Management of environmental procedures
Industrial activities must carry out various mandatory environmental procedures, established by the current legislation. Depending on the activity carried out in the facility, and its specific characteristics (example: annual amount of hazardous waste originated, characteristics of pollutant emissions rejected into the atmosphere, existing residual effluents, etc.), the plant must carry out the procedures that are in application.
TANDEM HSE can help you in the management of the environmental procedures, by taking care of the following administrative processes:
Industrial activities listed in the Registry of industrial waste producers, according to the Decree 93/1999, of April 6, about waste management procedures and to the 88/2010 one that modifies it, are obligated to present an annual declaration of industrial waste (DARI).
That declaration must be presented annually before March 31st, of the current year.
In the case of a waste management activity, you must present the specific annual declaration model to DARIG managers.
The packing companies and/or the ones responsible to market and distribute the packaged products must inform the competent organizations of the autonomous community where they are established, about the quantity of packages and packaged products placed in the market during the previous year, indicating as well which of them are reusable.
This information is communicated to the government through the presentation of the Annual Packaging Declaration (DAE). A single DAE should be made for the production centers that operate under the same CIF, instead of a declaration for each center.
According to the data presented in the DAE, the company will be obligated or not to present a packaging waste prevention business plan (PEP). For this reason, the accuracy of the data entered in the DAE is very important.
That declaration must be presented annually before March 31st, of the current year.
Packaging waste prevention business plans (PEP) aim to reduce the amount of packaging waste, generated by the marketing of a product by the industries, by planning a series of measures established by the industry itself. These plans must be approved by the competent body of the autonomous community where the measures provided for in the plan are implemented.
What Should be Included in the PEP?
According to the article 3 of Royal Decree 782/1998, which details the regulation for the enforcement of the packaging law are obligated to define a prevention business plan the companies that make packaging and during a calendar year take out a quantity of packaged products, capable of generating packaging waste in quantities greater than the following:
- 250 t, if it is exclusively about glass
- 50 t, if it is exclusively about steel
- 30 t, if it is exclusively about aluminum
- 21 t, if it is exclusively about plastic
- 16 t, if it is exclusively about wood
- 14 t, if it is exclusively about carton or composite materials (like beverage cartons)
- 350 t, if it is about different materials, and none of them exceed, individually, the above quantities.
Companies that generate more than 10 tons of dangerous waste per year, regardless of their industry, must prepare a study for the minimization of dangerous waste.
Through this study, companies establish various actions that tend to reduce dangerous waste either in quantity or in danger, for example actions related to process changes, internal recycling or the adoption of good practices.
This study will be presented every four years.
There are different types of discharges for which a prior administrative authorization by the competent basin agency is necessary. They must request authorization to discharge wastewater:
- The physical or legal person who wishes to make a discharge to a public wastewater treatment plant (WWTP) by means of a tank truck.
- The physical or legal person who wants to carry out a wastewater discharge to a public WWTP through the sewerage network. The entity in charge of the management of the different treatment plants is in charge of establishing the methodology to carry out this procedure, as well as the documentation and information to present.
The physical or legal person who wants to carry out a discharge of sewage to sea or public channel.
The water use and pollution declaration (DUCA) is a declaration about the consumption and the quality of the wastewater discharge, that the industries or similar companies must present to Agencia Catalana del Agua (Catalan Water Agency).
Through this declaration, the government will determine the amount of the water canon, a fee to be paid for the establishment destined to the study, control, protection and improvement of the receiving environment.
Who should submit the DUCA?
All industries and similar users with an annual volume of water exceeding 1,000 m3, and whose activity is included in sections C, D, E and groups A032, E360, E383 and J581 of the Catalan classification of economic activities (CCAE- 2009).
As well as users who, despite not meeting the above requirements, receive an express requirement from the Catalan Water Agency to do so.
This declaration is valid for four years, counting from the date to which the submitted data belong. Its renewal must be requested during the fourth natural quarter of the last year of validity.
Notification of Installations Subject to RD 117/2003 and Preparation of the Solvent Management Plan (PDGD).
Those industrial installations doing any of the activities included in Annex I of the Royal Decree 117/2003, from January 31, on the limitation of emissions of volatile organic compounds due to the use of solvents in certain activities, exceeding the solvent consumption thresholds established in annex II of the same decree, are subject to compliance with that Royal Decree.
These establishments must be registered as facilities affected by Royal Decree 117/2003, through administrative notification and will be required to prepare an annual solvent management plan.
Through the presentation of the solvent management plan, compliance with the emission limits established for these activities is evidenced before the government.
The solvent management plan for each year will be submitted before March 31 of the following year.
TANDEM HSE offers you are a service for the crafting of the yearly solvent management plan. In addition, in case the installation does not respect the established emissions limits from Royal Decree 117/2003, we can help you to fix the situation.
Preliminary soil report.
The companies with related activities in Annex I Royal Decree 9/2005, from January 14, which establishes the relationship between potentially polluting soil activities and the criteria and standards for the declaration of contaminated soils, are required to remit to the competent body of the corresponding autonomous community, within a period not exceeding two from the beginning of the activity, a preliminary status report for each of the soils in which said activity is carried out, with the minimum scope and content which is included in annex II of said legal provision.
Likewise, companies that produce, handle or store more than 10 tons per year of one or more of the substances included in Royal Decree 363/1995, from March 10, that approved the regulation on notification of new substances and classification, packaging and labeling of dangerous substances, and storage of fuel for own use according to Royal Decree 1523/1999, from October 1, which modifies the regulation of oil facilities, approved by Royal Decree 2085/1994, of October 20, and the complementary technical instructions MI-IP03, approved by Royal Decree 1427/1997, of September 15, and MI-IP04, approved by Royal Decree 2201/1995, of December 28, with an average annual consumption exceeding 300,000 liters and with a total storage volume of at least 50,000 liters.
Situation Report for Substantial Change
When the installations proceed to substantial changes in regard to the data previously stated in the preliminary situation report, which could increase the possibility of causing contamination of the subsoil or groundwater or modify the possible points of existing contamination, it must submit a report of the substantially changed situation in order to update the declared data.
Periodic Situation Report
Establishments where potentially polluting activities are carried out, required to submit the corresponding preliminary situation report according to article 3 of Royal Decree 9/2005, must also submit periodic situation reports.
It is the responsibility of the autonomous communities to establish both the periodicity and the content of such situation reports. The stipulated periodicity will count from the date of presentation of the preliminary situation report or, if any, from the presentation of the corresponding status report for substantial change.
More About the Thematic Record Books of Emitting Sources
In accordance with the provisions of article 8 of Royal Decree 100/2011, of January 28, which updates the catalog of potentially polluting activities of the atmosphere (CAPCA), companies must keep duly updated, according to the procedure, contents and formats established by the competent body, a record that includes at least data related to the identification of each activity, of each emitting source, and of its operation, emissions, incidents, controls and inspections.
To comply with this legal requirement, all emission sources emitting into the atmosphere, including those of non-systematic emission, classified as group A, B, C or “—” sources according to said catalog (CAPCA), which belong to installations classified as A, B or C of the CAPCA, must have an emission record book.
The sources in which emission measures must be made, either by regulations or because their environmental permit is so established, must also have a record book.
The sources that are not in the aforementioned assumptions, according to the catalog of potentially polluting activities of the atmosphere (CAPCA) regulated in Royal Decree 100/2011, of January 28, do not have to maintain a record book.
TANDEM HSE can help you with the management of every environmental process mentioned above.