B2.7 Operational Implications of Prescribed Processes
There are several operation implications if prescribed processes. In order to operate an installation, the applicant must demonstrate that they will manage the environmental management of the installation, including:
- Meeting emission limits for pollutants.
- Waste Management (waste elimination or minimisation).
- Energy Efficiency.
- Pollution prevention (to air, water and land).
- Monitoring of emissions data.
- Prevention of accidents and incidents.
- The environmental impacts of closure and decommissioning.
- The application of BAT.
Once a permit has been obtained, the operator must conduct monitoring to demonstrate that the permit conditions are being met.
The regulators will also conduct their own monitoring and conduct inspections to ensure compliance.
These requirements mean that the environmental management of the installation must be considered at every stage, throughout every stage of the process. Good environmental management can reduce administrative burden and result in financial benefits. However, a significant problem regarding the enforcement of prescribed processes if the subjective nature of the term BAT.
Enforcement bodies and organisations have differed in their interpretation of the elements within BAT:
Best:
What constitutes ‘best’ will differ from installation to installation, depending upon the specific nature of the processes. More importantly, whether what is considered best is actually sufficient, is also subjective. Regulators may not have the necessary knowledge to understand what is the ‘best’ technique.
Available and Technique:
To be available technology (the technique) must be already developed under economically and technically viable conditions. They do not have to be available in the country where the installation is based and they do not necessarily need to be proven in that particular sector. To be ignorant of technological developments, and therefore ignorant of what is available, is no defence.
It is therefore of paramount importance that organisations develop and maintain a close working relationship with their enforcing body, to ensure that all parties are content that sufficient actions have been taken.