of the EP. The steps involved in the ERA were as follows:
Preliminary Risk Assessment
In this initial step of the ERA technique, the environmental consultancy firm gathered background information and vital data to help it in the preliminary assessment of the risk posed by the pulp and paper industry. This was done by an inspection of the site for the installation, some low scale sampling in addition to reviewing available data and background information on the processes involved in a pulp and paper industry.
The data collected included legal data (customary laws, local laws and international laws and regulations), biological data (ecosystems involved, the plants and wildlife), socio-economic data (the infrastructure, patrimony, land use matters) and physical data(climate, soil, water) as prescribed by the Food and Agriculture Organization(1996). This was done so as to make an informed decision on whether to end the investigation since no risk was shown or to confirm contamination and scheme for subsequent investigations on the site to pinpoint pathways of exposure as well as the target populations.
A Risk is characterized as a measure of the probability that an adverse effect will occur; a function of both the concentration/dose and the intrinsic capacity of the contaminant to bring about an adverse effect in scenarios involving chemical contaminants (EnviroGulf Consulting 2007).
The environmental risks posed by the establishment of the pulp and paper industry were determined based on; the type (whether it was direct or an indirect risk resulting from a knock-off effect), the magnitude of the risk(could be major, minor or negligible), the reversibility of the risk especially pertaining to economic impacts and the absoluteness of the adverse effects and the duration of occurrence of the adverse effects pertaining to whether the impacts would only occur during the construction phase or those probable to come after a longer time span( Food and Agriculture Organization 1996). For the risks which were determined to be direct, irreversible, major in magnitude and likely to occur over long periods of time, appropriate measures to mitigate them were proposed.
The paper and pulp industry was assessed and noted to have the potential to pose several threats on the society and environment in several ways that are described below. First, there were environmental risks associated with the production and the exploitation of raw materials used in the pulp and paper industry. Bearing in mind that paper is made from natural fibres got mainly from wood and some recycled materials, the risk of environmental impacts of deforestation had to be determined.
Additionally, there was a risk of disrupting the ecosystem by the effects the harvesting of the forest would have on the flora and fauna that relied on the forest and this was also incorporated into the risk assessment. The management had plans for reforestation which were designed with the professional help of the environmentalists from the EnviroGulf consulting firm. The reforestation plans factored in the associated effects of risks brought about by invasive species, soil erosion and depletion, sensitivity to fires and effects on the balance of the ecosystem. The second area of environmental risk arises from the sludge that remains after processing paper and is composed of 30-50% solids consisting of short fibres, fillers and ink from the de-inking process (Ogilvie 1992). This sludge may contain low levels of heavy metals including cadmium, nickel, lead which if not disposed appropriately may accumulate and be transferred to other receptors and cause harm through bioaccumulation and biomagnification.
The third area of risk was from the actual industrial activities involved in making the pulp and eventually, paper by the installation. These impacts were broadly classed as emissions into the air, water and land. The major risky emissions into the air from the pulp and paper industry were noted to be odours (sulphur dioxide and other sulphur gases), particulate matter (lead, mercury, cadmium, arsenic and zinc), smoke, vapours as well as noise.
The other environmental risk of this installation was on water; both in terms of the enormous quantities of water used in this heavy industry and the effluents discharged into waterways (Martin & Ehrenfeld 1993). The discharge of toxic organochlorines into water - dioxin and over 300 other chlorine substances identified in the discharges of bleached pulp mills as characterized by many including Enell (1992) and Environment Canada (1991) – was noted to pose a risk on water (toxicity, odour, biochemical oxygen demand, temperature change, suspended solids), wildlife and humans over diverse periods of time and with potential severe adverse effects. Last but not least, the assessment revealed risks of the industrial emissions on soil pertaining to raw material production, exploitation, during construction as well as indirectly via sedimentation in water sources and steep slope erosion.
In all these scenarios the level of the particles emitted and deposited, and the toxicity of the gases emitted were measured under normal working conditions and varying modeled scenarios as specified in EPR-H1. The figures got were compared with Community EQS standards, statutory and non- statutory obligations, environmental action levels (EALs) and other environmental and regulatory parameters defined in EPR –H1 to classify the environmental risk expected.
In addition, the possible toxicological hazards presented by chemical pollutants were ascertained and summarized as toxicity profiles for each notable pollutant in the process of hazard characterization. Moreover, as part of the ERA process, scientific data as well as toxicity database information were used to establish the associations between observed levels of pollutants and specified biological responses in the dose-response assessment.
Next, an exposure assessment was done to estimate frequency of exposure of the receptor populations via air, land or water with the help of site-specific exposure modeling. Then the degree of such exposures on the environment and the health of people, risk characterization, was done with the weight of evidence approach employed to identify the most defensible value.
Finally, using probability analysis and quantified varying individual assumptions (EnviroGulf Consulting 2007) the uncertainty of the risk assessments was measured. Lastly, by way of probabilistic risk assessment and statistically analyzing concentrations of pollutants, an ecological risk assessment was done. This facilitated comparison of different pollutants and determination of whether their levels exceeded established toxic thresholds.
Life Cycle Assessment
A life cycle assessment (LCA) is a comprehensive environmental accounting tool that covers the whole life cycle of a product or service (from raw material extraction, to manufacturing, packaging, distribution, use and end of life) with well-established procedures and methods that are governed by specific rules and standards(Forest Products Association of Canada FPAC 2010).
The International Organization for Standardization (ISO) defines LCA as the compilation and evaluation of the inputs and outputs and the potential impacts of a product system throughout its life cycle (ISO 2000).The standards used are typically those developed by the ISO that divides LCA into four phases namely goal and scope definition, inventory analysis, impact assessment and interpretation of results (ISO 2000).
FPAC (2010: 2) underscores the importance of LCA in environmental management noting reporting that that the United Nations Environmental Programme (UNEP) defines Life Cycle Management (LCM) as “an integrated concept for managing the total life cycle of products and services towards more sustainable consumption and production patterns.” As such, though a complex analysis tool that needs a proper understanding before it can be effectively employed, the LCA is an effective tool in environmental management practices such as the issuance of environmental permits.
The life cycle assessment tool has also been used to drive performance improvements in industries by helping prioritize environmental investments, helping in cutting costs, identifying alternative and more effective technologies used in the industry’s activities, increasing synergy of diverse installation activities, software development and define key performance indicators (KPIs) that monitor progress and channel vital information to stakeholders(FPAC 2010). Additionally, it is useful in effective marketing communication, meeting the expectations of stakeholders and in ensuring the industry meets with established regulations.
Goal and Scope definition
In this step, the anticipated application, audience and the reasons for carrying out the assessment are outlined (Lopes et al. 2002). In our case, the LCA on the pulp and paper industry was conducted to facilitate the identification of the most significant contributors to environmental pollution and consequently instigate corrective measures to ensure eco-balance and eco-efficiency. Additionally, it would help our company assess the effectiveness of the technologies it had employed in ensuring sustainable environmental conditions for the installation and those around it.
The audience included the Environmental Agency, other environmental organizations, staff, shareholders, the immediate community and any other interested stakeholders. Pertaining to the scope of the LCA, the product being studied was printing and writing paper produced using eucalyptus pulp from Canada and precipitated calcium carbonate (PCC).
The system being studied produces pulp, writing and printing paper using kraft mills. Its boundaries cover such subsystems as Eucalyptus globulus forests, pulp production, production of writing and printing paper, final disposal, chemical production, electricity production, transport and fuel production. The functional unit, allocation procedures based on ISO regulations, the impact assessment methodology and data quality requirements were also defined.
After all these processes, the data was entered into TEAMTM LCA software package and computer modeling set up allow enabling the computation of environmental flows of inputs and outputs and their classification into impact.
The inventory analysis involved a collection and quantification of the entire inputs and outputs of the system boundaries described above. Among the inputs was a list of all the raw materials as well as energy sources while the outputs consisted of the air, water and land emissions.
The next step was the categorization of the environmental flows into impact categories based on indicators such as abiotic depletion, human toxicity, acidification, climate change, eutrophication, ecological toxicity, photo-oxidant smog formation fossil fuel depletion and stratospheric ozone depletion (FPAC 2010). With expert help from the environmental consultants the environmental flows were translated into two impact categories, namely endpoints and midpoints. This impact evaluation followed a cause-effect chain starting at the inventory flows to at least midpoint indicators before progressing with further cause-effect modeling to evaluate endpoint results. Additionally, the LCA reports covered life cycle inventory data encompassing water, minerals, wood and energy consumption.
Interpretation of Results
Following the impact assessment, the results were analyzed in line with the aforementioned goals of this life cycle assessment.
Environmental Management Systems
An environmental management system, EMS, is described as a structured framework for managing an organization’s significant environmental impacts (Baxter 2004). Environmental management systems can assist in the management, evaluation and improvement of environmental performance in a verifiable manner. An EMS can aid an installation in its efforts to reduce emissions, meet environmental regulations, ameliorate their resource efficiency and lower bottom line costs (The Environment Agency 2011). This would help legitimize the request of an industry to be granted an environmental permit by showing its commitment to being responsible for the effects on the environment that the industry would bring and to sustainable working environments.
The EMS used by an organization may be informally developed by the organization itself, or adopted from recognized national or international standards that outline the requirements of an EMS and also provide for external assessment and certification of such systems. It should be designed so as to cater for the nature, complexity, size and risks posed by the industry. Preferably, companies should adopt recognized standards such as the EU Eco Management and Audit Scheme (EMAS), ISO 14001, or the British Standard BS 8555(The Environment Agency 2011).
In accordance to the Environmental Agency’s recommendations in the Operator and Pollution Risk Appraisal (OPRA) scheme, the pulp and paper industry management adopted a formal EMS – the Institute of Environmental Management and Assessment (IEMA) Acorn Scheme - which is a phased programme centered around the British Standard BS 8555 (Businesslink 2011) and that allowed the installation to achieve accredited certification to ISO 14001 and registration to the EU’s Eco-Management and Audit Scheme ,EMAS,(Baxter 2004).
Moreover, the scheme was chosen because IEMA was an accredited by the United Kingdom Accreditation Services (UKAS). With the help of the environment consultancy firm hired, the following were the phases of the EMS adopted and implemented by the pulp and paper industry. They were based on the Denning Cycle( from Denning Cycle Plan Act Do Check ISO 14001) of planning what one is going to do, doing what one planned to do, checking to ensure that one did what was planned and lastly acting to make improvements(IEMA 2011).
The primary phase involved securing the commitment to and the participation of not only the top management but also other employees within the installation to environmental management and performance improvement initiatives. It also involved a baseline assessment that pinpointed the major environmental issues and opportunities. Based on this assessment drafts of the pulp and paper industry environmental policies were produced and communicated to staff to begin implementing.
The second phase involved the identification of the legal environmental regulations as well as other requirements that the pulp and paper industry needed to comply to. These were sourced from the NETREGS website that provided NETREGS, an internet based tool developed and operated by the UK’s environmental regulations (NetRegs 2011). Additionally, compliance control measures were developed and implemented as was also the case in situations where these control measures were not adhered to. The commitment to comply with these requirements was encouraged, regularly evaluated and enforced appropriately.
The third phase involved the development of the objectives, the targets and the programmes of the pulp and paper industry. The goal of this phase was the institution of the core elements of a functional EMS and the development of a structured framework for ongoing systematic environmental management and performance improvement as advised by the IEMA (2011).
The fourth phase covered implementation as well as the operation of the environmental management system in the installation. This involved the enhancement of the management elements of the EMS thus supporting the effectiveness progressing operation in addition to ascertaining that variations that influence the pulp and paper industry could be integrated into the system without resulting in performance fluctuations. Moreover, it also aided the meeting of specific requirements of the ISO14001 and EMAS regulations.
The end of the next phase, the fifth one, was a fully operational EMS in the installation. This phase covered the checking and auditing of the EMS and carrying out a management review. IEMA (2011) notes that this resulted in closure of the continual improvement loop for the installation’s environmental performance, and aligned it with the full requirements of ISO14001 and EMAS.
Lastly, the sixth phase laid out the preparatory stages for the acknowledgment of the EMS that would facilitate the industry’s EMAS registration and ISO14001 accreditation. As required by the EMAS, an environmental statement was issued by the pulp and paper industry management.
Another very critical area to be examined before an industry is granted an environmental permit is how the industry plans to source, utilize and manage its energy sources in a sustainable and environmentally safe way. The pollution and prevention control part A is concerned with among many other issues, energy efficiency. Indeed some of the environmental issues that the best available techniques (BAT) addresses are matters pertaining to energy management in an efficient, profitable and least environmentally harmful manner.
Among the chief challenges that industries currently face are the issues of energy saving and the conservation of resources, especially compounded by stricter anti-pollution legislation, heightened competition, globalization efforts, and rising electricity prices. Consequently, pulp and paper industries whose energy demands account for around ten percent of the total production costs have been forced to seek innovative solutions (Siemens AG 2011). Although in many industries people know that energy is a critical and often unpredictable production factor, very few act to manage it, observes Wadyalkar (2010).
Hart, Turner and Kennedy (1997) defined energy management as the judicious and effective use of energy to maximize profits (minimize costs) and enhance competitive positions. Some of the goals of energy management include minimizing environmental effects, minimize energy costs as well as wastes while maintaining production and to achieve and maintain optimum energy procurement and utilization. The management of energy was crucial to the top management of the pulp and paper industry and to oversee this task, an energy management cell (EMC’s) was formed.
To define and carry out effective energy management in a systematic manner at the pulp and paper industry, the EMC recommended and facilitated the carrying out of an energy audit. The audit was aimed at identifying all the energy streams in the industry, measuring energy usage as per its discrete functions, and balancing the total energy inputs with its use. This energy audit was executed in two parts namely a preliminary audit and a detailed audit.
The preliminary audit of the pulp and paper industry covered several issues in addition to setting a reference point onto which other audits would be based on. One of such was the establishment of energy consumption in the organization (total primary energy consumption) and an estimation of the scope for saving, with the help of such tools as the LCA. Another issue was an identification of the easiest areas for improvements at no or low costs. Lastly, it enabled the singling out of which areas of the paper and pulp industry to be studied in depth. All this was done using easily-available existing data.
Pursuant to this, detailed audit was carried out. In this audit, all the energy systems in the pulp and paper industry were comprehensively scrutinized to determine energy balance and the interactive effects of all the installation activities.
As a result, the industry was able to account for all the energy utilized by the major equipments as well as establish the energy costs and savings. This audit was carried out in three phases namely the pre-audit, the audit and the post-audit phases. The pre-audit phase involved the organization of resources and familiarization with the detailed audit plans prior to it being carried out.
In the audit phase, all the primary data needed was collected and all the other scheduled activities done in detail. Finally, in the post-audit phase, the implementation and actual follow up on the environmental management plans was done based on primary and secondary data gathered as well as the input of the consultancy firm experts.
Worth noting was the great need of electricity in many systems of this industry and the useful role of fuels in various processes. This presented the opportunity of seeking renewable energy sources and using decentralized energy management systems and modern technologies to enable the pulp and paper industry to lower energy consumption, exploit it more efficiently and lower costs. Based on the energy audit; it was observed that less energy was needed to produce recycled paper in comparison to that used in producing virgin paper from raw pulp, a concept supported by others such as Koay (1992), and that many environmental and financial benefits could arise from producing more recycled paper thus this prospect was considered.
The pulp and paper industry is a mature industry (Kuik 2006) characterized by three main producers, pulp mills, paperboard mills and paper mills. As a lucrative industry, many investors are constantly being drawn into this sector, the threats to the environment that it offers notwithstanding. Paper and pulp industries pose numerous environmental threats due to their infamous air emissions (especially organochlorines and carbon dioxide- with the associated threat of global warming) and noise pollution, the land and water emissions, the threats to biodiversity and ecosystems, exhaustion of non-renewable sources of energy, matters pertaining to disposal of wastes and used paper to mention but a few.
Consequently, appropriate local and international regulations must be established and enforced to maintain sustainable environments. The need for environmental permits to this end can thus not be overemphasized and the vital role of the techniques highlighted above in the obtenance of an EP is clear and justified. In conclusion however, the crux of the matter is a commitment to eco-efficiency from all industries which an EP cannot necessarily guarantee and neither should an EP be seen as a license to conduct activities without responsible exploitation of the environment and its resources.
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