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Ministère de l'Écologie, du Développement Durable et de l’Énergie
www.developpement-durable.gouv.fr
The French guidance on IED baseline
report
Emilie FAVRIE French Ministry of ecology, sustainable developpment and energy
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French guidance
France worked on a national guideline from 2012 in order to deal with the missing European guidelines
French guidance is based on the French national standard NF X31-620 for environmental consultants on site remediation
Published in February 2014, with a specific
appendixes on waste treatment plan in May 2014 and on rearing in October 2014
The responsibility of producing a quality baseline report lies with the operator.
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Baseline report scope
Baseline reports must consider the area where there is a risk of pollution.
Soil impact are studied only inside the border of the site
However, plums of pollution must be characterised
Number of sampling must be proportionate to the actual, future and past activities and regarding the risk of soil and water contamination
2 criteria are considered for the necessity of a baseline report
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Criteria 1 : relevant hazardous substances
Substances or mixtures that are classified in at least one of the hazard classes defined in Annex I of CLP Regulation
Substances or mixtures are considered as relevant:
If there are currently used, produced or release (past substances are not considered)
Or if those substances will be used when the installation is authorised
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Criteria 2 : possibility of soil and groundwater contamination
Possibility of soil and groundwater contamination regarding to:
The dangerousness of the relevant substances or mixtures
Its chemical characteristics regarding to its capacity to impact soil
and groundwater
It’s the responsibility of the operator to establish if the used quantities present a risk of soil and ground water contamination
Preventive measures are not relevant to avoid the preparation of a baseline report => difficult to guarantee that there will never be an accident or a failure of those preventive measures
No baseline report for gaseous or non-pulverulent solid hazardous substances
Baseline is mandatory if used of priority substances in the field of water policy and/or considered in environmental quality standards from the Water Framework Directive
No baseline if operator prove no risk of contamination considering product quantities and chemical characteristics
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Baseline report content – 5 chapters
Chapter 1 : site characterisation and environmental setting
Chapter 2 : existing data collection and analysis
Chapter 5 : Analysis of the results, interpretation of data and evaluation of the state of soil and groundwater contamination
If available data are not sufficient to determine the state of soil and groundwater
Chapter 3 : Definition of sampling strategy
Chapter 4 : Site investigation and analysis of samples
The methodology is based on the French national standard NF
X31-620 for services related to contaminated sites and soils . It’s
recommended that baseline report is made by a an consulting
company qualified for contaminated sites and soils.
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1: Site characterisation and environmental setting
Site history, environmental setting
Identify potential sources or accident which may have result in presence of the substances in soil and/or groundwater
Analysis of issues and potential impacts
Defined pathway and elaborate a conceptual site model
Differences between historical pollution and current processes to deal with hazardous substances
Elements which must be provided
List of substances used, produced or
emitted and their chemical characteristics
Site history study
Maps, plans
Conceptual site model
BRGM/INERIS
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2: Existing data collection and analysis
Collect all existing data and evaluate if there are relevant
Use all data available (soil and groundwater monitoring, results of remedial works, …)
Check if data are sufficient and representative to produce a baseline report (if so it’s not mandatory to made new investigation)
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3 & 4: Definition of sampling strategy, site investigation and analysis of samples
Groundwater, soil and, if relevant, soil gas sampling
Site specific approach to determined where sample, depending on the probability of occurrence of the pollution
Standard and best practise must be used in order to have reproducible sampling and analysis strategies
All the relevant technical data (measurements, analytical standards, maps, sampling logs…) must be attached to the baseline report
BRGM/INERIS
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5: Analysis of the results, interpretation of data and evaluation of the state of soil and
groundwater contamination Results must be presented with plans and chart according to the
substances found and the location of the pollutant
Uncertainty of the results due to the sampling or the impossibility to access some area must be described
Special demands for sites updating their permit:
Preventive measures must be preserved to avoid any new contamination
No sampling under sealed slab
A substance not described is considered as not present in the soil or in groundwater but might be look for at the cessation of activity
The responsibility of producing a quality baseline report lies with the operator
National authorities do not validate the investigation program
In case of discovery an important pollution, the French contaminated site policies will be applied
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Specificity for some sectors
Specificity for intensive rearing plants : no baseline report (unless heating oil storage tank with capacity storage greater than 50 m3 or non-biodegradable cleaning substances are used)
Specificity for waste treatment plants :
Disposal of non hazardous waste: no baseline excepted if hazardous substance is used;
Disposal or recovery or temporary storage of hazardous waste: baseline for substances identified in the SEVESO campaign and the one already monitored in surface water and/or groundwater;
Hazardous waste incineration or co-incineration plants: baseline for substances monitored in surface water and/or groundwater;
Landfills: no soil sampling under the cells, groundwater sampling according to the existing legislation. If hazardous substances are used => sample in the soil bellow the storage and in the groundwater.
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Still under discussions
How to determine whether there is a significant pollution between the state of the baseline report and site closure ?
How to monitor soil properly ?
How to defined a systematic appraisal of the risk of contamination ?
Those topics are still under discussions in France and we would highly appreciate your feedback
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Thanks for your attention
Any questions ?
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Guidance on the French Environment Ministry web site :
http://www.developpement-durable.gouv.fr/IMG/pdf/Guide_Elaboration_Rapport_de_Base_IED_Dechet_v2-1.pdf