UNDP/GEF Danube Regional Project
Strengthening the Implementation Capacities for Nutrient
Reduction and Trans-boundary Cooperation in the Danube
River Basin
FINAL REPORT
Project Component 1.5: Industrial reform and the
development of policies and legislation towards the
reduction of nutrients and dangerous substances
June 18, 2004
Prepared by:
Authors: Stanislav Kosina, Tom Owen
Danka Jassikova-Thalmeinerova,
Final Report: Industrial reform and the development of policies and legislation towards the reduction
1
of nutrients and dangerous substances
Table of Contents
Abbreviations .................................................................................................................................. 3
Executive Summary ........................................................................................................................ 5
For the legislation and policy analysis there are the following recommendations........................ 11
1. Introduction and Study Process............................................................................................. 13
Study Process ...................................................................................................................... 13
2. EMIS Inventory......................................................................................................................... 16
2.1 Objectives of EMIS inventory....................................................................................... 16
2.2 Current status................................................................................................................. 17
2.2.1 Compilation of data in the EMIS inventory........................................................... 17
2.2.2 Parameters in the industrial component of the EMIS inventory ............................ 18
2.3 Gaps in the EMIS inventory.......................................................................................... 18
2.3.1 Data Gaps ............................................................................................................... 18
2.3.2 Procedural Differences........................................................................................... 20
2.3.3 Quality assurance ................................................................................................... 20
2.3.4 Financial Support ................................................................................................... 20
2.4 Recommendations to up-date the methodology of the EMIS inventory....................... 20
2.4.1 Strategic Recommendations................................................................................... 20
2.4.2 Operational Recommendations .............................................................................. 21
2.4.3 Next Steps .............................................................................................................. 21
3. Policy and Legislation ............................................................................................................... 23
3.1 Methodology ................................................................................................................. 23
3.2 Policy Framework ......................................................................................................... 23
3.3 Country Profiles ............................................................................................................ 24
3.3.1 Bosnia-Herzegovina ............................................................................................... 24
3.3.2 Bulgaria .................................................................................................................. 30
3.3.3 Croatia .................................................................................................................... 33
3.3.4 Czech Republic ...................................................................................................... 38
3.3.5 Hungary.................................................................................................................. 40
3.3.6 Moldova ................................................................................................................. 43
3.3.7 Romania ................................................................................................................. 45
3.3.8 Serbia Montenegro .............................................................................................. 48
3.3.9 Slovakia.................................................................................................................. 52
3.3.10 Slovenia................................................................................................................ 56
3.3.11 Ukraine ................................................................................................................. 58
3.4 Water Legislation and Institutional Summary .............................................................. 61
3.4.1 Water legislation summary..................................................................................... 61
3.4.2 Institutional summary............................................................................................. 62
3.5 Bat Implementation ....................................................................................................... 64
3.5.1 Implementation of BAT at the National Level....................................................... 64
3.5.2 Priority.................................................................................................................... 65
3.5.3 Impact..................................................................................................................... 65
3.5.4 Administration........................................................................................................ 65
3.5.5 Inspection and Enforcement................................................................................... 65
3.5.6 Cost to Government ............................................................................................... 65
3.5.7 Cost to Industry ...................................................................................................... 66
3.5.8 BAT Application at individual industrial installations .......................................... 66
3.6 Recommendations and Next Steps................................................................................ 70
3.6.1 ICPDR and EU Legislation Development ............................................................. 70
UNDP/GEF Danube Regional Project
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3.6.2 Capacity building support programs ...................................................................... 70
3.6.3 BAT........................................................................................................................ 71
3.7 Appendices .................................................................................................................... 73
Appendix 1: Comparison of EMIS Inventory Parameters and Other Data Sources .... 75
Appendix 2: EU Water Legislation................................................................................. 81
Appendix 3: Report from the BAT Workshop................................................................ 83
Appendix 4: BAT Case studies ....................................................................................... 99
Appendix 5: Mechanism of data collection questionnaire summary ............................ 123
Industrial reform and the development of policies and legislation towards the reduction
of nutrients and dangerous substances
Abbreviations
BAT
Best Available Technique
B&H
Bosnia and Herzegovina
BOD
Biological oxygen demand
BREF
Best Available Techniques Reference Documents
BWD
Bathing Water Directive
F B&H
Federation of Bosnia and Herzegovina
COD
Chemical oxygen demand
DPSIR
Driving Force-Pressure-State-Impact-Response framework
DRB
Danube River Basin
DRBMP
Danube River Basin Management Plan
DRP
Danube Regional Project
DRPC
Danube River Protection Convention
DSD
Dangerous Substances Directive
DWD
Drinking Water Directive
EMAS
Eco-Management and Audit Scheme
EMIS
Emission Inventory made by ICPDR
EMIS/EG
Emission Expert Group of ICPDR
EPER
European Pollutant Emission Inventory
GEF
Global Environmental Facility
ICPDR
International Commission for the Protection of the Danube River
IPPC
Integrated Pollution Prevention and Control
JAP
Joint Action Program
MLIM /EG
Monitoring, Laboratory and Information Management Expert Group
PE
Population Equivalent, a unit to measure pollution
RBM/ EG
River Basin Management Expert Group
SIA
Significant Impact Area
UNDP/GEF Danube Regional Project
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SM
Serbia Montenegro
SS
Suspended Solids
SWD
Surface Water Directive
TOR
Terms Of Reference
UNDP
United Nations Development Program
UNIDO
United Nations Industrial Development Organization
UNIDO-TEST
United Nations Industrial Development Organization -Transfer of
Environmentally Sound Technology in the Danube River Basin
UNOPS
United Nations Office for Project Services
UWWT
Urban Waste Water Treatment
WW
Waste water
WWTP
Waste Water Treatment Plant
Final Report: Industrial reform and the development of policies and legislation towards the reduction
5
of nutrients and dangerous substances
Executive Summary
The Danube River Protection Convention (DRPC) is the overall legal instrument for trans-boundary
water issues in the Danube River Basin (DRB). The International Commission for the Protection of the
Danube River (ICPDR) is the organization which facilitates the implementation of the DRBC.
This document is the Final Report of the UNDP-GEF Danube Regional Project (DRP) "Industrial
Reform and the Development of Policies and Legislation Towards the Reduction of Nutrients and
Dangerous Substances". This industrial policy project is a component of the larger DRP, which is a 5
year project managed by the GEF Danube Regional Project Team in Vienna. The methodology for this
project involved four activities; secondary source analysis; site visits; review and verification of the
information and the development of recommendations. Local consultants were hired to participate in
the development of data in countries with the greatest need and in preparation of the industry case
studies.
A policy framework approach was taken for the project. Simply stated a policy approach is a
predictable, consistent response to a similar set of issues or situations. The advantage of a policy
approach is that the emphasis on applying a proven response to future similar situations is more
effective because the response has already been applied. It is also more efficient because the emphasis
is on identifying and grouping situations with common set of characteristics rather than doing a
detailed independent evaluation for each new situation.
This report provides an analysis and recommendations for the EMIS Inventory. It also reviews policies
and identifies gaps between EU and existing and future legislation for industrial pollution control and
enforcement mechanisms. Finally it examines alternatives for the further support for the application of
Best Available Techniques in the DRB. While addressed in separate sections of this report the policy
and EMIS Inventory are very much interrelated. The Industrial component of the Inventory provides
data for the development of policies and is used as the basis of the analysis of the pressures and human
impacts to be used in the DRBMP. When an industrial policy change is accepted in the DRB the EMIS
Inventory may be used to identify the impacts of the policy change on the industrial emission
reduction patterns in the DRB. The executive summary is organized into three sections; study process,
findings and recommendations and next steps.
Study Process
A kick off meeting was held with the GEF Danube Project Manager, the ICPDR Executive Secretary
and the ICPDR staff person responsible for the EMIS EG. During the inception period available
documentation and changes which had taken place after the ToR was written were reviewed.
Discussions were held with selected individuals including the EMIS EG Chair, representatives of the
ICPDR and the DRP and individuals involved in the UNIDO-TEST Project. A revised work plan was
developed at the end of the inception period
Key considerations which went into the revised work plan included:
- The steps taken by the ICPDR toward the implementation of the "Strategic Paper for the
Development of a Danube River Basin Management Plan"
- The invitation from the European Union to the Czech Republic, Hungary, Slovakia and
Slovenia to become EU Member States.
- Activities related to the implementation of Best Available Techniques (BAT) were
growing rapidly in the DRB
These and other considerations were incorporated in the Inception Report which resulted in the work
plan activities being organized into the following three groups:
1) Updating the EMIS Methodology
2) Policy and legislative analysis
3) BAT pollution reduction at industrial establishments
UNDP/GEF Danube Regional Project
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The three groups are interrelated in that the inventory data generally come from data sources required
by national law, and the analysis of the data provides a basis for improving government policy and
enforcement. Effective enforcement in turn is a key factor in causing pollution reduction in industrial
establishments. During the inception period given the changing circumstances it was decided to
produce a "road map" of recommendations. A road map provides options on how to get to a
destination. A road map can also show routes under construction and the anticipated time of opening.
In view of the changing situation in the DRB the "road map" approach would provide options and
flexibility in data collection and policy activities to respond to developing conditions in the DRB. The
"road map" provides both specific recommendations and strategic recommendations. The strategic
recommendations allow the ICPDR to analyze ongoing changes in the DRB which the ICPDR may
want to consider in the future activities and programs. Operational recommendations are more specific
and can be implemented in a shorter time frame.
The project team made a presentation at the 17th EMIS EG meeting in Brno Feb 16-17, 2003 to
outline the project approach. EMIS EG members were also given general information on the
forthcoming country site visits at the Brno meeting. The Inception Report was put on the project
website for review and comment. A structured interview guide was designed for the site visits. The
EMIS EG member for each country was contacted to arrange for a site visit. The country EMIS EG
member also arranged for discussions with other relevant people, for example, those involved in data
collection, legislative development and BAT implementation. Site visits were made to 9 of the 11
countries. One country was not interested in participating and for the second mutually agreeable dates
for the site visit could not be found. In two countries, Bosnia Herzegovina and Serbia Montenegro the
project team had an additional task to fill data gaps. The project team, working with the national
EMIS EG member and local consultants, provided data on 53 additional industrial installations. These
were forwarded by the BiH EMIS EG for inclusion in the 2002 Inventory. In Serbia Montenegro,
because of the almost continuous conflict for a long period of time, the data do not exist. However,
systems and procedures are now being put in place for future data collection. The data collected from
the site visit interviews were combined with information available from other sources was into a single
consolidated country profile. To ensure that the information was accurate the final step in the process
was to send a questionnaire and completed country profile to each EMIS EG member to verify the
information collected by the project team. The information was incorporated into the draft final report.
The draft final EMIS Methodology report was presented to the EMIS EG meeting in Ljubljana Feb 16-
17, 2004. The comments made at that meeting are incorporated into the final report.
Findings
The study identified the institutional and legislative base in each country. The institutional base
includes the organizations involved in water management and decision making in each country. The
legislative base determines the pollutants regulated the allowable limits, the pollution charges and the
data available on a continuing basis. The EU Directives were used as a framework for the legislative
analysis. Both legislation and the institutional capacity to collect data, monitor and enforce the
provisions of the water related legislation are necessary for effective water management.
The summary of the institutional base is included in detail is provided in section 4 of this report. The
analysis of the institutional structure shows that, all of the countries have permitting, inspection and
monitoring in place, however, the specifics differ on a country by country basis. Most countries rely
on self-monitoring by individual installation and data are centrally collected and assessed.
The legislative situation at the national level appears below. The EU Water Directives, including the
Water Framework Directive were used as the framework for the analysis because of the
comprehensiveness of the Directives. In the 2000 plenary session in Sofia it was decided the EC Water
Framework Directive would be the highest priority for the ICPDR.
Industrial reform and the development of policies and legislation towards the reduction
of nutrients and dangerous substances
7
Summary of national legislation
Country/
Water Framework
Dangerous Substances Integrated
Prevention Seveso Environmental
Impact
Environmental
Directive
and Pollution Control
Assessment
Management and Audit
Schemes
Bosnia &
Not implemented and
Not implemented and
Not implemented and
Not implemented and
Not implemented and
Not implemented and changes
Herzegovina changes not planned to
changes not planned to
changes not planned to
changes not planned to
changes not planned to
not planned to transpose the
transpose the EU directive
transpose the EU directive
transpose the EU directive
transpose the EU directive
transpose the EU directive
EU directive
Bulgaria Partially
implemented Transposed and
Partially implemented
Partially implemented
Fully implemented in
Partially implemented using
using as future framework
substantially implemented
using as future framework
using as future framework
National Legislation
as future framework for
for national legislation
in National Legislation
for national legislation
for national legislation
national legislation
Croatia*
Not implemented and
Not implemented and
Not implemented and
Not implemented and
Not implemented and
Not implemented and changes
changes not planned to
changes not planned to
changes not planned to
changes not planned to
changes not planned to
not planned to transpose the
transpose the EU directive
transpose the EU directive
transpose the EU directive
transpose the EU directive
transpose the EU directive
EU directive
Czech
Transposed and
Fully implemented in
Fully implemented in
Fully implemented in
Fully implemented in
Fully implemented in
Republic
substantially implemented
National Legislation
National Legislation
National Legislation
National Legislation
National Legislation
in National Legislation
Hungary Transposed
and
Fully implemented in
Transposed and
Fully implemented in
Fully implemented in
Fully implemented in
substantially implemented
National Legislation
substantially implemented
National Legislation
National Legislation
National Legislation
in National Legislation
in National Legislation
Moldova
Not implemented and
Not implemented and
Not implemented and
Not implemented and
Not implemented and
Not implemented and changes
changes not planned to
changes not planned to
changes not planned to
changes not planned to
changes not planned to
not planned to transpose the
transpose the EU directive
transpose the EU directive
transpose the EU directive
transpose the EU directive
transpose the EU directive
EU directive
Romania Partially
implemented Partially implemented
Partially implemented
Partially implemented
Transposed and
Partially implemented using
using as future framework
using as future framework
using as future framework
using as future framework
substantially implemented
as future framework for
for national legislation
for national legislation
for national legislation
for national legislation
in National Legislation
national legislation
Serbia -
Not implemented and
Not implemented and
Not implemented and
Not implemented and
Not implemented and
Not implemented and changes
Montenegro
changes not planned to
changes not planned to
changes not planned to
changes not planned to
changes not planned to
not planned to transpose the
transpose the EU directive
transpose the EU directive
transpose the EU directive
transpose the EU directive
transpose the EU directive
EU directive
Slovakia Transposed
and
Fully implemented in
Fully implemented in
Fully implemented in
Fully implemented in
Fully implemented in
substantially implemented
National Legislation
National Legislation
National Legislation
National Legislation
National Legislation
in National Legislation
Slovenia Transposed
and
Fully implemented in
Fully implemented in
Fully implemented in
Fully implemented in
Fully implemented in
substantially implemented
National Legislation
National Legislation
National Legislation
National Legislation
National Legislation
in National Legislation
Ukraine
Not implemented and
Not implemented and
Not implemented and
Not implemented and
Not implemented and
Not implemented and changes
changes not planned to
changes not planned to
changes not planned to
changes not planned to
changes not planned to
not planned to transpose the
transpose the EU directive
transpose the EU directive
transpose the EU directive
transpose the EU directive
transpose the EU directive
EU directive
*Following the collection of this information Croatia was invited to begin the accession process. As part of that process Croatia has committed to adopting the EU legislation.
UNDP/GEF Danube Regional Project
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The analysis of legislation comparability with EU Directives results in the identification of three
groups of countries. The first group; the Czech Republic, Hungary, Slovakia and Slovenia will have
fully transposed the EU legislation by May 1st 2004. The second group; Bulgaria, Croatia and
Romania is in the process of transposing the EU Directives into national law. For the third group
Bosnia Herzegovina, Moldova, Serbia and Montenegro and the Ukraine EU legislation is not a major
consideration in legislation development. The first group will become Member States in May 2004;
the second includes those in the accession process, and the third group is comprised of those not yet
involved in the accession process. Therefore on May 1st, 2004 nine out of the 13 DRB countries will
be using the EU Directives or in the process of incorporating them into their national legislation. The
legislative base in the DRB countries is proving a more consistent base for ICPDR activities including
the implementation of the "Strategy Paper on a Danube River Basin Management Plan".
The first EMIS inventory was published in 1998. It was updated in 2000 and contains data on 12
countries in the DRB (no data are available for Serbia Montenegro). The 2000 inventory is divided
into municipal sources (approximately 500 treatment plants) and industrial sources (approximately
220 installations). The following chart shows the data provided in graph form. The vertical axis
provides the percentage of installations providing this data for all reporting installations in all
countries. The horizontal axis identifies the individual parameter. The nine heavy metal parameters
have been excluded from the chart because of the low general reporting rate for these parameters.
Industrial reform and the development of policies and legislation towards the reduction
of nutrients and dangerous substances
9
Selected parameters from the 2000 EMIS inventory
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
e
D
D
2
3
l
l
-N
4
P
Cl
4
es
ts
e
S
X
itud
BO
NH4
NO
NO
PO
T-
SO
SS
Oi
hide
ano
NE
DIS
CIH
t-Cl
TOT
TO
gen
ac
AO
Phenols
eth
ater Load ischarge
CO
Sulp
D
Fluorid
aldehyd M
Deter
de / long
rm
w W
lume
Fo
latitu
Ra
ter Vo
aste Wa
W
UNDP/GEF Danube Regional Project
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The chart indicates the following:
- Location and waste water discharge and COD data are available for more than 70 % of the
installations.
- COD data are available for between 60% and 70% of the installations.
- For fifteen or more that 50% of the parameters less than 20% of the installations provided data
There are no data available except for the industrial code for 24 or almost 10% of the installations
This is considerably less data in the Industrial Inventory than is available in the Municipal section of
the EMIS Inventory.
The analysis shows that there is a high degree of consistency of the data parameters in the EMIS
Inventory and other data bases with the most consistency occurring for dangerous substances. Data
parameter comparisons are found in Appendix 7. However, the data is organized differently which
limits computer based comparisons with data bases kept by other organizations.
Quality assurance is provided at the national level and varies widely in the DRB so that comparison of
data among the countries contributing to the EMIS Industrial Inventory is limited.
The EMIS Inventory of industrial installations is being used to identify human activity and pressures
for the Danube River Basin Management Plan (DRBMP). A chart of ICPDR activities related to the
DRBMP including EMIS is provided in Section 3 of this report.
Final Report: Industrial reform and the development of policies and legislation towards the reduction
11
of nutrients and dangerous substances
Recommendations
Detailed recommendations are contained in the body of the report and are summarized as follows:
For the EMIS Inventory there are two strategic recommendations:
·
The EMIS EG should consult the users of the EMIS Inventory including the ICPDR
Secretariat, the RBM EG, the MLIM EG and public users of the data in the inventory to
identify and determine future uses of the inventory data
·
The EMIS EG should analyze other developing sources which provide data for a significant
portion of the DRB for example, the data reporting required under the EU Directives, to see if
that data will be useful in assisting the work of the EMIS EG. An initial comparison of EMIS
Inventory and the reporting requirements of the UWWT, Dangerous Substances and IPPC
Directives indicates the following. The EMIS Inventory requires reporting on the basis of tons
of BOD and COD emitted. The UWWT Directive requires the reporting for the agro food
industry on the basis of sources emitting more than 4,000 PE. The data for 2004 will be
published in 2006 under the UWWT Directive. The European Pollution Emission Register
(EPER ),created as part of the IPPC Directive, requires reporting from all installations which
fall under the IPPC. An IPPC institution is one that uses one or more of the six categories of
technology. Data is reported on the basis of threshold limit values of parameters. Data from
the new EU member states should be included in the 2006 publication which will have the
data from 2004.The Dangerous Substances Directive contains parameters which are most
consistent with the EMIS Inventory and a comparison is included in Appendix 7 to this report.
Under the Dangerous Substances Directive data will be collected annually and will be
available to the EU Commission upon request. The EMIS Inventory requirements should be
adapted to the DRBMP and the methodologies should be harmonized the WFD methodologies
in the same manner as the Strategic Paper for the Danube River Basin Management Plan sets
out for the MLIM.
The operational recommendations address the completeness, quality assurance and comparability of
data in the inventory. With respect to completeness, the number of industrial installations needs to be
increased and the gaps in reporting parameters reduces. Quality assurance varies widely and it is
recommended that a uniform system be put in place. The EU Water Framework Directive requires a
river basin approach for European Union Member States. It would be useful if the data provided in the
EMIS Inventory uses international standard coding so that comparisons can be made with other data
from other European river systems.
The detailed next steps are outlined in the body of the report.
For the legislation and policy analysis there are the following recommendations
·
The EU Directives and policy have become increasingly important in the DRB now that 6
ICPDR member countries are also EU Member States. The ICPDR should establish a
mechanism to support the six ICPDR national governments which are also EU Member States
to advocate for future EU policy and decisions which are directed toward the reduction and
prevention of the industrial water pollution in the DRB. This mechanism also could be used to
support other ICPDR policy initiatives.
·
For each of the ICPDR member countries, not involved in EU accession, it is recommended
that a targeted three year support program for industrial pollution reduction policy and
capacity building be developed. The components should include legislation drafting,
institutional development, technical assistance and training among others. The program would
be developed in cooperation with the individual national government and tailored to the needs
UNDP/GEF Danube Regional Project
12
of each country. These activities should be complementary similar activities by other
international organizations which are either underway or planned for these countries.
For the Further Application of BAT the following is recommended:
·
There are an increasing number of sources providing information on legislation, BAT BREFs,
BAT methodology and other BAT related materials available to national governments,
industrial organizations and individual industrial installations in the DRB. It is recommended
that a link on the ICPDR website be developed which will allow all interested parties to access
the major sources and the experts which have worked with the EMIS EG on BAT issues.
Final Report: Industrial reform and the development of policies and legislation towards the reduction
13
of nutrients and dangerous substances
1. Introduction and Study Process
The Danube River Protection Convention (DRPC) is the overall legal instrument for trans-boundary
water management in the DRB. The International Commission for the Protection of the Danube River
(ICPDR) was created to facilitate the implementation of the DRPC.
The Danube Regional Project (DRP) supports the ICPDR. The DRP is a five year project managed by
the GEF Danube Regional Project Team in Vienna. The four immediate objectives of the Danube
Regional Project are:
Objective 1:
Creation of sustainable ecological conditions for land use and water management,
Objective 2: Capacity building and reinforcement of trans-boundary cooperation for the
improvement of water quality and environmental standards in the DRB,
Objective 3: Strengthening of public involvement in environmental decision making and
reinforcement of community actions for pollution reduction and protection of
ecosystems,
Objective 4:
Reinforcement of monitoring, evaluation and information systems to control trans-
boundary pollution, and to reduce nutrients and harmful substances.
This project is component 1.5 "Industrial Reforms and the Development of Policies and Legislation
Towards the Reduction of Nutrients and Dangerous Substances" (Industrial Policy Project) under
Project Implementation Plan Phase One (2002-2003). An expert group within the ICPDR, the EMIS
EG produces an EMIS Inventory which includes industrial sources.
The project will assist the EMIS/EG in its work and also the ICPDR in facilitating future policy and
institutional development. Following the inception phase, as recommended in the Inception Report the
activities for component 1.5 were organized into three groups:
· how to improve the EMIS inventory
· analysis of national industrial environmental legislation
· promotion of BAT in the region.
These three groups are interrelated. The inventory data generally comes from data sources required by
national law, and the analysis of the data provides a basis for improving government policy and
enforcement. Effective enforcement in turn is a key factor in causing pollution reduction in industrial
establishments which results in reduced harmful emissions to the Danube and improved water quality.
Study Process
In September 2002 a kick off meeting was held with the GEF Danube Project Manager, the ICPDR
Executive Secretary and the ICPDR staff person responsible for the EMIS EG. At that meeting the
project consulting team was asked to use the inception period to conduct a preliminary review of
documentation for example the "Strategic Paper for the Development of a Danube River Basin District
Management Plan" and have preliminary interviews with selected individuals in order to develop a
revised work plan .During the inception period a review of the available documentation both from the
ICPDR and other sources was undertaken, along with discussions with selected individuals including
the EMIS EG Chair, representatives of the ICPDR and the DRP and individuals involved in the
UNIDO-TEST Project.
In 2000, at a Plenary Session in Sofia it was decided that the implementation of the Water Framework
Directive for would be the highest priority for the ICPDR. The ICPDR produced the "Strategic Paper
UNDP/GEF Danube Regional Project
14
for the Development of a Danube River Basin District Management Plan" This paper analyses, in
detail, the Water Framework Directive requirements and applies them to the DRB. It includes a phased
timeline and outlines the responsibilities of the Expert Groups within the ICPDR including the EMIS
EG in developing the Danube River Basin Management Plan.
Another important event, which occurred during the inception period, was the invitation from the
European Union to the Czech Republic, Hungary, Slovakia and Slovenia to become EU Member
States. This has important implications for future pollution reduction policy initiatives in the DRB
from two different perspectives. First, during the pre accession period these four countries were
required to report regularly to the Commission on number of issues including progress in
implementing the environmental component of the Acquis communautaire. This resulted in more data,
with respect to water pollution, being updated regularly. There were also substantial funds available to
address water pollution and other environmental issues. Foreign investment in the industrial sector was
accelerated in anticipation of the EU membership. From a policy perspective each of these four
countries had to transpose the EU Directives into their national legislation providing a solid legal basis
for water management. The EU initiated changes went beyond these four countries as two other
countries, Bulgaria, and Romania are also involved in the EU pre accession to become future Member
States of the EU. Croatia has also applied to become part of the accession process. From May 1st 2004,
nine out of the 13 DRB countries will have adopted the environmental section of the Acquis
communautaire are actively working toward it.
It also became evident during the inception period that, in addition to the EMIS EG sector guidelines,
other activities related to the implementation of Best Available Techniques (BAT) were growing
rapidly in the DRB. Many of these activities occurred because of the requirement to implement BAT
for those industrial installations falling under the jurisdiction of the Integrated Pollution, Prevention
and Control (IPPC) EU Directive. For example, a BAT Centre has been established by the EU in
Seville to provide Best Available Techniques Reference Documents (BREFs). The BREFs are very
detailed and some are more that 1000 pages. Each EU Member State is putting in place a system to
adapt the BREFs into national circumstances. Also the UNIDO-TEST project had developed a
methodology and examples of BAT applications in conjunction with national Cleaner Production
Centers in the DRB.
The progress toward implementation of the "Strategic Paper for the Development of a Danube River
Basin District Management Plan", the implications of the expansion of the EU and the rapidly
developing events with respect to the implementation of BAT in DRB countries were taken into
consideration in producing revised work plan in the Inception Report.
During the inception period, given the changing circumstances, it was decided to produce a "road
map" of recommendations. A road map provides options on how to get to a destination. A road map
can also show roads under construction and the anticipated time of opening. In view of the changing
situation in the DRB the "road map" approach would provide options and flexibility in data collection
and policy activities to respond to developing conditions in the DRB. The "road map" provides both
specific recommendations and strategic recommendations. The strategic recommendations allow the
ICPDR to analyze ongoing changes in the DRB which the ICPDR may want to consider in the future
activities and programs. Operational recommendations are more specific and can be implemented in a
shorter time frame.
The project team made a presentation at the 17th EMIS EG meeting in Brno Feb16 -17, 2003 to
outline the project approach. EMIS EG members were also given general information on the
forthcoming country site visits at the Brno meeting. The Inception Report was put on the DRP website
for review and comment. A structured interview guide was designed for the site visits. The EMIS EG
member for each country was contacted to arrange for a site visit. The country EMIS EG member also
arranged for discussions with other relevant people, for example, those involved in data collection,
legislative development and BAT implementation. Site visits were made to 9 of the 11 countries. One
country was not interested in participating and for the second mutually agreeable dates for the site visit
could not be found. In two countries, Bosnia & Herzegovina and Serbia Montenegro the project team
Final Report: Industrial reform and the development of policies and legislation towards the reduction
15
of nutrients and dangerous substances
had an additional task to fill data gaps. The project team, working with the national EMIS EG
member and local consultants, provided data on 53 additional industrial installations. These were
forwarded by the B&H EMIS EG for inclusion in the 2002 Inventory .In Serbia Montenegro, because
of the almost continuous conflict for a long period of time, the data do not exist. However, systems
and procedures are now being put in place for future data collection. The data collected from the site
visit interviews were combined with information available from other sources was into a single
consolidated country profile. To ensure that the information was accurate the final step in the process
was to send a questionnaire and completed country profile to each EMIS EG member to verify the
information collected by the project team. The information was incorporated into the draft final report.
The draft final EMIS Methodology report was presented to the EMIS EG in Ljubljana. The comments
made at that meeting are incorporated into the final report.
This report is organized into two main sections. The first section addresses issues related to the EMIS
and the second industrial policy issues and the implementation of BAT in the Danube River Basin.
UNDP/GEF Danube Regional Project
16
2. EMIS Inventory
The first EMIS inventory was published in 1998. It was updated in 2000 and potentially contains data
on 13 countries in the DRB. The 2000 EMIS Inventory is divided into municipal sources
(approximately 500 treatment plants) and industrial sources (approximately 220 installations). The
methodology consists of a one pages set of instructions for filling in the country worksheets. This
analysis is based upon the 2000 EMIS Inventory because it was the last version completed before the
start of this project. The analysis is focused on the industrial installation component of the inventory
data.
The EMIS Inventory provides base data in a number of key areas. The inventory may potentially be
used as an input into the development of the DRBMP and effective industrial policy. The inventory is
designed to identify the major polluters, loads, locations and future costs of upgrading.
Danube River Basin Management Plan (DRBMP)
At the 3rd Plenary Session in Sofia in November 2000 the following resolution was passed. "The
Implementation of the EC Water Framework Directive is considered as being the highest priority of
the ICPDR" The following chart shows the ICPDR approach to the development of the DRBMP.
The EMIS EG is responsible for providing input into identifying pressures and effects from human
activities as input into the DRBMP process. The approach of this project is to build upon prior EMIS
EG achievements. Therefore, existing documents on the methodology were reviewed and the gaps in
the 2000 inventory were identified. This provided the basis for the recommendations and strategies
identified in this report.
2.1 Objectives of EMIS inventory
Historically, the EMIS inventory was developed to provide the base data supporting the identification
and development of policies aimed at pollution reduction in the Danube Basin. Thus data from
inventory can help to identify industrial pollution sources by industrial sector, pollutant impact,
location or other criteria.
The objectives of the inventory are to identify sources for 75% of the municipal discharges into the
Danube River. For industrial sources, the focus was devoted to selected industries in which polluters
discharge more than 1 ton of BOD per day or 2 tons of COD per day into the DRB.
The EMIS inventory has been used in several research and development projects:
· The formulation of the Joint Action Program (JAP) 2001-2005
· Monitoring program (TNMN) conducted by MLIM EG and Joint Danube Survey Trip
(2001)
· The Concept Paper on Pressures and Impacts (2003)
· the UNDP/GEF project on Strengthening the Implementation Capacities for Nutrient
Reduction and Trans-boundary Cooperation in the DRB
· The selection of priority industries in the GEF/UNDP Industrial Policy Project (1.5).
The EMIS inventory is placed on DANUBIS, so it is accessible to the public.
The DRBMP uses a conceptual approach that has been used by the European Environmental Agency,
the OECD and others. This approach shows the causality between human activities and environmental
policies. It is shown in the figure below.
Final Report: Industrial reform and the development of policies and legislation towards the reduction
17
of nutrients and dangerous substances
In this conceptual framework driving forces describes human activities, for instance, industrial
production or wastewater treatment plants. Pressure describes the problems caused by the driving
force on the function/use in the river basin. State means, for example, what concentration of pollutants
are present or what are the characteristics of the ecosystem. The impact describes the loss of
function/use e.g. toxicity that causes a decrease in the fish population. Finally, responses describe the
political action taken to deal with the problems.
THE DRIVING FORCE- PRESSURE- STATE- IMPACT-
RESPONSES (DPSIR) FRAMEWORK
Driving
Responses
forces
Pressures
Impact
State
Figure 1: Driving force-Pressure-State-impact-Response (DPSIR) framework (OECD)
Within this framework the EMIS Inventory data will be used to identify and analyze pressures and the
effect of human activities.
2.2 Current status
In order to develop recommendations for the update of the EMIS inventory, the current status with
respect to procedures and basic features of the EMIS inventory was assessed. The assessment was
based upon an analysis of the existing EMIS inventory, review of existing guidelines and procedures
for the inputs into the EMIS inventory, and personal interviews with members of the EMIS EG and
other experts.
2.2.1 Compilation of data in the EMIS inventory
The EMIS inventory is based upon national data sources. Individual countries do not specifically
collect data for the EMIS Inventory. The data provided is collected for other purposes. The most
common source of data for the inventory is national data from the pollution permit and pollution
charges. National governments have an incentive to keep accurate data in these data bases because
they provide revenue for them in the form of fees and fines.
The industrial component of the EMIS Inventory includes selected industries, in which polluters
discharge more than 1 t of BOD per day or 2 tons of COD per day into the DRB. Data are compiled in
different ways at the national level and then transferred to the EMIS/ EG. However, the list of
designated institutions responsible for providing the data to the EMIS EG members for the EMIS
Inventory is not available therefore it is difficult to evaluate the base data sources. These sources differ
UNDP/GEF Danube Regional Project
18
from country to country. The EMIS EG members provide as consistent as possible approach to the
process subject to individual country conditions and constraints.
There are also large variations in procedures used for reporting of both at the level of individual
installation and monitoring agencies to the national authority or designated institution. The variations
include frequency of sampling, parameters monitored, and reporting format. The EMIS EG members
are responsible for the facilitation of the collection process but not the data collection itself. The
Guidelines of the ICPDR that are regularly distributed to the representatives of EMIS EG are limited
to "the transfer" of the compiled data. The one page guidelines contain information on format and how
and when to transfer data from a national database to the ICPDR. The situation is most complicated in
countries that have not yet developed a national database or where comprehensive monitoring does not
exist.
2.2.2 Parameters in the industrial component of the EMIS inventory
The following parameters are included:
· AV code
· River basin and river codes and name of main river
· raw water load (in thousand of pe),
· volume of WW discharged (m3/year)
· industrial sector code
· BOD and COD
· nutrients (NH4-N, NO2-N, NO3-N, TOT-N, PO4-P and TOT-P)
· enlarged parameters (Cl, SO4, SS, Pb, Cr, Cd, Cu, Fe, Mn, Ni, Zn, As, Mg, Al, Hg, oil,
phenols, fluorides, detergents, sulfides, formaldehyde, methanol, NES, DIS, CIH, act-Cl,
AOX)1
In addition, the 2000 EMIS inventory, latitude and longitude information was collected to provide the
basis for the design of maps.
2.3 Gaps in the EMIS inventory
As a part of this analysis, a questionnaire was used to collect information with respect to the
mechanism of data collection. EMIS EG representatives from six DRB countries (of the eleven
requested) submitted the questionnaire. This level of response restricts the overall evaluation and
comparison with the Report on the Summary of National Practices concerning the Monitoring of
Wastewater Discharges conducted in 1998-99 (ICPDR Report, IC/20/2000). However, it is still a
useful indicator and the summary of the questionnaire is appended to this report
2.3.1 Data Gaps
There are gaps with respect both with respect to installations included in the EMIS Inventory and data
from reporting installations. There are 265 installations in the 2000 EMIS industrial Inventory. A
summary for selected parameters are shown in the chart below. . The vertical axis provides the
percentage of installations providing this data for all reporting installations in all countries. The
horizontal axis identifies the individual parameter. Heavy metals have been excluded from the chart
because of the low general reporting rate for these parameters.
1 Parameters in the EMIS inventory 2000. For the EMIS inventory 2002, the Danube List of Priority
Substances is to be included.
Industrial reform and the development of policies and legislation towards the reduction
of nutrients and dangerous substances
19
Selected parameters from the 2000 EMIS inventory
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
e
D
D
2
3
l
l
-N
4
P
Cl
4
es
ts
e
S
X
itud
BO
NH4
NO
NO
PO
T-
SO
SS
Oi
hide
ano
NE
DIS
CIH
t-Cl
TOT
TO
gen
ac
AO
Phenols
eth
ater Load ischarge
CO
Sulp
D
Fluorid
aldehyd M
Deter
de / long
rm
w W
lume
Fo
latitu
Ra
ter Vo
aste Wa
W
UNDP/GEF Danube Regional Project
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The chart shows the following:
· Location and waste water discharge data are available for 70 % of the installations.
· COD and BOD data are available for more that 60% of the installations
· For fifteen (more that 50%) of the parameters less than 20% of the installations provided data
There are no data available except for the industrial code for 24 or almost 10% of the installations.
This is considerably less data than is available in the Municipal section of the EMIS Inventory.
2.3.2 Procedural Differences
Reporting procedures differ from country to country. Several countries require self-monitoring of
polluters and self-monitoring data are published in the inventory. In other cases the information is
obtained from a central database originating from designated laboratories. Because these have
different levels of accuracy and reliability the aggregate data require careful interpretation.
2.3.3 Quality assurance
The quality of data relies on the nationally designated reporting institution. There are several factors
that might influence the quality of data in the inventory. The factors include monitoring systems and
sampling methodology as well as recording and reporting requirements within the country. Periodic
checks have been made however there is no continuing quality assurance procedure in place at the
EMIS EG level. As a result of this, the data included in the EMIS inventory have limited use in
comparing individual countries or parameters for the DRB generally.
2.3.4 Financial Support
There is no internal money available to pay the extra costs to collect data on parameters in the EMIS
Inventory that are not collected for national purposes. This is a limiting factor in data collection.
2.4 Recommendations to up-date the methodology of the EMIS inventory
Two types of recommendations; strategic and operational are outlined in this section. Strategic
recommendations address the question of how the EMIS Inventory will be used in the future.
Operational recommendations address more specific issues within the inventory itself.
2.4.1 Strategic Recommendations
There are two strategic recommendations:
· The EMIS EG should consult the users of the EMIS Inventory including the ICPDR Secretariat,
the RBM EG, the MLIM EG and public users of the data in the inventory to determine future
uses of the inventory data
· The EMIS EG should analyze other developing sources which provide data for a significant
portion of the DRB for example, the data reporting required under the EU Directives, to see if
that data will be useful in assisting the work of the EMIS EG. An initial comparison of EMIS
Inventory and the reporting requirements of the UWWT, Dangerous Substances and IPPC
Directives indicate the following. The EMIS Inventory requires reporting on the basis of tons of
BOD and COD emitted. The UWWT Directive requires the reporting for the agro food industry
on the basis of sources emitting more than 4,000 PE. The data for 2004 will be published in 2006
under the UWWT Directive. The European Pollution Emission Register (EPER), created as part
of the IPPC Directive, requires reporting from all installations which fall under the IPPC. An
IPPC institution is one that uses one or more of the six categories of technology. Data is reported
on the basis of threshold limit values of parameters. Data from the new EU member states should
be included in the 2006 publication which will have the data from 2004.The Dangerous
Substances Directive contains parameters which are most consistent with the EMIS Inventory
and a comparison is included in Appendix 7 to this report. Under the Dangerous Substances
Final Report: Industrial reform and the development of policies and legislation towards the reduction
21
of nutrients and dangerous substances
Directive data will be collected annually and will be available to the EU Commission upon
request.
The EMIS Inventory requirements should be adapted to the DRBMP and the methodologies should be
harmonized the WFD methodologies in the same manner as the Strategic Paper for the Danube River
Basin Management Plan sets out for the MLIM.
2.4.2 Operational Recommendations
The operational recommendations address the completeness, quality assurance and comparability of
data in the inventory.
There are very significant gaps in the industrial section of the 2000 EMIS Inventory. Therefore, it is
recommended that the EMIS EG take the following steps. First, update the number of industrial
installations in the DRB. Second, review the parameters in the inventory for which significant gaps in
data have been identified in this report. Discuss with national governments the reason for the gaps and
whether if the data will be provided in the future. For the data for which national governments do not
plan to provide data remove the parameters from future inventories or find other possible sources.
Quality assurance is the responsibility of each national government. The data in the inventory is
gathered from self monitoring and government monitoring and reporting systems. Sampling,
measurement methods and analytical procedures vary widely within the DRB. Therefore it is
recommended that future inventories indicate the data gathering method e.g. self monitoring. Also, the
EMIS EG should review the quality assurance system in place in each country and recommended
changes as necessary to ensure that the data published in future inventories are of uniformly high
quality.
The EU Water Framework Directive requires a river basin approach for European Member States. The
implementation of the "Strategic Paper on Danube River Basin Management Plan" places the ICPDR
at the forefront of river basin management in Europe. The approaches, experiences, and data collection
system of the ICPDR will likely be used as an example for other river basins in Europe. Therefore, it
would be very useful if the data provided in the EMIS Inventory uses international standard coding so
that comparisons can be made among river basins and the transfer of knowledge and information from
the ICPDR to other basins will be facilitated.
2.4.3 Next Steps
The next steps for the implementation of are addressed in this section.
IDENTIFY FUTURE USES
Specify current users and uses of the data. Future EMIS Inventories should be directed toward the
users and uses of the data. The following steps should be taken by the EMIS EG:
· Identify the current users and uses for the EMIS Inventory including RBM EG, MLIM EG,
and public users of the EMIS Inventory data.
· Develop a questionnaire for users including the following:
- Existing uses of EMIS EG Inventory
- Suggestions for changes in future EMIS Inventories to facilitate existing uses
- Future potential data needs
- Suggestions on how future EMIS Inventories could provide data and analysis relating
to -these future data needs
· Organize a stakeholder workshop to discuss future users and uses for the EMIS Inventory
· Conduct a stakeholder analysis using the questionnaire and results from the workshop
· Revise future inventories to reflect the results of the user analysis.
UNDP/GEF Danube Regional Project
22
REVIEW DEVELOPING DATA SOURCES TO IDENTIFY SYNERGISM
The purpose of the review is both to see what data, collected by other organizations such as the EU,
might be useful to the EMIS EG. At the same time an understanding of other data collection systems
provides the basis for future discussions among the institutions collecting data on industrial sources in
the DRB.
Identify emerging sources of data for example the data collection and reporting requirements
in the, European Pollution Emission Register, Urban Waste Water Treatment Directive and
the Dangerous Substances Directive.
Within these emerging sources analyze the parameters, methods and timing of publication as
possible input into future EMIS EG activities including future EMIS inventories. The EMIS
Inventory requires reporting on the basis of tons of BOD and COD emitted. The UWWT
Directive requires the reporting for the agro food industry on the basis of sources emitting
more than 4,000 PE. The data for 2004 will be published in 2006. EPER created as part of the
IPPC Directive requires reporting from all installations which fall under IPPC. An IPPC
institution is one that uses one or more of the six categories of technology. Data is reported on
the basis of threshold limit values of parameters. The Dangerous Substances Directive is the
most consistent with the EMIS Inventory. The EU Directive Reporting Requirements are in
Appendix 5 of this report.
Develop a plan to use as appropriate emerging sources as input into the EMIS EG activities.
REVISE FUTURE INVENTORIES
Develop an updated list of industrial institutions using information collected by other organizations.
For example information can be found in EU accession reports including country reports and the
national lists of industrial installations requiring permitting under the IPPC Directive.
The EMIS Inventory requirements should be adapted to the DRMP and the methodologies should be
harmonized the WFD methodologies. This will have the EMIS Inventory following a parallel path
with the one recommended for MLIM in the Strategic Paper for the Danube River Basin Management
Plan.
The operational recommendations provided in this report, the results of the user analysis and emerging
data sources should be used in revising future inventories.
Final Report: Industrial reform and the development of policies and legislation towards the reduction
23
of nutrients and dangerous substances
3. Policy and Legislation
This section of the report addresses the following items in the ToR:
1.5.4 Review policies and relevant existing and future legislation for industrial pollution control and
identification enforcement mechanisms at the country level.
1.5.5 Compare and identify gaps between relevant EU and national legislation
1.5.6 Develop necessary complementing policy and legal measures for the introduction of BAT
3.1 Methodology
The methodology involved three activities; secondary source analysis; site visits; review and
verification of the information. For the secondary source analysis general country documentation and
more specialized studies for the World Bank and the EU as well as other available sources were used.
The EU studies were particularly detailed and useful for those countries in the process of joining the
EU. Country visits were offered to each of the countries. Only one country did not want to participate
and a second was not visited due to problems in finding a suitable date. Local consultants were hired
to participate in the development of data in countries with the greatest need and in preparation of the
industry case studies for the application of BAT. A country profile was prepared for each country
including a general overview of the institutional structures and legislation in place or being prepared
using EU legislation to provide the framework. The information on individual countries was then
summarized recommendations developed to address all of the countries in the basin.
3.2 Policy Framework
Simply stated a policy approach is a predictable and consistent response to a similar set of issues. The
advantage of a policy approach is that the emphasis on applying a proven response to future similar
situations is more effective because the response has already been applied and proven itself. It is also
more efficient because the emphasis is on identifying and grouping situations with common set of
characteristics rather than doing a detailed independent evaluation for each new situation.
The policy development process involves data collection and analysis, education and awareness and
the implementation of the appropriate measures to address the issue being addressed. The process is
not always sequential. A negative environmental event such as an oil spill or the leakage of toxic
waste which results in an immediate and highly visible impact including the loss of human or animal
life may raise awareness that results in pressure to implement immediate measures to prevent future
occurrences. On the other hand, substances such as PCB's, which only become evident over longer
periods of time, are often first discovered through the painstaking data collection and analysis by
experts.
Policy makers sometime try to speed up the expert analysis in order to be able to make an informed
decision. In other situations they find themselves resisting the pressure to take immediate action after a
highly visible event so that enough information is available to put in place the appropriate solutions.
As the cross border nature of environmental issues and policies becomes more apparent, it is necessary
for decision makers in several jurisdictions to make compatible decisions. Political boundaries do not
always coincide with ecological systems. The Danube River Basin is an example of a situation where
this occurs. International conventions and agreements are often used to address trans-boundary
environmental issues. However, the impact of the convention is dependent upon the actions of
individual national governments. These governments may have different legislation and institutional
frameworks.
In the Danube River Basin, in addition to the DRPC is the legal instrument for dealing with trans-
boundary water issues in the DRB. In addition there is EU Directives and national legislation. Initially
UNDP/GEF Danube Regional Project
24
only two countries in the DRB were EU Member States. However as of May 1 2004, four more will
become Member States and an additional three are aligning their national legislation and supporting
systems to become members. The majority of Danube countries will have very similar legal
environmental management systems. This has important implications for future industrial pollution
reduction and prevention activities within the context of the Danube River Basin Management Plan
which is currently being developed. The EU IPPC Directive will legally require the application BAT
mandatory for the majority of the Danube countries and result in the creation of the European
Pollution Emission Registry. Therefore the IPPC Directive will be the driving force for BAT in the
majority of countries. IPPC and other directives such as the Water Framework Directive have data
reporting requirements which need to be taken into account for future data collection activities of the
ICPDR, for example, the EMIS Inventory.
In the following section a description of the existing and future situations is compared with the EU
requirements on a country by country basis. The policy and legislation is reviewed, gaps identified,
and the IPPC Directive of the EU also provides the basis for addressing issues relating to the
implementation of BAT.
3.3 Country Profiles
In this section the country profiles are presented. Each profile begins with a general description
including the political structure, economic indicators and similar information. This is followed by
sections on legislation, institutions, permitting, monitoring, inspection and selected industrial pollution
information.
3.3.1 Bosnia-Herzegovina
General Background
The relatively new state of Bosnia-Herzegovina is an administratively decentralized state, organized
into two entities: Federation B&H (F B&H) and Republic of Srpska (RS), both having a high degree
of autonomy. F B&H is further decentralized, into ten cantons each of which has a high degree of
authority in decision making. The Republic of Srpska is more centralized.
Main characteristics of FB&H and macroeconomic indicators, 2001/2002
Indicator Unit
Population
Inhabitants
3 964 388
GDP
USD
7 billion (estimate in2001)
GDP per capita
USD
1 800 (estimate in2001)
Inflation rate
%
5
Unemployment rate
%
40 (estimate 2001)
1 EURO = 1.95BAM (Bosnian convertible mark)
GDP remains far below the 1990 level. Real growth of the GDP in 2001 was estimated at 6%. GDP
distribution is agriculture 16%, industry 28%, services56% (1998 estimated). The main industries are:
steel, coal, iron ore, lead, zinc, manganese, bauxite, vehicle assembly, textiles, tobacco products,
wooden furniture, tank and aircraft assembly, domestic appliances, oil refining.
Environmental issues include air pollution from metallurgical plants; limited sites for disposing urban
waste; water shortages and destruction of infrastructure because of the 1992-95 civil strife.
B&H water courses are part of the Black Sea and Adriatic Sea catchment areas. Of the 51,129 km2,
which is the total area of B&H, 38,719 km2 or 75.7% is part of the Black Sea, that is, the Sava River
catchment area, while 12,410 km2 or 24.3% is part of the Adriatic Sea catchment area. The Black Sea
watershed is the larger. The complete Sava river basin is part of the Danube River basin. The B&H
national legislation defines 5 sub-river basins of the Sava River: Una-Sana, Vrbas, Bosnia, Drina and
Final Report: Industrial reform and the development of policies and legislation towards the reduction
25
of nutrients and dangerous substances
additional sub-river basin with small rivers that are direct tributaries to the Sava River. There are three
sub-river basins Trebisnjica, Neretva and Cetina which are part of the Adriatic Sea watershed.
Federation of Bosnia and Herzegovina (F B&H)
Water related legislation
There is a new water law, which was approved by the state Parliament in both entities. The law mainly
provides for the establishment and financing of the public water companies, but there are problems
providing sufficient data on permits, legal procedures, international standards and conditions for water
use.
The Federal Water Law (OJ F FBiH 18/98) states that it is necessary to adopt 22 regulations, decrees
and by-laws. Cantonal water laws exist in Sarajevo, Tuzla Zenicko-dobojski and Srednjebosanski
canton. Unsko-sanski and Bosanskopodrinjski cantons use the federal law. Furthermore, the Water
Law does not clearly state what matters are to be regulated by cantonal water laws. The Federal Water
Law creates basic requirements for the control of industrial water pollution.
There is a Regulation on Dangerous Substances which stipulates substances which must not be
discharged into water and a regulation on maximal concentrations of contaminants as well as radio
nuclides.
The country lacks an effective framework for environmental licensing. However, a new set of laws on
environment related issues were recently adopted by the Assembly in both entities F B&H and RS.
Environmental Framework Law includes the following sectoral environment laws, Law on Water
Protection, Law on Waste Management, Law on Nature Protection, and Law on Air Protection. This
new framework will build upon the principles of the integrated permit system. The laws do not
correspond with the water regulation within EU.
EU Directive
Compliance
Water Framework
not transposed
Dangerous Substances
not fully transposed but partially covered in existing
Water Law
Integrated Prevention and Pollution not transposed but the principle is contained in the
Control
Environmental Framework Law
Seveso
not fully transposed, some proposals considered
EIA
not transposed but is addressed in the Environmental
Framework Law
EMAS not
transposed
Institutions
The Federation consists of ten cantons. According to the Federation Constitution, the cantons have all
competencies not expressly granted to the Federation Government. The cantons exercise self-
government through their own legislatures, executives and judiciaries.
Bosnia-Herzegovina does not have either a ministry or agency responsible for environmental issues.
Instead the responsibility is shared among at least four ministries: Ministry of Foreign Affairs,
Ministry of Foreign Trade and Economic Relations, Ministry of European Integration, and Ministry of
Civil Affairs and Communications. In the F B&H (similarly to the Republika Srpska) there are two
ministries responsible for environmental protection Ministry of Agriculture, Forestry and Water
Management and the Ministry of Physical Planning and Environment. The first concentrates on water
management, the second on the water and air protection and waste management.
The main functions and tasks related to water are assigned to the cantons. The Cantonal Ministry
responsible for water management is usually the ministry of Agriculture, Water Management and
Forestry. They are responsible for licensing and allocation of water resources (drainage, irrigation,
water supply, waterways for navigation, hydropower, and water protection). The other water sector
responsibilities are split among cantonal ministries of physical planning and environment. The former
UNDP/GEF Danube Regional Project
26
have jurisdiction over the ownership of water utilities and are responsible for the operation and
maintenance as well as investments in these facilities. The latter will be responsible for water
resources, new water sources, flood control, water pollution control and new investments in the
relevant facilities.
In order to coordinate environmental issues between the two entities two inter-entity bodies, called the
Commission for Water and the Environmental Steering Committee, were established in 1998. There
are some overlapping duties referred to in the memoranda of understanding on the establishment of
these steering committees. The Water Steering Committee is in charge of co-operation between the
competent ministries of the entities in water matters, aiming to eliminate eventual conflicts in water
management. Some of the tasks for the Commission for Water are:
· International relations
· Harmonize the water management regulations
· Harmonize water quality standards and monitoring of water quality
· Compile and exchange information between the two entities
The tasks of the Environmental Steering Committee (ESC) are similar but related to environmental
issues. ESC deals with all issues related to the environment, coordinating between the competent
ministries of the entities.
The major sources of pollution usually come from government-owned companies, which cause
problems in regulation. The relationship between the polluter and the regulator has a tendency to be
too close and thus the laws are poorly enforced. The direct relationship between the government and
the companies has made it difficult for the public administration to acknowledge environmental
problems.
F B&H has only a few cleaner production initiatives and the environmental regulation does not fully
support these initiatives.
Permitting
Water acts describe conditions, approvals and permits for water. They also give conditions for other
permits e.g. construction, mining. Permits are issued by cantonal and the federal (FB&H) Ministry of
Water Management. Permits contain conditions for water consumption (quantity, site and way of
extraction), conditions for water discharge (degree of water treatment/cleaning, quantity, quality and
site of water discharge), fees, etc. Permits are time limited having validity between one and 30 years.
The organizational structure causes problems and overlaps in the permit system. Both the Ministry of
Physical Planning and Environment and the cantons have permit systems for large companies. The
central ministry has a uniform applications procedure throughout the Federation on permitting and
inspecting large and medium-sized companies. During the permit procedure the Ministry of
Agriculture, Water Management and Forestry should be consulted. The permit is given in three steps:
1) Location permit, 2) Building permit and 3) Resource use permit. In the case where the cantons also
have permit systems it complicates the process for the companies and in some cases they do not know
where to apply.
Monitoring
There are different lists, which attempt to identify the major companies but since the war there has not
been regular reporting of industries. Consequently there is no updated database in the area.
There is no uniform system monitoring the emissions from the companies. In some cantons
monitoring is mentioned in the legislation, however even when it is in the legislation generally it is not
done. A few cantons monitor on an ad-hoc basis. The major monitoring agencies are the Public
Enterprise for the Sava River Basin and the Hydro meteorological Institute of the FB&H.
There is no national monitoring.
Final Report: Industrial reform and the development of policies and legislation towards the reduction
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of nutrients and dangerous substances
Inspection
Water management inspection is performed at both the cantonal and federal level (Ministry of
Agriculture, Water management and Forestry). It can be either a planned (regular) inspection or for a
specific purpose.
Inspection includes:
· check of documents (permits)
· site inspection
· check of specific parameters check (quantity and quality of water, waste water, technology,
fees
· check of daily records
· identifying corrective measures as necessary
The inspection function is limited due to lack of resources.
Republic of Srpska (RS)
Water related legislation
The RS Water Law was enacted in 1998 (OG 10/1998). The general provisions define the principal
concepts used in the Law. Water belongs to the category of goods of public interest and it cannot be
privately owned. The Water Law provides for the systematic control of water quality, an obligation to
install measuring instruments in water supply companies (municipal or other) and requirements for
reporting the volume of abstracted water. The laws do not fully correspond with the water regulation
within the EU; however the Water Law is supplemented by several Books of Rules as follows:
· Book of Rules on treatment and discharge of waste waters for cities and settlements where
there is no sewerage system;
· Book of Rules on conditions of waste water discharge into public sewerage system;
· Book of Rules on conditions of waste water discharge into surface waters;
· Book of Rules on way and methods of determination of pollution level of waste water as basis
for determination of water management fee;
· Book of Rules on conditions that water management laboratory must fulfill in order to
perform surface, ground and waste water quality examination;
· Decree on water course classification and categorization.
Additional national legislation (book of rules), are harmonized with the main requirements of the
WFD (pollutant list, monitoring requirements, water management bodies responsibilities, pollutants
parameters and emission limits are defined by those Book of Rules, and most are harmonized with the
WFD). Although the Act does not fully correspond with the EU water regulation the basic WFD
requirements are already transposed.
There is another Act on Water Protection prepared by the Ministry of Urbanism, Space Planning, Civil
Engineering and Environment published in 2002 (OG 53/2002). There is some overlap between these
two pieces of legislation.
EU Directive
Compliance
Water Framework
not fully transposed but basic requirements already in compliance
Dangerous Substances
not transposed
Integrated Prevention and not transposed
Pollution Control
Seveso not
transposed
EIA not
transposed
EMAS not
transposed
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Institutions
The water management in the RS is under the responsibility of the Ministry of Agriculture, Forestry
and Water Management (MoAFW). However, also the Ministry of Health and Social Protection,
Ministry of Space Planning, Civil Engineering and Environment, the Ministry of Industry and the
Ministry of Energy and Mining are involved in industrial environmental regulation. Unlike the
Federation of Bosnia-Herzegovina the republic is not divided in cantons. The only decentralized
authority is the municipalities.
The Ministry of Agriculture, Forestry and Water Management (MoAFW) is among other things
responsible for:
· defining the provisions relative to harmful and hazardous substances and sanitary-technical
conditions for wastewater;
· proposing programs for systematic water and wastewater control and provisions relative to the
control methods;
· defining conditions (staff, equipment etc.) for companies authorized to control surface and
groundwater quality;
· proposing to the Government the basis of and rates for the general and specific water
management fee, and the calculation method.
· establishing an inventory of existing water management facilities, financed by grants, taxes or
public contributions.
Under the MoAFW is the Republic Directorate for Waters (RDW).
· The RDW is in charge of implementing the long-term, medium-term and annual plans for
water management development. The Directorate for Water prepares the Plan for budget
allocation, to be adopted and implemented by the Government.. It decides about the projects
needed and tasks to be performed and also acts as a central data collection body. The Ministry
of the Finance collects the fees. The Republic of Srpska Government determines the size of
the budget for the Directorate. The fees are used/distributed centrally and only a small portion
goes to the water protection sector. The RDW also finances water quality monitoring.
The Republic Directorate for Waters has close cooperation with the following institutions:
· The Institute for Water (WI) in Bijeljina which is responsible for water quality monitoring and
discharge monitoring from industries and other polluters. Even if the WI conducts the majority
of the monitoring tasks it is not an institution appointed by the legislation to be responsible for
water quality monitoring.
· The Institute for Water Management is responsible for water management (river basin
management, water supply and consumption, sewerage, etc.).
According to the Water Law, the MoAFW and the Ministry of Health and Social Protection
(MoHSP) cooperate by performing several water management duties as follows:
· plans for protection against pollution ;
· regulations on the classification of waters and categorization of water streams;
· approval of regulations on the methods for monitoring water pollution and methods for
wastewater quality tests;
· approval of regulations on the quality of water used for the irrigation of agriculture and water
supply for fish ponds; and
· approval of regulations on the conditions that companies authorized for wastewater quality
tests must meet, and approval of such companies .
The MoHSP also approves regulations on the quality of drinking water and water used for food
processing and recreation, and defines zones for protection of potable water supplies.
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of nutrients and dangerous substances
Permitting
Regarding the permit system, large companies submit the application to the local municipality, which
is forwarded to the Ministry of Space Planning, Civil Engineering and Environment where the
Urbanism, Housing-Communal Services, Civil Engineering and Ecology departments handle the
application. This Ministry consults with the municipality when making the permit decision. The
permit covers building location, construction and operation. Further requirements can be added if
necessary. Permits for smaller companies consist of the same parameters as for larger ones but are
under the responsibility of the municipalities.
Monitoring
The water quality monitoring is done at the central level. In accordance with the above-mentioned
legislation the WI prepares an Annual Plan of monitoring which is approved by the Directorate for
Water. Currently 4 series of surface water monitoring are performed annually, at 25 measurement
points, 4 points on the Sava River and the others on the Sava tributaries in B&H. A professional team
of the WI directly takes the necessary number of water samples, transports them to the laboratory and
performs the laboratory analysis. The Laboratory uses Standard Methods of control for certain
parameters. Results are then distributed to the Directorate for Water, in written and electronic format.
The quantity parameters of surface water and groundwater are reviewed and examined by RS Hydro-
Meteorological Institute. These data are public and can be obtained free of charge.
The Book of Rules on conditions of waste water discharge into surface waters and the Book of Rules
on the methods and measurements of determination of pollution level of waste water as a basis for
determination of water management fee are defining way, methods and obligation of waste waters
quality and quantity monitoring. According to the latter one, all industrial facilities are obliged to
engage authorized laboratory annually for waste water quality control. Polluters that have 500 PE
are obliged to perform waste water quality control once a year. Polluters that have > 500 PE are
obliged to perform at least 4 controls a year. Authorized laboratories for waste waters quality control
in RS are: The Laboratory of the Institute for Water Bijeljina, Hemix laboratory in Banja Luka and
Laboratory of the Faculty for Chemical Engineering in Zvornik. According to valid book of rules a
laboratory is obliged to transmit one copy of analysis to the Republic Directorate for Waters that
collects and stores all data. According to the law, major polluters are obliged to do self-monitoring in
their own laboratories or in authorized ones.
Since 1991 no data were sent from RS to the ICPDR. Republic Directorate for Waters or an authorized
institution is in position to deliver such data.
Inspection
The inspection situation in the RS is similar to the one in B&H. The Ministry of Space Planning, Civil
Engineering and Ecology carry out inspections. But they are random due to lack of staff and
equipment. However, also, the municipalities perform the environmental inspections. The situation
with registration of the companies and environmental monitoring is similar to the one in the
Federation.
Industrial pollution in the FB&H and RS
Industrial pollution in B&H
The industrial pollution in B&H origins from following industries
· steel production
· coal, iron ore, lead, zinc, manganese and bauxite mining
· vehicle assembly
· textiles, tobacco products, wooden furniture and domestic appliances production
· tank and aircraft assembly
· oil refining
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Industrial pollution in RS
Republic of Srpska has data on all industrial polluters before the war. After the war due to
transition process and economic situation, most of industries stopped working or they work
with small capacities.
In RS there are all kinds of industries:
· in agriculture fruit and vegetable processing
· wood processing;
· smaller capacities of meat and meat products processing;
· smaller capacities of steel producing;
· two oil refineries;
· two steam power plants;
· production of paper;
· smaller capacities of leather processing and textile industry
3.3.2 Bulgaria
General background
The territory of Bulgaria covers about 111 000 km2. Administratively, the country is divided into 28
regions and 262 municipalities. The population is 8 million. Most of population is concentrated in
urban areas (about 69%). The average density of the population is 74, 2 persons/km2. The most
urbanized parts of the country are the metropolitan areas Sofia, Plovdiv and Varna.
Main characteristics of Bulgaria and macroeconomic indicators
Unit
Indicator
Population
Inhabitants
7 621 337 (July 2002 estimated)
GDP
USD
50,6 billion (2002 estimate)
GDP per capita
USD
6 600 (2002 estimate)
Inflation rate
%
5,9 (2002 estimate)
Unemployment rate
%
18 (2002 estimate)
Exchange rate 1 EURO = 2.21 Lev (BGL)
Bulgaria, a former socialist country striving to enter the EU, has experienced macroeconomic stability
and positive growth rates since a major economic downturn in 1996 led to the fall of the socialist
government. A $300 million stand-by agreement negotiated with the IMF at the end of 2001 will help
the government maintain economic stability as it seeks to overcome high rates of poverty and
unemployment and, at the same time, cut the budget deficit and contain inflation.
The main industries are: electricity, gas and water; food, beverages and tobacco; machinery and
equipment, base metals, chemical products, coke, refined petroleum and nuclear fuel. Environmental
pollution issues include: air pollution from industrial emissions; rivers polluted from raw sewage,
heavy metals, detergents; deforestation; forest damage from air pollution and resulting acid rain; soil
contamination from heavy metals from metallurgical plants and industrial wastes.
The percentage of the Bulgarian territory draining to the Danube River, Black Sea and Mediterranean
Sea is 31.6%, 20.1% and 48.3%, respectively. The country has a well-developed water supply system,
servicing about 98% of the population. The sewerage connection covers 49% of which 70% is towns.
Water related legislation
Based upon the Strategy for Integrated Water Management, the Water Act was adopted in 1999 and
entered into force in 2000. The Act provides for water management at three levels: the Council of
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of nutrients and dangerous substances
Ministers, the Ministry of Environment and Water, and the Basin Directorates. It transposes the basic
principles of the EU water policy. The Water Act has 16 Regulations, which transpose the
requirements of the all EU water related directives. These are the Regulation on the Emission Limit
Values of Dangerous Substances in wastewater discharged in water bodies (State Gazette No
97/2000); Regulation on Wastewater discharge in the sewage systems (State Gazette No 98/2000), and
Regulation on Requirements for water quality of coastal sea waters (State Gazette No 10/2001).
The new requirements concerning the Water Framework Directive need some amendments of the
national legislation (Water Act).
The following table summarizes the compliance of Bulgaria with the main EU directives dealing with
industrial water pollution.
Directive Compliance
Water Framework
Partially transposed, the amendment of Water Act is planned.
Full harmonization is expected in the 2005.
Dangerous Substances
Transposed, Act on Emission Limit Values of Dangerous
Substances adopted in 2000
Integrated Prevention and Pollution Transposed, The Act on Environmental Protection adopted
Control
in 2002,
Seveso Not
transposed
EIA
Transposed and implemented, Act on EIA adopted in 1998
EMAS N/A
Institutions
Environmental protection is administered by the Ministry of Environment and Waters (MEW), the
Executive Agency of the Environment (EEA), and 15 regional bodies and municipalities. The Ministry
of the Environment and Waters (MEW) with Regional Inspectorates in the country is responsible for
development and implementation of environmental legislation, decision-making including water
quality and quantity monitoring. The water management is carried out through the Water Directorate.
The country is divided into four river basins Danube, Black Sea, East Aegean and West Aegean
river basins.
The EEA is an administrative body established in 1999 to carry out and coordinate information and
monitoring services. It is the governing body of the National System for Environmental Monitoring
and is a National Reference Center for the European Environment Agency.
The main institution responsible for most of the water supply systems and sewerage facilities in
Bulgaria is the Ministry of the Regional Development and Public Works (MRDPW). At the end of
2001, there were 48 Water Supply & Sewerage Companies (WSSCs) set up in Bulgaria.
Permitting
Permits are issued under the Water Act, which stipulates that a permit shall be required in all cases of
water use of more than 10 m3/day. The water use includes taking water from river bodies as well as the
utilization of water energy. In addition, permits for use of water bodies are required for:
· new construction, reconstruction or upgrade of existing systems and facilities adjusting flows,
exploration and drawing from underground water, discharge of water, the extraction of sand,
ballast and recreation and water sports
· engagement in activities such as commercial fishing, fish breeding,
· other actions that affect the natural state of a water body.
Permits are issued under the provision of the Water Act, except in cases when an EIA is required as
stipulated by the Environmental Protection Act and the decision on assessment contains all
components of a permits required by the Water Act. Permits are issued by:
· the Council of Ministers when related to the needs of defense and national security
· the MEW for water and dam use, use of domestic sea waters, and of the Danube River,
discharge of wastewater containing dangerous substances into the ground,
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· the MEW, after gaining consent from the Ministry of Defense and the Ministry of Transport
for use of parts of the Danube river, domestic sea waters, or the territorial sea, and
· the Director of the Water Basin Directorate for all other cases of water use and use of water
bodies under public state ownership.
The IPPC legislation has been fully harmonized in 2002. It is partially covered by the Environmental
Protection and the IPPC Regulation. There are following competencies
Assessment of the application is done by the Executive Environmental Agency, Regional
Inspectorates (RI) and Basin Directorates
The Executive Environmental Agency and/or Regional Inspectorate Preparation prepare the permit
which is then issued by the Ministry of Environment or Director of RI.
Regional Inspectorates control and inspect the permits.
The Ministry of Environment and Water prepares of methodologies and the BAT database
The Executive Environmental Agency registers the permits and results of monitoring.
Regional Inspectorates have prepared the inventory installations falling under the scope of the
industrial pollution control legislation. There is a strong tendency to issue single permit for all
installation at one site (company).
All the procedures for issuing permits are legally specified, including the scope of information
required and periods for issuing a permit. In general, any official documentation has to be considered
and answered by the competent authority. There is a tendency to increase the negotiation elements in
permitting between the applicant and the competent authority, especially by consultations before the
application for a permit.
Monitoring
The institutions responsible for water monitoring are:
· Bulgarian Environmental Agency (National System for Environmental Monitoring)
· Regional inspectorates for monitoring of all environmental components
Hydrological monitoring is managed and implemented by the National Institute of Meteorology and
Hydrology, a branch of the Academy of Science. The Institute operates 209 stations on rivers and 461
for ground water monitoring. The monitoring equipment is rather old and inefficient. All data for the
year are not publicly available and there are few publications.
Urban and industrial discharges are monitored through forms completed annually by the regional
water companies and about 1 070 industrial facilities. The reports include the volumes treated and
discharged. Similar but different forms have to be completed for the national statistical agency and for
the Executive Environmental Agency. For control purposes, occasional sampling and analysis of
discharged water is carried out. No information is available about industries discharging into urban
sewage networks.
In general the laboratories are internal to the institutions (EEA, Regional Inspectorates). In a few cases
there are contracts with external laboratories on specific tasks. All the laboratories in the EEA and
some of the laboratories in the Regional inspectorates are accredited and others are in the process of
being accredited. It should be noted that when new standards are applied then additional accreditation
will be required.
Data collection, analysis and dissemination are not well developed. However, currently monitoring
data are communicated to the public by:
· Ministerial Bulletin
· Year book on the Environment
· The primary monitoring data are available only under by written request.
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of nutrients and dangerous substances
Inspection
The main institutions responsible for inspection are:
· The Regional Inspectorates, in certain cases assisted by the EEA or MEW experts
· The municipalities also have also responsibilities related to urban planning and communal
services.
The level of integration is not very high. Usually inspections are carried out on an individual medium
basis water, air, waste. Practically all of the inspectors in Regional Inspectorates are specialized in
different media. The level of integration will increase significantly as integrated permitting is being
implemented. At present some training on such inspections is provided in parallel to the issuing of
pilot integrated permits.
In general the inspections are oriented towards the large enterprises and problematic facilities.
Inspectors may suspend the operation of production lines in an installation if necessary and the
Minister for Environment can issue an order to stop the whole operation of the installation. The
Inspectorate can levy administrative penalties as defined by Law. For of small infringements only
prescriptions are made. The sanctions and fines are implemented where the violations are severe.
However, charges need to be increased and require greater correlation with the pollution impact.
Industrial pollution
The main industries are electricity, gas and water; food, beverages and tobacco; machinery
and equipment, base metals, chemical products, coke, refined petroleum and nuclear fuel.
Environmental pollution issues include air pollution from industrial emissions; rivers polluted from
raw sewage, heavy metals, detergents; deforestation; forest damage from air pollution and resulting
acid rain; soil contamination from heavy metals from metallurgical plants and industrial wastes.
3.3.3 Croatia
General background
Croatia has been an independent state from 1991. Although Croatia declared its independence from
Yugoslavia in 1991, it was 1998 before the current territory was brought under the Croatian
Government. The country is divided into 20 counties and one city (Zagreb). Croatia has an area of
56542 km2.
Main characteristics of Croatia and macroeconomic indicators
Indicator Unit
Population
Inhabitants
4,390,751 (July 2002)
GDP
USD
38.9 billion (2002 est.)
GDP per capita
USD
8,800 (2002 est.)
Inflation rate
%
4
Unemployment rate
%
20,2
1 EURO = 7.74 (HRK) hrvatska kuna (in 2002)
Before the dissolution of Yugoslavia, the Republic of Croatia, after Slovenia, was the most prosperous
and industrialized area, with a per capita output perhaps one-third above the Yugoslav average. The
economy emerged from its mild recession in 2000 with tourism the main factor, but massive structural
unemployment remains a key negative element. The government's failure to press the economic
reforms needed to spur growth is largely the result of coalition politics and public resistance,
particularly from the trade unions, to measures that would cut jobs, wages, or social benefits. As a
result, the country is likely to experience only moderate growth without disciplined fiscal and
structural reform.
The main water problem in Croatia is that a large part of population do not have public water supply.
Also, and there are not enough sewage systems and the existing ones are in bad condition. The
majority of municipalities discharge untreated water. Thirty percent of the companies discharge
through a municipal sewage system, even though the discharge is not properly pre-treated.
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Water related legislation
In the Constitution of Croatia (1990) conservation of nature and human environment is a high priority.
This is supported by the Declaration of Environmental Protection (34/1992) that describes the course
for future environmental legislation. It declares that Croatia should work towards a legislative system
in accordance with international and European standards. Further it stresses the importance of using
physical planning to achieve sustainable development. Another important law is the Law on
Environmental Protection (82/1994). It lays down the principles for sustainable development. Further
it introduces environmental impact assessment, the Polluter Pay Principle and an Environmental
Protection Information System. The law also includes water management objectives and principles.
In 1992 the Strategy for Water Protection identified three goals in water management.
· To supply 90% of the population with public water supply
· To repair and construct sewage treatment plants
· Increase the protection against floods.
The Water Act (107/1995) is an umbrella law that integrates the previous regulations. It establishes the
ownership and legal status of water and delegates the responsibilities among the different authorities.
The laws do not correspond with the water legislation within the EU.
EU Directive
Compliance
Water Framework
not transposed
Dangerous Substances
not transposed
Integrated Prevention and Pollution Control
not transposed
Seveso not
transposed
EIA not
transposed
EMAS not
transposed
Articles 72 and 73 of the Water Act (Official Gazette No. 107/95) determine that in order to prevent
deterioration of water quality and to protect the environment in general, the limit values of hazardous
and other substances shall be prescribed, as follows: for technological waste water before its release
into public sewerage system or other receiving water; for water being released, after treatment, from
the public sewerage system into natural receiving water; and for waste water and substances
discharged into sumps and collector tanks." According to the Ordinance on limit values of parameters,
hazardous and other substances in waste water (Official Gazette Nos. 40/99, 6/01), the limit values and
permitted concentrations for technological waste water are defined by parameters and in relation to the
recipient waters. For discharges into a natural recipient there are four limit values defined depending
on the class (planned type) of water (classes II., III., IV., and V.), including the fifth limit value, which
is related to waste water discharge into the public sewerage system.
Allowed limit values of parameters and allowed concentrations of hazardous and other substances
discharged into the public sewerage system or natural water courses as well as special measures for
emissions reduction of substances in waste water from individual industrial sectors should be also
determined based upon the specific technologies and the use of best available technology which may
be different from the prescribed values for parameters in the special annexes of the Ordinance on limit
values. Currently, the only completed annex is the annex for leather and fur producing plants.
There is no integrated permitting and the IPPC directive has not been implemented.
Institutions
In 2000 the Ministry of Environmental Protection and Physical Planning (MoEPPP) was established.
Before that environmental responsibilities were divided between many different ministries. Even
though Croatia now has an environmental ministry other ministries and state organizations are
involved in environmental issues. These are Ministry of Agriculture and Forestry, Ministry of Health,
Ministry of Maritime Affairs, Transport and Communication and Ministry of Economy and State
Water Directorate.
In accordance with the Law on Structure and Scope of State Ministries and State Administrative
Institutions (Official Gazette Nos. 48/ 98, 15/00, 29/00 ), the State Water Directorate performs
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35
of nutrients and dangerous substances
administrative and other tasks related to management of waters and water management system;
monitoring and adapting of water management development to the needs of economic development;
regulation of watercourses and other water bodies and the protection from adverse effects of water and
ice; protection from erosion and torrents, hydro amelioration drainage and irrigation; management and
use of water estate; protection of water and sea from land-based pollution; securing water reserves for
water supply of settlements with drinking water and industries with industrial water; use of
hydropower; planning and harmonizing development and construction of public water supply and
sewerage systems of national interest and performing inspection activities.
In line with Article 156 of the Water Act, Hrvatske Vode (Croatian Water) - the legal entity for water
management - was established for the purpose of performing of the activities constituting the
management of state and local waters.
Several weaknesses have been identified in the administrative organization. First, there is a shortage of
staff and adequate qualifications in all parts of the administration. Second, the different authorities
tend to disagree over competences thus there is a problem coordination similar activities between
different authorities. Also the authorities lack proper equipment.
Permitting
Both the Inspectorate under the MoEPPP and the Environmental County Offices issue permits and
carry out inspections. The permit covers three steps: 1) location permit, 2) EIA and 3) building
permits. The EIA is supposed to be carried out before the location permit or any special permits on
e.g. water or nature are approved. However this is not always achieved.
Water management approval
The legal entity or physical person which has obtained the water management terms must, before the
start of the construction or other works, apply for the Water Management Approval from the relevant
body. The Water Management Approval confirms that the documentation for construction or other
works is prepared in accordance with the water management terms.
The validity of water management terms, for which the approval has not been obtained, shall expire
two years following the issue date.
The validity of water management terms for which the approval has been issued shall expire two years
from the date of issuing of the approval if the date of the application for construction permit has not
started.
Water management permit
The water management permit regulates the permission for water use and defines the purpose,
location, method, conditions and extent of water use and discharging of waste water: hazardous or
other substances that may pollute or contaminate water.
The water management permit is required for water use and discharging of waste water in connection
with industrial and other activities, and with activities involving water intake and use and discharging
of waste water.
The water management permit is issued by the relevant County office, based on the previously
obtained opinion from Hrvatske Vode. In certain cases, the water management permit is issued by
Hrvatske Vode, with confirmation of State water Directorate for:
· industrial and other activities involving the intake and use of the water from an interstate
watercourse or discharging of waste water into an interstate watercourse,
· for activities in chemical, textile, leather, food-processing, metal, construction, petrochemical and
other industries involving hazardous substances in the technological process,
· activities and services in sea and river transport (ports and harbors),
· hydropower plants with the capacity of 20 MW or more,
· transport and storage of oil, gas and other hazardous substances,
· water supply systems exceeding the capacity of 10 l/sec,
· running the public sewerage systems.
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The water management permit is issued for specific period of no longer than 15 years (in practice no
longer than 5 years).
In order to prevent deterioration of water quality and to protect the environment in general, the limit
values of hazardous and other substances are prescribed in water management permits.
Permit ordinance
The permit ordinance is a document issued along with the water management permit in order to adjust
the behavior and activities of the permit holder with the conditions and responsibilities resulting there
from. The permit ordinance orders the holder of the water management permit to take an action, carry
out an investment or to abstain from some action in order to eliminate the risk possible or already
existing disturbance, or non-compliance with the conditions and responsibilities under ta water
management permit, and to establish the conditions in compliance with this Act.
The permit ordinance is issued by the same body which has issued the water management permit.
A permit ordinance may be issued during the entire period of validity of a water management permit.
The copy of the water management and permit ordinance are sent to the relevant water management
inspector. The water management inspector shall advise the State Water Directorate to cancel the
water management permit and permit ordinance, or propose temporary withdrawal of the permit,
permit ordinance for following reasons:
· if the holder fails, within a specified period, to carry out the activities or investment, or to obtain
from some activities as required by the permit ordinance,
· if non-compliance with the permit ordinance is likely to result in serious hazard to human lives
and health or in economic problems.
The detail procedure related to the issuing of the water management legal acts is specified within
Regulation on issuing of water management legal acts. The procedures of issuing of water
management legal acts are subject to the provisions of the General Administrative Procedure Act.
Monitoring
The environmental law (1994) introduced the Environmental Protection Information System. The
system consists of ten components of which water is one. Each of these components is supposed to
have an independent information system. However none of these systems are functioning yet possibly
because of the complexity because several authorities are involved. However, in general, the country
needs adequate data on the state of the environment, information on what data already exist and
adequate statistical data. Hrvatske Vode, which monitors the status of waters and provides the State
Water Directorate with information, has made great progress. They have established a GIS center,
which should be responsible for the water information systems. The initiation and development of the
Water Information System (WIS) is seen as the measure aimed at creating timely and available
information in the field of water management. This forms the basis for ensuring public access to
information, systematic and continuous collection, processing and adequate presentation of data and
information.
The Water Act, Chapter 10, in Articles 113 118 outlines the obligation of keeping of water-related
documentation, and in Article 158 the managing of the integrated water information system, which
should enable the keeping of water related documents in accordance with current information
technology.
A Water Information System project due to be completed in 2007 has the objective to the task of the
WIS to systematically and timely collect, process, exchange and enable access to data and information
both internally, to the Water State Directorate and Hrvatske Vode, and externally, to state
administration authorities, international institutions and all interested parties, the general public in
particular.
Water pollution is registered at Hrvatske Vode. All polluters with permits must provide information
about emissions to the counties. The emission is then forwarded to Hrvatske Vode which obtains data
on all the discharges to the waters. Currently the data are available on request.
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of nutrients and dangerous substances
The data on monitoring of polluters and pollution are delivered to the ICPDR through national
members of EMIS EG, MLIM EG and APC EG.
Inspection
Inspection according to the Water Act and subsidiary regulations is carried out by the State Water
Directorate (hereafter: State Water Management Inspection) and the County offices in charge in water
management (hereafter: County Water Management Inspection). Water management inspection may
also be performed by other government officials authorized by the Director of the State Water
Directorate.
Water management inspection supervises in particular:
· the conditions of the watercourses,
· technical condition and proper use of water works and plants,
· the use of water and water estate in accordance with this Act, water management legal acts and
concession agreements,
· the status of water pollution and contamination and implementation of water protection measures,
the compliance with the conditions determined by the water management legal acts,
· preparing and implementation of flood protection measures and other measures for protection
from adverse effects of water.
The State Water Management Inspection supervises the application of the provisions hereof and other
regulations, and implementation of measures in water management referring to interstate
commitments, works and the conditions of water system on interstate and national waters and the
coastal sea, preparing and implementing, between others, the National Water Protection Plan,
compliance with water management legal acts.
The State Water Management Inspection may directly carry out the responsibilities of a County, if this
is considered the only way to implement the provisions of this Act and other regulations. This occurs
when the authorized water management inspection has failed to carry out the supervision in time, or
has not completed the procedure by the specified time-limit.
In case of a violation of the environmental regulations the Inspectorate can impose a fine or suspend
the work permit.
Industrial pollution
The main industries include chemicals and plastics, machine tools, fabricated metal, electronics, pig
iron and rolled steel products, aluminum, paper, wood products, construction materials, textiles,
shipbuilding, petroleum and petroleum refining, food and beverages and tourism.
The most serious pollution issues: air pollution (from metallurgical plants) and resulting acid rain is
damaging the forests; coastal pollution from industrial and domestic waste; landmine removal and
reconstruction of infrastructure consequent to 1992-95 civil war.
The main industrial waters are released from the food, chemical, pulp and paper and fertilizer
industries.
Every industrial company must have a Waste Water Discharge Permit, proscribing the quantity and
quality of waste water discharged into the recipient-surface water or sewerage. To meet these
obligations in the majority of cases it is necessary to build a site specific waste water pre-treatment
plant.
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3.3.4 Czech Republic
General Background
The territory of the Czech Republic covers 78 866 km2. The area within the Danube basin is about 21
000 km2. The country is administratively divided into 13 regions and one (capital) city. Within this
broader administrative division there are 6 323 municipalities. The Czech Republic has a population of
around 10 million of which 2,7 million of inhabitants live in the Danube basin.
Main characteristics of Czech Republic and macroeconomic indicators
Unit
Indicator
Population
Inhabitants
10,256,760 (July 2002 .)
GDP
USD
58,1 bill. (OECD, 2002)
GDP per capita
USD
5 600 (2002)
Inflation rate
%
2,2
Unemployment rate
%
8,5
1 EURO = 33,1 CZK (Czech crown) in 2002
The Czech Republic is one of the advanced transition economies entering the EU in 2004. The
following industrial sectors contributed to the total GDP as follows: services 56%, industry 41% and
agriculture 4%.
Water related legislation
The Czech Republic will enter the EU in 2004 and all water related legislation was transposed and is
being implemented. Some changes in the Water Act (254/2001) will be required to fully harmonize
with the Water Framework Directive. There are also implementing regulations on emission limits
(Government Order 61/2003 Coll.), River Basin Management Planning (Ministerial Decree 140/2003
Coll.) and a range of administrative matters (definition of River Basin Districts, record keeping
requirements for water authorities etc.). Further secondary legislation pursuant to the Water Act is
being prepared in respect of monitoring of the water environment.
The Water Act requires that anybody discharging wastewater into ground or surface water must ensure
that the quality of the receiving water will not be deteriorated. It should be noted that direct discharge
of wastewater to groundwater is not generally permitted. Also, appropriate treatment of discharged
waters must be established and a permit issued prior to discharging to the receiving water. A new Act
on IPPC has been adopted and is being implemented through the Regional Authorities, the Ministry of
Environment, the Czech Ecological Institute and the Czech Environmental Inspectorate.
EU Directive
Compliance
Water Framework
The Directive has been substantially transposed. The Water Act and
the Decree on River Basin Management Planning will be amended
before the date of accession in order to ensure full transposition.
Dangerous Substances
Fully transposed. Implementation underway.
Integrated Prevention and Fully transposed, being implemented.
Pollution Control
Existing installations to be permitted by October 2007
Seveso
Fully transposed, but some elements of implementation still require
attention
EIA
Fully transposed and implemented2
EMAS Fully
transposed
Institutions
Two main ministries are involved in the administration of water issues: Ministry of Environment
(MoE) and Ministry of Agriculture (MoA). The MoE is the environmental supervisory body and flood
2 Strategic EIA implementation to be completed by July 2004
Final Report: Industrial reform and the development of policies and legislation towards the reduction
39
of nutrients and dangerous substances
prevention body, MoA is the authority responsible for water management (including urban
wastewater). The Ministry of Agriculture is also responsible for issues associated with state water
management policy and planning, river basin administration, technical works and amelioration,
sewerage and water mains.
There are five River Basin Administrations (Povodí) which are state enterprises under the supervision
of the Ministry of Agriculture. The cover the whole of the country, are responsible for investment in
water management projects, participate in permitting of certain water uses and levy charges on water
users. The MoE directs the Czech Hydrometeorological Institute (the expert body covering
meteorological and hydrological issues and ambient air monitoring) and the T.G. Masaryk Water
Research Institute (the research center).
Permitting
There are 205 Authorized Municipal Offices and 14 Regional Offices (inc. Prague) that are permitting
institutions. In many cases the same organization is responsible for both permitting and
inspection/enforcement, so the approach allows feed-back. However, in practice a great deal of
inspection is undertaken by the Czech Environmental Inspection.
The integrated permitting system was recently developed for the IPPC installations. Act on IPPC the
Act on Integrated Pollution Prevention and Control came into effect in 1st January 2003. The Decree
554/2002, establishing the template of the application for integrated permit, the scope and method of
filling in of the application The Government regulation No. 63/2003 on the BAT Information
exchange system came into force in January 2003 and the Government regulation will come into force
in January 2004. The permitting bodies are regional offices and the Czech IPPC Agency is an expert
body that reviews the submitted applications. It is estimated that around 1400 - 1500 installations are
affected by IPPC. By the end of the year 2003 there will be about 30 integrated permits issued.
Monitoring
The majority of monitoring responsibilities is carried out by the Czech Hydrometeorological Institute
which undertakes hydrological and water quality monitoring for both surface water and groundwater.
Additional monitoring is also undertaken by the Agricultural Water Management Authority. At the site
level, monitoring is mainly self-monitoring, linked to permitting standards and enforcement actions.
Only accredited laboratories can be used for monitoring. Where an agency undertakes self-monitoring,
a different (also accredited) laboratory must be used. Self-monitoring data is generated by the
permitted site and passed to the regulators.
The Czech Hydrometerological Institute is the main agency that collects environmental monitoring
data. It is also responsible for the reporting to the ICPDR and other international institutions in
cooperation with the Ministry of Environment and the Water Research Institute.
Inspection
Inspection and enforcement is the responsibility of the Regional Authorities and the Czech
Environmental Inspectorate (CEI). The Czech Environmental Inspectorate is the main body
responsible for environmental enforcement. It has a national office and nine regional offices.
Regional Authorities also have a role in relation to air pollution control, water and nature protection,
while smaller local authorities (Municipalities/Towns) are responsible for the smallest sites. The
Ministry of Health is responsible inspection of drinking water and bathing water quality.
Inspecting authorities can require self-monitoring data to be provided to them. They can also
commission their own monitoring for comparison purposes. Plants do not have full-time inspectors,
only company employees (e.g. environmental managers).
Water discharges are inspected when conditions are changed. Large industrial enterprises are
inspected minimally once a year.
Inspectors of CEI have power of entry to installations. They have right to limit, or to stop immediately
damaging activity, if it is a hazard to human health.
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Industrial pollution
Main industry branches are: metallurgy, machinery and equipment, motor vehicles, glass and chemical
production (explosives), armaments.
Environment pollution issues include air and water pollution in areas of northwest Bohemia and in
northern Moravia around Ostrava present health risks; acid rain damaging forests.
More specific about water pollution from industrial dischargers into the Danube catchment area can be
seen in the Emission Inventory for the Danube Basin undertaken in 2000 under the auspices of the
ICPDR.
3.3.5 Hungary
General background
The Territory of Hungary covers 93 030 km2. The country is administratively divided into19 districts
(megyek) and 20 urban counties. Hungary has a population of 10,3 million and a population density
109,6 inhabitants per km2. Hungary is a country of average urbanization. Nearly two thirds of the
population (64.6%) live in towns and one third in villages (some of them on farmsteads). In the year
2000 the country had 237 towns and 2,898 villages. Almost 40 % of the urban population live in
Budapest, and even more people have ties to the capital city through their jobs.
Main characteristics of Hungary and macroeconomic indicators
Unit
Indicator
Population
Inhabitants
10 075 034
GDP USD 134,7
Billion
(2002)
GDP per capita
USD
13 300 (2002)
Inflation rate
%
5,3
Unemployment rate
%
5,8
1 EURO = 258 HUF (Hungarian forint) in 2003
Hungary continues to demonstrate strong economic growth. . The private sector accounts for over 80%
of GDP. Foreign ownership of and investment in Hungarian firms is widespread, with the cumulative
foreign direct investment totaling more than $23 billion since 1989. Hungarian sovereign debt was
upgraded in 2000 to the second-highest rating among all the Central European transition economies.
Inflation and unemployment - both priority concerns in 2001 - have declined substantially. The key
short-term issue is the reduction of the public sector deficit from 6% of GDP to 4.5% in 2003 and 3%
in 2004. The following industrial sectors contributed to the total GDP (2000) as follows: services 62%,
industry 34% and agriculture 4%.
90% of drinking water relies upon vulnerable groundwater. Almost 98% of the population is served by
public water. The level of sewerage is only about 45% while that of biological wastewater treatment is
30%.
Water related legislation
By the end of 2001, harmonization with EU legislation was completed. Water legislation in Hungary
includes most of the elements of the WFD and, consequently no major changes in legislation are
needed specifically for this directive. Lower level legislation, however, is awaiting significant
reshaping (decrees related to the use and protection of water resources, regulation of wastewater
discharges to surface water, protection of groundwater resources, protection against nitrate pollution,
urban water management, defining quality objectives, river basin management plans preparation and
approval procedures regulation, etc.). The deadline for legal harmonization, December 2003 should be
met.
The most comprehensive law is the Act on Water Management (LVII/1995). An important legislative
tool is the Act on the General Rules of Environmental Protection (LIII/1995), and there are an
additional 7 laws having significant water management implications (Act LXV/1990 on local
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41
of nutrients and dangerous substances
municipalities, Act XI/1991 on State Health Services, Act LIII/1996 on Nature Protection, Act
XXI/1996 on Regional Development, Act LXXVIII/1977 on the Development and Protection of Man-
made Environment, Act XLVIII/1993 on Mining, Act LXXIV/1999 on the Control of Catastrophes.)
The practical application is described in approximately150 decrees.
The Act on Water Management defines two major groups of tasks: public and individual tasks. Public
tasks are to be managed by the state and municipalities. The law includes the following items:
· surface and groundwater resources;
· any establishment or activity that influences runoff and hydraulic conditions of waters, water
quantity, quality, riverbed, shoreline, or the aquifer conditions;
· use and surveillance of water users, management of water resources;
· monitoring activities, evaluation of the state of aquatic environment, research;
· control and protection of water damages.
The following table summarizes the compliance of Hungary with the main EU directives dealing with
industrial water polluters
EU Directive
Compliance
Water Framework
Partially transposed
Dangerous Substances
Transposed in 201/2001 governmental decree
Integrated Prevention and Pollution Transposed in 193/2001 governmental decree
Control
Seveso
Transposed, Act entered into force in 2002
EIA
Transposed, governmental decree EIA adopted
EMAS
It will come into force automatically on the date of accession,
Institutions
The water management and environmental protection belonged to different ministries until May 2002.
Ministries were organizationally merged but regional offices currently remain divided. The regional
organization of water, environment and nature protection is under the umbrella of the Ministry of
Environment and Water. These, however, operate within a regionally independent organizational
frame. Second-degree authority levels and institutions (National Chief Directorate of Water
Management and National Chief Directorate of Environmental and Nature Protection) also act
independently.
Share of tasks between the water and environmental sectors is as follows:
· Water directorates: there are 12 water directorates issuing water right permits and surveillance
(professional control of urban water works and irrigation works, protection of quantity of
water and long-term aquifers), collection of levies and taxes, implementation of large scale
state investments, flood control and access water protection, monitoring and spill control,
international relations.
· Regional environmental inspectorates (REI): authority permissions and control. This
practically means the regional tasks of the protection of the quantitative and qualitative state
of the waters, setting fines, monitoring, and handling water quality emergencies.
The 12 water directorates manage complex tasks in their jurisdiction, except for legislation and
financing. Directorates are managers of the state-owned water structures, and act as investors and the
permitting authority regarding the projects. The priority task is the management and access to waters,
flood control measures, and water protection. Total employment at the water directorates is about
5,000 people.
In addition, there are 12 REIs with areas overlapping the water directorates. The focal point of their
activities is administrative (permitting, control, surveillance, setting and administering fines).
Inspectorates operate water quality labs that are the basis of water quality monitoring in Hungary.
Tasks also include authority measurements to set wastewater fines. They employ power about 1200
people.
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Presently the managed tasks of the two authorities are partially overlapping and complementary
(quantitative protection of water resources, state assessment, monitoring and water quality emergency
control). The regulation is theoretically correct but there are tensions and redundancies in practice.
Many practical questions can only be solved by complicated regulation, i.e., the management of water
quality emergencies, and various permitting procedures.
There is also the Ministry of Internal Affairs responsible for state tasks related to municipalities, The
Ministry of Agriculture and Regional Development responsible for state tasks related to agriculturally
utilized water bodies and water structure, and the Ministry of Health, Social and Family affairs
responsible for human biological aspects (drinking water, bathing, etc.) of water. Coordination
amongst the different ministries is based upon administrative rules of operation including financial
issues. There is no inter ministerial forum for handling water management issues generally. There are
several inter ministerial committees among which two are particularly important:
· Regional and/or governmental committee that manages emergency situations (floods, water
quality emergencies, large scale spills, access water, etc.). This committee is an integrated part
of the flood control and access water management.
· Inter ministerial committee responsible for the introduction EU WFD a governing body that
could fulfill the role of the missing coordination forum.
The Ministry of Environment and Water is responsible for the legal aspects of the IPPC. An IPPC Unit
was established in 2002 in the Institute of Environmental Management dealing mainly with BAT
activities, and of course the regional environmental inspectorates are responsible for the
implementation (permitting procedure and control)
Permitting
The present permitting system in Hungary is complicated and several different permits are required for
new installations to start operation. The water license permitting authority is the Water Directorate.
The Regional Environmental Inspectorates issue the permits for the following:
· Parts of the sewage discharges licensing procedure
· permitting of activities having significant impact on the environment on the basis of EIA.
· IPPC permit
In addition, the National General Directorate for the Prevention of Disasters started operation in
January 2000. It is controlled by the Ministry of the Interior and is responsible for authorizing
establishments in which dangerous substances are produced, used, handled or stored. It also includes
the National Command for Civic Defense and the National Command of the Fire Brigade.
Permitting and inspection are not separated in Hungary. All authorities have the responsibility of
checking and enforcing their own conditions.
Separate permits are issued for different media. 1075 installations are affected by IPPC (as existing
installations) and only a handful will be classified as new installations. The highest portion of IPPC
installations is represented by various farms. The implementation of IPPC legislation started in June
2002 (for new installations) and for existing ones it is planned to start after the accession to the EU.
Monitoring
The 12 Regional environmental inspectorates are responsible for monitoring and processing the data
that are collected. The REIs have their own laboratories.
A national surface water monitoring system is in place with sampling taking place at 150 sites
throughout the country. In March 2000 three new automatic water quality-monitoring stations were
installed along rivers, to assist with the implementation of the Directive on the quality of surface water
used for the abstraction of drinking water.
The results of the REI's monitoring activity are fed into regional registers which provide the basis for
the National Environmental Protection Information System. The REIs also compile summary reports
on the potential sources of pollution, the major polluters and the number/quality of licenses issued. So
far, only the computerized data register on wastewater is compatible with EU standards. In addition
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of nutrients and dangerous substances
in other areas there is no unified data register and an adequate system of data supply is not yet in
place, which makes the exchange of information at the international level difficult.
The VITUKI institute is responsible to transfer the emission data to the ICPDR. It is an appointed
National Reference Laboratory.
Inspection
Enforcement is carried out by the 12 Regional Environmental Inspectorates (REIs) and, in the nature
protection section, the Nature Conservation Authority and its 9 National Park Directorates.
The REIs are responsible for on-the-spot inspections and monitoring of implementation/ enforcement.
They have the power to impose fines. The REIs also have responsibility for permitting and
monitoring, as well as for inspection/enforcement. Around 1400 people work in the 12 REIs, of these
around 350 is responsible for inspection and permitting.
Industrial pollution
Main industrial branches are mining, metallurgy, construction materials, processed foods, textiles,
chemicals (especially pharmaceuticals), and motor vehicles
3.3.6 Moldova
General background
Moldova became independent from the USSR in 1991. Russian forces have remained on Moldovan
territory east of the Dniester River supporting the Slavic majority population, mostly Ukrainians and
Russians, who have proclaimed a "Transnistria" republic. The territory is 33 843 km2. The country is
divided into 9 counties, 1 municipality, 1 autonomous territorial unit and 1 territorial unit.
Main characteristics of Moldova and macroeconomic indicators
Unit
Indicator
Population
Inhabitants
4,434,547 (July 2002)
GDP
USD
11 billion (2002 est.)
GDP per capita
USD
3 300 (2002 est.)
Inflation rate
%
5,5
Unemployment rate
%
8
1 EURO = 11.73 MDL (Moldovan leu)
Moldova has a favorable climate and good farmland but has no major mineral deposits. As a result, the
economy depends heavily on agriculture, featuring fruits, vegetables, wine, and tobacco. Moldova
must import all of its supplies of oil, coal, and natural gas, largely from Russia. Energy shortages
contributed to sharp production declines after the breakup of the Soviet Union. As part of an ambitious
reform effort, Moldova introduced a convertible currency, freed all prices, stopped issuing preferential
credits to state enterprises, backed steady land privatization, removed export controls, and freed
interest rates. The government entered into agreements with the World Bank and the IMF to promote
growth and reduce poverty. The economy returned to positive growth, of 2.1% in 2000 and 6.1% in
2001. Growth remained strong in 2002, in part because of the reforms and because of starting from a
small base. The economy remains vulnerable to higher fuel prices, poor agricultural weather, and the
skepticism of foreign investors.
The GDP in 2000 generated by sector was as follows: agriculture: 28%, industry: 23%, services: 49%.
Water related legislation
Moldova has the following water and environmental legislation:
· Protection Areas of Rivers and Lakes (1983)
· The law on Environmental protection (1993)
· Water Code of the Republic of Moldova (1993)
· The Law on Industrial Waste (1997)
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The main law on water management in Moldova is the Water Code from 1993. According to this law,
the discharge of wastewater is only permitted if the discharges do not cause the water to exceed the
quality values. Further the polluter has to treat the wastewater in accordance to the ecological, water
management and sanitary authorities. It also states who is responsible for monitoring and inspecting
the industries and the municipal treatment plants.
Institutions
Environmental protection and water management are under the responsibility of the Ministry of
Ecology, Construction and Territorial Development (MECT). The ministry was established in early
2000. Other institutions involved are:
· Sanitary-Epidemiological Services under the Ministry of Health
· The Hydrological Department under the MECT
· Pollution Control Center under MECT
· Ecological Inspectorates under MECT
· The national water management consortium Apele Moldovei under the Ministry of
Agriculture and Food
The Ecological Inspectorates function at three different levels. The State Ecological Inspectorate is
responsible at the national level. Further the country is divided in three regions: north, central and
south, with regional offices in Chisinau, Balti and Cahul. Also, most municipalities have a smaller
local inspectorate.
Permitting
As stated in the Water Code all installations are required to obtain a wastewater license before
discharging wastewater into the surface water. The MECT and Sanitary-Epidemiological Services
under the Ministry of Health issue the licenses. The license is valid for a period from one to five years
and then it has to be renewed.
Monitoring
Several institutes monitor the quality and quantity of the surface water:
· The Hydrological Department monitors surface water quantity.
· Pollution Control Center monitors surface water quality. The monitoring is done from 15
sampling stations and the quality is measured by 30 hydro-chemical and 5 biological
parameters.
· Ecological Inspectorates monitor both water quality and quantity however the resources at the
local level are extremely limited.
· Apele Moldovei monitors the surface water quality primarily related to fertilizers.
There is a need to enhance the cooperation and coordination between these institutes in order to avoid
overlaps etc. Further, there is no national database compiling the different data and no other kind of
information exchange between the ministries involved.
As mentioned before the Ecological Inspectorate is subdivided into three regions. The regional offices
are responsible for monitoring both municipal treatment plants and industrial sites. The frequency of
the monitoring varies from once every 1-3 month depending on the amount of discharge. The regional
offices send quarterly reports to the national office which publishes an annual report that prescribes
the state of the environment.
The Water Supply Companies, which own the treatment plants, are obliged to monitor the wastewater
discharge every day. The data is submitted to the Ecological Inspectorate once a month. The Water
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45
of nutrients and dangerous substances
Supply Companies also monitor the wastewater coming from industries. This is done once a month
and is submitted in the monthly report to the Inspectorate.
The data for the EMIS inventory are compiled from the Ecological Inspectorates. The data are sent to
the responsible person in the Ministry that recalculates the data into annual amounts.
Inspection
The State Ecological Inspectorate makes sure the companies apply the conditions in the licenses. The
conditions can be on transportation, use of specified materials, construction, operation and close down
of operation. In case of none compliance the inspectorate is authorized to take legal action, impose
fines, and in serious cases may close down an installation.
Industrial pollution
Main industrial branches are food processing, agricultural machinery, foundry equipment, refrigerators
and freezers, washing machines, hosiery, sugar, vegetable oil, shoes, textiles
The pollution issues include heavy use of agricultural chemicals, including banned pesticides such as
DDT, has contaminated soil and groundwater; extensive soil erosion from poor farming methods.
3.3.7 Romania
General background
Romania has a population of 22.68 millions inhabitants, of which 56% are living in urban areas and 44%
in rural areas. The average population density is 95.8 inhabitants/km2, varying from 1291.7
inhabitants/km2 in Bucharest, to 32.1 inhabitants/km2 in the county of Tulcea. Romania is divided into 42
counties (judet), and one municipality Bucharest. Romania covers an area of 237,500 km2.
98% of the Romanian territory is in the Danube River Basin and the remaining 2% is in the Black Sea
catchment area. Romania shares several other trans-boundary river basins with neighbor countries.
Most of the year the rivers have a low level of water except during the spring flood.
Main characteristics of Romania and macroeconomic indicators
Indicator Unit
Population
Inhabitants
22,317,730 (July 2002
GDP USD
152,7
billion
(2002)
GDP per capita
USD
6 800
Inflation rate
%
34,5
Unemployment rate
%
9,1
Euro = 32.1 LEI (ROI) in January 2002
65% of the population has drinking water supply, which primarily originates from surface water, and
40-43% has sewerage systems in place. There is an unsatisfactory situation in villages, as far as these
utilities are concerned, both for the water supply system (16,1 % in average) and the sewerage system
(2,4% in average). Of 3,033 million m3/year of wastewater requiring treatment, about 18% is treated
adequately. The highest amount of untreated wastewater is generated by the same entities:
municipalities (urban wastewater, about 85%), chemical industry (4%), metal-processing and the
machine-construction industry (3%).
Romania, one of the poorest countries of Central and Eastern Europe, began the transition from
Communism in 1989 with a largely obsolete industrial base and a pattern of output unsuited to the
country's needs. Over the past decade economic restructuring has lagged behind most other countries
in the region. Consequently, living standards have continued to fall - real wages are down perhaps
40%. The country emerged in 2000 from a punishing three-year recession thanks to strong demand in
EU export markets, and despite the global slowdown in 2001, strong domestic activity in construction,
agriculture, and consumption led to 4.8% growth. A standby agreement with the IMF - covering the
period October 2001 to March 2003 - provides a key opportunity for vigorous privatization, regulatory
reform, deficit reduction, and the curbing of inflation. The government in the past has not been able to
fully implement IMF agreements; its degree of success in this case will affect prospects for joining the
UNDP/GEF Danube Regional Project
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EU. GDP in 2000 was generated by sectors as follows: agriculture: 15%, industry: 30%, services:
55%.
Water related legislation
The Water Law (107/1996) is the main law specific for the water field. The law covers all water
bodies except mineral and geothermal waters and establishes the ownership of the water. Further the
law states that it is required to have a license both to use and discharge water.
The Water Law confirmed and strengthened the role of the pre-existing River Basin Authorities
regarding integrated water resources administration. This provides a single institution at the river basin
level, with functions relating to all aspects of water resources management: surface water, ground
water, atmospheric water, and water quantity and water quality.
According to Water Law, any kind of water resource pollution is forbidden. The Ministry of Waters
and Environmental Protection (MWEP) establishes water quality standards. A Government Decision
approves the effluent limits of pollutants in wastewater discharge. The effluent limits provided in the
water management license are the maximum allowable limits and it is forbidden to exceed such limits.
Romania was the last country to open negotiation with the EC on the environmental chapter in March
2002. Presently the directives are at different stages of transposition. Parts of the WFD have been
transposed for example the prevention of nitrates pollution from agriculture and the action plan for
reducing pollution of ground waters and of the aquatic environment. Also, norms have been set on
discharges of wastewater, the quality of surface waters to support fish life and the quality of bathing
water. For industrial pollution control and risk management norms for technical and the procedural
framework for environmental inspections have been set.
EU Directive
Compliance
Water Framework
to be transposed by 2007
Dangerous Substances to be transposed by 2007 and it is envisage to receive transition period
by 2015
Integrated Prevention to be transposed by 2007 and it is envisage to receive transition period
and Pollution Control
by 2015
Seveso
to be transposed by 2007
EIA
Is transposed, but there is resource problems in implementation
EMAS
Institutions
The institutions for the implementation of the water management activity include:
· Ministry of Water and Environmental Protection (MWEP)
· County Environmental Protection Inspectorates (EPI)s under the MWEP
· National Company "Romanian Waters" (Apele Romane)
· Basin Committees, where each Committee consists of 15 representatives of all related authorities
ranging from the national to local level
The MWEP is responsible for implementing the national water and environmental policy.
The EPIs are in charge of the enforcement of the environment protection strategy at the county level.
There are 41 branch Inspectorates having an office at each County plus one in Bucharest. The tasks
being performed by each Inspectorate are:
· Issuing the water management and environmental permits/licenses in accordance with the
Environmental Protection Law and regulations for the application of this law;
· Control of the economic/social units such as industrial plants, ports, agricultural farms and the
public utilities authorized under the environmental permits/licenses;
· Surveillance of quality of the environmental factors: air, water and others, and reporting the
monitored data to the MWEP.
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47
of nutrients and dangerous substances
Permitting
In order to operate all companies must obtain an environmental permit as well as a permit to discharge
water, both of which are issued by the MWEP. There are two permitting systems concerning the
water:
· water management permit and licenses, and notification
The permit is issued on the basis of a project proposal showing the technical parameters of the
work, the way in which this work affects the water quantity and quality regime and the measures
to mitigate its impact on the water resources. Through these permits, the quality parameters of the
wastewater discharged into the recipient are established. The permits are given in close
cooperation with Apele Romane. It expires two years after the date of issue, if the works have not
been started.
In order to begin operating a work or an installation it is necessary to obtain a water management
license. This license establishes the operational conditions of the work. The license is valid for a
limited period of time, no more than 5 years, and should be periodically reviewed. The license
may also contain special conditions valid for a limited period (e.g. certain concentration for the
substances discharged to waters, in a special situation).
· environmental protection permit and licenses
The environmental protection authorities conduct the permitting procedure and issue an
environmental permit and an environmental license. There is a specific list of activities that
require an environmental impact assessment for issuance of an environmental permit and/or an
environmental license. Water management permits and licenses are necessary for obtaining
environmental permit/licenses.
During the permit process the EPIs verify the data in the application and make recommendations
for the permit. The recommendations are then forwarded to the MWEP, which issue the actual
permit. At least every five years the permit has to be renewed. The environmental permit contains
pollution limits for each pollutant. Also the permit indicates if the company is obliged to self-
monitor and when to report to the Inspectorate.
Monitoring
In the year 2000, the MWEP began to compile data from the different monitoring institutions into the
"National Integrated Monitoring System". In addition to indicating the status of the environment it is
also meant as an alarm system in case of a rapid rise in pollution. The monitoring of the water quality
and emissions to water are under the responsibility of Apele Romane. Apele Romane monitors water
quantity in 1016 hydrometric stations by measuring the flows. In about 40% of the locations the water
quality and quantity are measured together. For the other stations, information about the discharge is
transmitted from the nearest hydrometric station. With respect to the surface water, there are 65 control
stations upstream of the big polluters which are in rapidly flowing water quality being monitored daily.
There are another 240 control sections, which are in the slow flowing water quality being monitored
monthly
The wastewater discharges for 2100 point sources are monitored by the authorities from 1-24 times
per year depending on the type of pollution. Although, most companies also are required to self-
monitor, there is a lack of information of pollution at the source. This occurs mainly because the
authorities lack the necessary monitoring equipment and the companies self-monitoring is very poor.
Inspection
The EPI inspects companies with environmental permits. The inspectors rarely monitor the discharges
when inspecting, due to the lack of adequate equipment. In case they need to monitor they can bring in
an authorized monitoring laboratory. In total the 42 inspectorates employ 400 environmental
inspectors.
In case of violations of the permit conditions or any environmental laws the EPIs are authorized to
issue penalties and collect fines. It case of danger to humans or the national economy the penalty can
be imprisonment.
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The Inspectorates list all companies in two categories: Type A and B, where Type A is the most
polluting having a significant impact on the environment. The list is sent once a year to the Ministry of
Water and Environmental Protection giving the Ministry a national list of such installations.
Industrial pollution
The main industries include textiles and footwear, light machinery and auto assembly, mining, timber,
construction materials, metallurgy, chemicals, food processing, petroleum refining
The main environmental problems include soil erosion and degradation; water pollution; air pollution
in south from industrial effluents; contamination of Danube delta wetlands.
3.3.8 Serbia Montenegro
General Background
After the split of former Federal Republic of Yugoslavia and declaration of sovereign states from
former federal states - Slovenia, Croatia, Bosnia & Herzegovina, Macedonia, Serbia and Montenegro
existed from 1992 till 2003 as Republic of Yugoslavia. In February 2003 a loose federation of two
states Serbia and Montenegro was created. The territory is 102 350 km2.
Administrative division includes two republics - Serbia, Montenegro; and two nominally autonomous
provinces - Kosovo, Vojvodina. Data on unemployment are rather high as those on poverty.
According to the Government statistics, some of the 10% of the population are down the poverty line
of 2$ per day and further 10% are just above the line, thus making the 800.000 citizens bellow the
poverty line or 250.000 of families.
Main characteristics of Serbia and Montenegro and macroeconomic indicators
Indicator Unit
Population
Inhabitants
10 656 259 ( 2002)
GDP
USD
25,3 billion (2002
GDP per capita
USD
2370
Inflation rate
%
18
Unemployment rate
%
28
Euro = 59,6 Dinar (YUM) in 2002
After renewing the membership in the IMF in December 2000, Yugoslavia continued to reintegrate
into the international community by rejoining the World Bank (IBRD) and the European Bank for
Reconstruction and Development (EBRD). A World Bank-European Commission sponsored Donors'
Conference held in June 2001 raised $1.3 billion for economic restructuring. An agreement
rescheduling the country's $4.5 billion Paris Club government debts was concluded in November
2001; it will write off 66% of the debt and provide a basis for Belgrade to seek similar debt relief on
its $2.8 billion London Club commercial debt. The smaller republic of Montenegro severed its
economy from federal control and from Serbia during the MILOSEVIC era and continues to maintain
it's own central bank, uses the euro instead of the Yugoslav dinar as official currency, collects customs
tariffs, and manages its own budget. Kosovo, while technically still part of the Federal Republic of
Yugoslavia (now Serbia and Montenegro) according to United Nations Security Council Resolution
1244, is moving toward local autonomy under United Nations Interim Administration Mission in
Kosovo (UNMIK) and is dependent on the international community for financial and technical
assistance. The euro and the Yugoslav dinar are official currencies, and UNMIK collects taxes and
manages the budget. The complexity of Serbia and Montenegro political relationships, slow progress
in privatization, and stagnation in the European economy are holding back the economy; nonetheless,
growth may be 4.5% in 2003. The GDP in 2001 was generated by sectors as follows: agriculture:
26%, industry: 36%, and services: 38%.
In 2000, 98% of the FRY population had access to the public drinking water supply. However the
majority of rural households have septic tanks, many of them improperly designed and located. In the
past two years, IFIs and donors have initiated projects in the water supply and wastewater sector, in
large and medium-sized cities and rural areas. Most of the population has access to sanitation: 57% are
linked to a sewage system. However, wastewater treatment is almost non-existent. Ten years of little
Final Report: Industrial reform and the development of policies and legislation towards the reduction
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of nutrients and dangerous substances
maintenance and no investments in the wastewater supply sector has resulted in a situation whereby
most municipal and industrial wastewaters are discharged, largely untreated. It is estimated that only
13% of he total number of treatment plants work satisfactorily.
Quantities of municipal and industrial wastewater discharges have changed significantly in the past
decade. Roughly 10% of total wastewater discharged in Serbia is from households and this figure has
remained steady throughout the 1990s. What has changed dramatically is the combined wastewater
from both households and industry. Both have dropped by about 60% since the early 1990s.
Meanwhile, wastewater treatment capacity has remained roughly the same for both domestic and
industrial wastewater treatment and the treated amount remains similar in 2000 to that of 1990.
Generally the environmental and industrial regulatory competences have shifted from federal level to
the republics. However the federal government still plays an important role in international matters
such as negotiation, ratification and implementation of international agreements and conventions.
Besides the shift from federal to republic level there has also been a comprehensive decentralization,
which moved authority to the municipalities.
There is no federal ministry with the overall responsibility of water protection and management. The
responsibility is divided between several ministries (agriculture, forestry and water management, civil
engineering, health and finance), which regulate water under their area of interest. Because there is no
clear division of tasks between the different authorities, the environmental regulation seems
fragmented with lack of planning.
The environmental management of industrial development is primarily the responsibility of the
Environmental Department of the Federal Secretariat for Labor, Health and Social Care, however at
least four other federal institutes are involved. Their main task is to develop overall strategies and
policies to be reflected and detailed in the legislation of the two republics.
Two federal institutes are involved in monitoring and collection of data and information on
environmental and industrial development.
· The Federal Hydrometeorological Institute has the responsibility for international water issues
and interpretation of data on air quality, radioactivity and water pollution
· The Federal Institute for Public Health collects and report data on health protection.
However it is the responsibility of the republic's hydrometeorology institutes to monitor the ambient
waters. There is no environmental information system to describe the emissions and environmental
impacts from the industry. Consequently, there is a lack of reliable data to analyze the present situation
in order to make environmental priorities.
Serbia
Water related legislation
The Serbian Law on Waters covers protection of waters, utilization and management of waters, goods
of general interest, conditions and methods for performing water-related activities, organization and
financing of such activities, and supervision and monitoring for enforcement. The enforcement of the
law refers to surface and groundwater, including drinking water, thermal and mineral waters, border
and trans-boundary water flows, and inter-republic water bodies within the boundaries of the Republic
of Serbia.
In addition to the Law on Water, there are different regulations, where the Regulation of Hazardous
Substances in Waters regulates the wastewater. In 2002 the Water Master Plan for Serbia was
approved. It presents a strategy to meet the increased demands including the financial cost of the
expansions. Further, Serbia has developed a program of water pollution control improvements. The
financial priority is improving the sewer system and industrial pre-treatment plants. The
establishments of new plants are based on environmental criteria, primarily the protection of the
drinking water resources. Wastewater is also regulated by Regulation on Methods and Minimal
Number of Wastewater Quality Assessments (47/1983, amendment 13/1984).
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The water legislation is not in compliance with the EU directives however the new act on the
environment is under preparation and will be approved in the Serbian parliament soon. It will regulate
also IPPC.
Through a two phase Project "Development of Environmental Legislation in the Federal Republic of
Yugoslavia" which in the finalized nowadays also the preparation of guidelines for BAT (within the
framework of IPPC Directive) for the certain industries in Serbia BREF Reference Documents by
the end of 2005 will be finished.
Directive Compliance
Water Framework
Not transposed
Dangerous Substances
Not transposed
Integrated Prevention and Pollution Control
Not transposed
Seveso Not
transposed
EIA Not
transposed
EMAS Not
transposed
Institutions
The Ministry of Protection of Natural Resources and Environment and the Republican Water
Directorate within the Ministry for Agriculture and Water management is responsible for
implementation of the WFD and IPPC Directive. Both ministries are responsible for large parts of the
water management as water resource management water supply is under their jurisdiction.
Permitting
Ministry of Protection of Natural Resources and Environment gives permits for:
· Environmental impact analysis for new installations or when reconstructing existing ones
· Chemical-accident risk evaluation for large installations with heavy consumption of
chemicals.
The municipalities are also involved in industrial regulation. They are responsible for permitting and
inspecting smaller industries.
It is expected (according to the currently prepared Act of the Environment Protection) that there will
be transition period by the end of the year 2010.for IPPC permits required
Preliminary analysis of Serbian industries shows that about 170 installations are subject to IPCC and
another 673 might potentially be subject to the Directive. From all 840 installations about 154 are
located in the DRB. However, their number can potentially grow to 336.
Monitoring
Water quality monitoring is conducted by Serbia's Hydrometeorological Institute, which is responsible
for measuring and recording quantities of wastewater discharged, and submitting the data to the
relevant public agency. Monitoring also includes tracking the performance of wastewater treatment
facilities.
Inspection
The inspections are under the responsibility of the Water Resource Management Inspectorate. The
Inspectorate has little power to enforce the legislation. The coordination with the courts is poor, so the
inspectors do not know whether the court proceedings took place or if there any penalty was issued.
The actual proceedings take a long time and sanctions are so low that it does not have any effect on
polluters. Even the most heavily polluting companies cannot be closed down because the Ministry has
no legislative authority.
The Ministry of Protection of Natural Resources and Environment only has 39 inspectors allocated for
industrial activities, which is inadequate. Further the inspectorate needs vehicles and computers to
fulfill their tasks properly.
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of nutrients and dangerous substances
Montenegro
Water related legislation
In 1996, the Environmental Law (12/1996) was adopted as a general environmental framework. The
Law also contains general provisions regarding environmental monitoring, liability for environmental
pollution, environmental financing, and compliance and enforcement, including penalties. Only a few
regulations pertaining to the Environment Law have been issued, such as the Regulation on
Environmental Impact Assessment (1997). In addition, a number of laws under the authority of other
ministries are also relevant, particularly regulations on quality of soil and agricultural land, water
quality and wastewater. According to the Ministry of Environment and Physical Planning (MEPP), all
recently issued sector laws and by-laws are compatible with respective EU legislation. However, there
seems to be little, real appreciation of what the process requires in terms knowledge of the Community
acquis and ability to formulate policy and draft legislation which are EU-compatible, and which
consider monitoring, costs and enforcement capacity.
EU Directive
Compliance
Water Framework
Not transposed
Dangerous Substances
Not transposed
Integrated Prevention and Pollution Control
Not transposed
Seveso Not
transposed
EIA Not
transposed
EMAS Not
transposed
Institutions
Like Serbia, several ministries and the municipalities are involved in water regulation. However, in
Montenegro the Ministry of Environmental Protection and Physical Planning has taken the lead role in
planning and organizing water management. The ministry is also one of the primary authorities
responsible for implementing the environmental legislation relating to industry. Another important
authority is the Ministry of the Economy, which is responsible for mining, energy and industry. Unlike
Serbia, Montenegro only has one local level of authority - the municipalities. They are also involved in
the protection of water and nature, but generally they lack resources and experience. Several other
authorities are involved in environmental regulation in Montenegro, which complicates the system.
There is a need for coordination and cooperation between the different authorities.
Permitting
The permits are required by all operations that may cause pollution of the environment. The permits
are given in accordance with an environmental impact assessment. The assessments are done by expert
organizations and a part of the requirement is to draw up the draft conditions for the permits. The
Ministry of Environmental Protection and Physical Planning issues the permits.
A condition of the permit may be self-monitoring. The requirements in the environmental legislation
are transferred into site-specific conditions in the permit. Reporting conditions are related to fees for
use and emission of natural resources. The companies have to make an annual report regarding the use
and discharge of water.
Monitoring
The Ministry of Environmental Protection and Physical Planning is in the fist phase of implementing a
national information system. The system should among other things contain information about
company and sector environmental impact. The data for this is generally collected by self-monitoring
of the companies, through inspections and through the permitting authorities own monitoring.
The monitoring of ambient water is done by the Centre for Eco-Toxicology Research and the Republic
Hydro-Meteorological Institute. Together these institutes have a well-established monitoring network
of stations. The monitoring has improved quickly recently. Monitoring programs are being developed
for air pollution, radioactivity, soil pollution and water quality.
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Inspection
The Ministry of Environmental Protection and Physical Planning is the main organization responsible
for the inspection. The inspectors are not involved in the permit process. There are four environmental
inspectors at the Ministry and they are responsible for inspections for the entire country. The
inspections can either focus on the environment as a whole or on one parameter. In the former
different expert inspectors with different area of expertise (wastewater, air pollution etc.) participate.
Three or four inspectors carry out these inspections. For a single media one or two inspectors
participate to examine whether or not the company meets the requirements for e.g. wastewater. In case
of none compliance with the legislation the inspectors can issue fines or prevents the sale or import of
certain material that do not meet the requirements. Criminal charges and imprisonment are also
possible. . In some municipalities there is an environmental inspector, but they do not really have
authority to inspect on their own, hence their work is mostly to support and cooperate with the
inspector from the Ministry. The inspection unit needs staff and equipment. Currently the
documentation is in paper files but it would improve the efficiency of the office if computers were
available.
Industrial Pollution in Serbia and Montenegro
Industries include machine building (aircraft, trucks, and automobiles; tanks and weapons; electrical
equipment; agricultural machinery); metallurgy (steel, aluminum, copper, lead, zinc, chromium,
antimony, bismuth, cadmium); mining (coal, bauxite, nonferrous ore, iron ore, limestone); consumer
goods (textiles, footwear, foodstuffs, appliances); electronics, petroleum products, chemicals, and
pharmaceuticals.
Main pollution problems include pollution of coastal waters from sewage outlets, especially in tourist-
related areas such as Kotor; air pollution around Belgrade and other industrial cities; water pollution
from industrial wastes dumped into the Sava River which flows into the Danube.
3.3.9 Slovakia
General background
The territory of Slovakia covers 49.034 km2. The country is divided into 8 regions and 79 districts.
Within this broader administrative division there are 2 883 municipalities. Slovakia has a population
of around 5,4 million and a population density 109,9 inhabitants per km2. Slovakia is a rural country of
small settlements. The urban population is 56%of the total concentrated in a few larger cities.
Slovakia is country in economic transition. In 2000, the GDP reached 887.2 bill. SK (constant prices).
The average unemployment rate in 2002 was 19.6%. The rate of inflation increased dramatically in
1999, when large price reforms for public services were introduced (including water services). Since
2000, inflation continues to decline. The pace of decline slowed in 2002 when the Government put a
brake on the process of price deregulation.
Main characteristics of Slovakia and macroeconomic indicators
Unit
Indicator
Population
Inhabitants
5 402 547
GDP USD 23,7
(2002)
GDP per capita
USD
12 000
Inflation rate
%
8,4
Unemployment rate
%
18,6
1 EURO = 44 SK (2002)
In the past, Slovakia was dominated by the heavy machinery industry, chemical industry and food
processing industry. In economic transition, most of large state owned enterprises ceased to operate.
Presently, the main economic sectors are metallurgy, production of automobiles, and the chemical
industry. These are the largest polluters of the environment. As almost all companies are private and
have foreign investment which brought an upgrade and reconstruction towards BAT and other
environmental improvement systems.
Final Report: Industrial reform and the development of policies and legislation towards the reduction
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of nutrients and dangerous substances
Slovakia is drained by ten major rivers, of which nine are part of the Danube river basin. The Danube
catchment area in Slovakia is 47.064 km2. The basic water infrastructure falls short of what is required
by EU directives. The total inhabitants connected to a public water supply network in 2000
represented 83% of the population. The development of the sewerage systems lags behind the
development of water supply systems. In comparison with other countries this represents a relatively
serious underdevelopment. The number of people connected to public sewerage systems is 2.8 mill.
inhabitants, or 54,7 % of the total population (2000)
Water related legislation
Slovakia enters the EU in 2004 thus most of the European environmental legislation has been
transposed. The Water Act 184/2003 was adopted in 2003 and transposed all EU water related
legislation (except for some provisions of the WFD). The Water Act requires that anybody discharging
wastewater in ground or surface water must ensure that the quality of receiving water will not be
deteriorated. Also, appropriate treatment of discharge waters must be established prior to discharging
to the recipient water. Each withdrawal larger that 15 000 m3/year or 1 250 m3/month is subject of a
permit. Permits are granted by the environmental departments of the District Offices (DO).
There is a Regulation 491/2002 on permissible levels of pollution discharges and ambient quality
standards of receiving waters. The Regulation sets the maximum limits of pollution discharged into
the recipient and the DO should take into consideration also the ambient water quality of the recipient
(approach of emission AWQ standards is applied as required by the WFD).
There is also Regulation (35/1979) on Pollution Charges however, it does not provide for reduction
control measures of major industrial polluters.
EU Directive
Compliance
Water Framework
Partially transposed, the amendment of the Water Act planned in 2004
Dangerous
Transposed and implemented, Water Act
Substances
Reduction programs for List I and List II substances are under the development
Transition period obtained for specific industries by 2006
Integrated Prevention Transposed, Act adopted in 2003, integrated permits will be introduced from
and Pollution Control 2004
Transition period obtained for specific industries by 2011
Seveso
Transposed and implemented, the Act on Prevention of Major Industrial
Accidents entered into force in 2002
EIA
Transposed and implemented, Act on EIA was amended in 2002
EMAS
Transposed and implemented, Act on Environmentally Oriented Management
and Audit Scheme entered into force in 2003
Institutions
The Slovak Ministry of Environment is the central body of the state environmental administration and
it is responsible for policy development as well as the management and protection of the environment,
including nature protection, water management and water protection, air protection, waste
management, environmental information system and environmental monitoring.
There are 8 regional (RO) and 79 District Offices (DO), which have environmental units in charge of
the state environmental administration. The main functions of these offices involve decision-making,
permitting, supervision and enforcement.
From 2004, RO and DO will be cancelled and some responsibilities should be transferred to the
municipal level. Also there will be a newly established environmental administration that will cope
with hydrological borders of the main river basins based upon a previously existing organization. This
proposal is under discussion.
The main institution with respect to the implementation of IPPC will be the Slovak Environmental
Inspection (SEI).
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The Ministry of Environment also directs supporting agencies:
· The Slovak Hydrometeorological Institute (SHMI)
· The Water Research Institute (WRI)
· Slovak Environmental Agency (SEA).
Permitting
Any activity that might impact environmental quality requires permits. These are issued by the DO of
the appropriate jurisdiction. The activity is also reviewed for compliance with the local and regional
land use plan and environmental impact assessment. However, the final statement of the EIA is not an
obligatory (legally binding) document for the decisions on future industrial or other activities.
The DO grants approval for operators of pollution sources based upon an application. A complex
application is reviewed with respect to all of the requirements including technical, operational and
organizational parameters of the proposed activity. Also, the authority can request an expert opinion
and/or can invite the Slovak Environmental Inspectorate (SEI) to review the application.
DOs are legally obliged to issue permits within the limits set up in the legislation. The water authority
might issue stricter limits or conditions of the operation. The legislation allows for exemption from the
limits for a limited time (also set up in the Acts).
Prior to November 2003, permits have not been integrated. A new Act on IPPC No. 245/2003 provides
for issuing of integrated permits for selected companies that falls under the IPPC Act as required by
the IPPC Directive.
There are following competent bodies in the integrated permitting process:
The Slovak Environmental Inspectorate with four new regional IPPC departments and an IPPC
Headquarter in Bratislava are responsible for reviewing the applications submitted to them. They issue
integrated permits. The IPPC Act appoints a number of affected bodies that enter into the permitting
process (district offices, municipalities, hygiene institutes, etc.). The Regulation 391/2003 authorized
persons (by the SMoE) can help installation in the preparation of the application. The Slovak
Environmental Inspectorate IPPC Department is building also a BAT center. Slovak Environmental
Agency is an appointed institution for EPER (and other reporting to the EC). The total number of
IPPC installation is around 540, among them 33 "new" ones.
Until 2002, the permits were not time limited. The Water Act of 2003 requires a regular revision of
permits; special attention is paid to dischargers of dangerous substances from List I and List II where a
maximum 4-year permit would be issued. Also, annually, the facility has to report (and ask for permit
approval) on discharge into the recipient waters. A summary of water related permits required from
industry is as follows:
Water and wastewater permits
· withdrawal of surface and ground waters
· withdrawal or use of mining waters
· discharge of waste waters into surface or ground waters
· discharge of special waters (mineral waters, mining waters)
Other water permits
· water management facilities (dams, reservoirs, irrigation facilities, melioration facilities,
facilities for protection against floods)
· geological and hydrological activities in protected zones
· extraction of sand, gravel, silt from the water flows beds
Special water authorizations
· constructions and facilities in water flows
· long-distance pipes, storage, tanks, landfills
· any industrial activity or change in technology that might impact the quality of quantity of
water
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of nutrients and dangerous substances
Monitoring
There are several monitoring institutions dealing with monitoring of water quality:
· The Slovak Hydrometeorological Institute (SHMI) is responsible for monitoring of
environmental quality standards for air and water (both generally and in relation to specific
discharges/sites).
· River Basin Enterprises monitor surface waters (both generally and in relation to specific
discharges/sites) and discharges of polluters. However, the monitoring is focused only on
substances that are the subject of pollution charges.
· The Water Research Institute keeps a record on monitoring of municipal WWTPs discharges
that are operated by the Water Works Utilities. Industries that discharge into public sewage
system must prior to discharge pre-treat their waters in order to avoid damaging the public
WWTP. No information is available about industries discharging into urban sewage networks.
· There is self-monitoring of polluters that submit data on voluntary basis to the SHMI. The
SHMI recently developed the monitoring and reporting protocol for the industry with respect
to reporting on dangerous substances.
The surface and ground water quality monitoring is processed at the SHMI. It consists of 176 basic
and 3 special sampling locations (1999). The sampling is conducted once per month for all sampling
locations of the parameters of the basic group (t, color, oil substances, dissolved oxygen, BOD, COD,
soluble substances, insoluble substances, pH, conductivity, chlorides, sulfates, NH4+, NO3-, NO2-,
total P, coliform bacteria, bioseston saprobity). Special (enlarged) sampling is conduced specifically
according to the purpose of monitoring. Heavy metals are measured 4 6 times per year, chlorophyll
"a" during the vegetation period, pesticides 2-6 times per year.
The National Reference laboratory (for water) tests and ensures the analytical quality control of labs
conducting the sampling. Monitored data are available to the public. The SHMI is the responsible
institution to submit monitoring data to the ICPDR.
Inspection
The Slovak Environmental Inspectorate (SEI) includes a central (headquarters) body reporting to the
MoE, with separate, media-based inspectorates covering water, waste, air and nature and operating at
the regional level. The inspectorates check compliance with the requirements of permits through a
program of site inspections. Inspectors can also check self-monitoring data. Penalties can be imposed
for non-compliance, and recommendations can be made for technical improvements (this is not a legal
requirement, and is often done informally).
Inspectorates are not integrated but they are closely coordinated; compliance is checked per
environmental medium.
As described in the previous chapter the SEI is since July 31, 2003 also an IPPC permitting and
inspecting institution.
Industrial pollution
Industrial production contributes 26% of the GDP in Slovakia (1999). The main industrial sectors are
metallurgy, production of cars and production of food. Production of wastewater from industrial
production has had a decreasing trend both in total volume of wastewater discharged and quality of
discharged wastewaters. Not only environmental policy measures but also the general reduction in
industrial production contributed to the positive trend of reducing emission levels.
In 2003, all water pollution permits are being revised and stricter limits are being issued. Each
discharger of dangerous substances must develop a reduction plan that will ensure the elimination of
List I and the reduction of List II substances. BAT will be required for IPPC installations.
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3.3.10 Slovenia
General background
Slovenia is a relatively small country covering 20 253 km2. It is administratively divided into 182
municipalities and 11 urban municipalities. It has the highest GDP per capita of the CEE countries.
The GDP is even higher than some of the EU Member States. The country is rich in water resources
and 80% of the population has drinking water supply. The country has made great environmental
progress in recent years and the amount of GDP spent on environmental issues has increased from 1.5
to 2-2.5%. The environmental consciousness of the population is high compared to the other ECC
countries. Due to the size and wealth and previous transition progress the country experienced very
easy negotiations with the European Commission and it was the first country to close the
environmental chapter in the beginning of 2001. Hence Slovenia is among the countries to join EU in
2004.
Indicator Unit
Population
Inhabitants
1 932 917
GDP
USD
36 billion (2002 est.)
GDP per capita
USD
18 000 (2002)
Inflation rate
%
7,4
Unemployment rate
%
11
1 EURO -= 230.5 Tolar (SIT) (2002)
Slovenia, with its historical ties to Western Europe, enjoys a GDP per capita substantially higher than
that of the other transitioning economies of Central Europe. Privatization of the economy proceeded at
an accelerated pace in 2002, and steps were taken to bring down the budget deficit from 2.9% of GDP
in 2002 to 1.2% in 2003. Despite the economic slowdown in Europe in 2001-02, Slovenia maintained
3% growth. Internal structural reforms to improve the business environment, encouragement of direct
foreign investment, and measures to curb inflation are needed to prepare the way for EU membership.
GDP was generated in 2001 by sectors as follows: agriculture 3%, industry 36%, and services 61%.
Water related legislation
Slovenia has three fundamental legislative tools that outline the objectives and strategies for future
environmental regulation and water management. They are the Environmental Protection Act (1994)
National Water Resource Strategy and National Environmental Action Program (1999). The Action
Program prioritizes water, waste and nature management and makes realistic strategies for all three
areas. The strategies are divided into short-term and long-term where the former are going to be met
prior to accession and the latter prior to 2008. The Environmental Protection Act primarily focuses on
pollution stemming from point sources. Only a few changes in the Act were necessary to meet the EU
requirements. In 2001 different amendments began the transposition of the IPPC Directive. 15
installations have transitions period to meet IPPC requirements until 2011 and the rest will be in line
with the Directive in 2007. Also for the UWWD transitional arrangements were made.
In 2000-2001 vulnerable areas were identified and all of Slovenia was classified as a vulnerable area
under the Nitrate Directive. In July 2002 the Water Act was approved that transposes all EU
Directives and considers the management of the whole water system. Also the discharges in the
Dangerous Substance Directive were aligned in 2002.
EU Directive
Compliance
Water Framework
Transposed
Dangerous Substances
Transposed
Integrated Pollution Prevention and Transposed with transition period until 2011 (for fifteen
Control
existing installations)
Seveso Transposed
EIA
Transposed
EMAS
Implementation in progress. The process is expected to be
finished by the end of 2003
Final Report: Industrial reform and the development of policies and legislation towards the reduction
57
of nutrients and dangerous substances
Institutions
The overall responsible authority is the Ministry of Environment and Spatial Planning. The Ministry
has been simplified and streamlined in order to improve the implementation of the directives. In 2001
the environmental administration was further improved when the Environmental Agency was
established. The Agency was established by amalgamating three former institutes namely: the Nature
Protection Authority, the Hydro-meteorological Institute and the Administration for Geophysics.
Slovenia has increased the number of staff dealing with EU environmental issues by 50 % over the last
five years. Furthermore, employees in the Environmental Agency have received special training in
order to make environmental impact assessments.
Permitting
The following types of permit are required:
· Location Permits (for construction) are issued directly by Ministry of Environment and Spatial
Planning but relating to spatial planning rather than environment. They must be consistent
with the structure plan and comply with EIA requirements (including public consultation) in
accordance with the EIA Directive.
· Operating Permits are issued separately for air, water and waste by the Environmental
Agency. Permit requirements will be consistent with the environmental acquis, providing
relevant implementing legislation is in force in Slovenia.
The process of obtaining a permit is as follows. When an investor wishes to obtain a permit he usually
first checks the physical plan for possible construction locations, then he issues a request for the draft
location and draft building documentation. When all the necessary documentation has been received,
he starts the procedure of negotiating with the permitting authority. This is usually conducted by an
authorized company, which is preparing the location and building permit documentation. This
company invites all authorities responsible for location and building permits to issue their consent
statements or guidelines. Permits are negotiated in the sense that a polluter may be give time to come
into compliance, but the absolute standards are not negotiated. Permits are generally handled on a
case-by-case basis, although a consistent approach is adopted for a particular type of facility (power
plants, landfill sites etc).
The present permitting system is fragmented and media-specific. The system experiences some
coordination problems, but it seems like Slovenia will solve the problems by making one integrated
permit issued by a single permit authority. In that case the responsibility will be under the Ministry of
Environment and Spatial Planning.
Monitoring
The Hydro-meteorological Institute formerly did the monitoring of surface water quality but after the
establishment of the Environmental Agency the responsibility has transferred to the Agency. There are
more than 100 sampling stations along the main rivers and the monitoring is done from two to six
times a year. The methodologies and needs of the system are harmonized with the requirements from
the European Environmental Agency.
The Ministry of Environment issues authorizations for laboratories to conduct monitoring on request
of companies. This list is publicly available. Site monitoring of permitted facilities is carried out by
approved contractors, certified by the National Standardization Office and approved by Ministry to
standards set by the monitoring regulation. Local Monitoring may also be carried out by or on behalf
of local authorities.
Inspection
Enforcement is the main role of the Environmental Inspectorate. Local authorities also have a limited
inspection role. Inspections are based primarily on Inspectorate regional offices. There are recognized
`experts' in some sectors, who are called in when the local inspectors identify issues that are beyond
their competence/experience. Inspectors cover all media. The primary method of enforcement is site
visits.
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Inspections may be carried out on a routine basis (without advance notice) or in response to
complaints submitted by the public through a dedicated telephone hot-line. Where the inspection
reveals an infringement of permit requirements, the inspector generally issues a compliance notice
requiring the operator to take specified action within a defined period. Failure to comply with the
requirements of the notice within the period makes the operator liable to legal action. This may be
primarily administrative in nature (specified financial penalty, but no criminal record) or, for more
serious offences, result in criminal proceedings that can result in fines, imprisonment or withdrawal of
the operating license (i.e. closure). Prosecution is dealt with through a dedicated office for legal issues
within Inspectorate; although individual inspectors can deal with more routine cases (particularly
administrative infringements) themselves using standard pro-forma letters.
Industrial pollution
The main industry branches are ferrous metallurgy and rolling mill products, aluminum reduction and
rolled products, lead and zinc smelting, electronics (including military electronics), trucks, electric
power equipment, wood products, textiles, chemicals, machine tools
The main pollution problems include the Sava River polluted with domestic and industrial waste;
pollution of coastal waters with heavy metals and toxic chemicals; forest damage near Koper from air
pollution (originating in metallurgical and chemical plants) and resulting acid rain
3.3.11 Ukraine
General background
Ukraine achieved independence in 1991 with the dissolution of the USSR, however, true freedom
remains elusive as many of the former Soviet elite remain entrenched, stalling efforts at economic
reform, privatization, and civil liberties. The territory covers 603 700 km2. It is administratively
divided into 24 counties, 1 autonomous republic and 2 municipalities with county status.
Indicator Unit
Population Inhabitants
48,396,470
GDP USD
205
billion
(2001)
GDP per capita
USD
4200
Inflation rate
%
12
Unemployment rate
%
3.6
1 EURO = 4.88 Ukrainian hryivna (UAH), 2002
After Russia, the Ukrainian republic was far and away the most important economic component of the
former Soviet Union, producing about four times the output of the next-ranking republic. Its fertile
black soil generated more than one quarter of Soviet agricultural output, and its farms provided
substantial quantities of meat, milk, grain, and vegetables to other republics. Likewise, its diversified
heavy industry supplied the unique equipment (for example, large diameter pipes) and raw materials to
industrial and mining sites (vertical drilling apparatus) in other regions of the former USSR. Ukraine
depends on imports of energy, especially natural gas, to meet some 85% of its annual energy
requirements. Shortly after independence in late 1991, the Ukrainian Government liberalized most
prices and erected a legal framework for privatization, but widespread resistance to reform within the
government and the legislature soon stalled reform efforts and led to some backtracking. Output by
1999 had fallen to less than 40% the 1991 level. Loose monetary policies pushed inflation to
hyperinflationary levels in late 1993. Ukraine's dependence on Russia for energy supplies and the lack
of significant structural reform has made the Ukrainian economy vulnerable to external shocks. GDP
in 2000 showed strong export-based growth of 6% - the first growth since independence - and
industrial production grew 12.9%. The economy continued to expand in 2001 as real GDP rose by 9%
and industrial output grew by over 14%. Growth was supported by strong domestic demand and
growing consumer and investor confidence.
Water resources are not equally distributed throughout the Ukraine. Over 60% of the population is
connected to municipal wastewater treatment plants but a majority of the villages discharge their
Final Report: Industrial reform and the development of policies and legislation towards the reduction
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of nutrients and dangerous substances
wastewater without treatment. The major problem is that in rural areas most of municipal waters are
discharged untreated.
Water related legislation
The legislative framework for water management contains the Law on Environmental Protection and
the Water Code of Ukraine. The Law on Environmental Protection from 1991 lays down the basic
principles of nature protection and in particular, the principles that users must pay for the discharge of
pollutants into water. The Water Code from 1995 provides the basic framework for water legislation.
The basic provisions include the management of legal relations to ensure water protection, rational use
of water for the population and industry, restoration of water resources and protection of waters from
pollution and illegal disposal.
The laws do not correspond with the water regulation within EU. There is no specific legislation
dealing with the integrated prevention and pollution control.
EU Directive
Compliance
Water Framework Directive
not transposed
Dangerous Substances Directive
not transposed
Integrated Prevention and Pollution Control Directive
not transposed
Seveso Directive
not transposed
EIA Directive
not transposed
EMAS not
transposed
Institutions
Water management is shared by a number of state institutions among which the Ministry of
Environmental Protection and Nuclear Safety carries out complex management of water resource
protection and
· develops new legislation and regulations,
· conducts state environmental impact assessment,
· issues permits for special water use,
· conducts state monitoring of water resources and,
· enforces the various water regulations.
There are water authorities at the local level, however, the mechanism on the supervision and
management are not clear.
Permitting
According to the Water Code, water use and discharge requires a permit. The permits for water
resources of national significance are granted by the Ministry of Environmental Protection and
Nuclear Safety, while abstraction from and discharges into local water resources are permitted by local
authorities. The permit determines the volume of raw water that can be taken and used and also the
amount of pollutants that can be discharged (concentration as well as load). Ambient standards are
used to set effluent limits. The permit also defines the rate of the two fees (abstraction and pollutions
charges) that the user has to pay. The licensing procedure provides for cooperation with the
Committee on Water Resources, the Committee on Geology or the Ministry of Health Protection. The
permit may be granted for a short (up to 3 years) or a long-term period (3 to 25 years).
Monitoring
The situation was confusing without a clear delineation of the responsibilities between the various
entities. In 1998, Resolution 391/1998 was adopted to improve the coordination of monitoring
activities. Overall coordination of monitoring is under the Ministry of Environmental Protection and
Nuclear Safety.
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The following authorities are involved in water monitoring and control:
· Ministry of Environmental Protection and Nuclear Safety
· Ministry of Agriculture and Food Production
· Committee on Water Resources
· Committee for Hydrometeorology
The Committee on Water Resources maintains more than 200 monitoring stations for surface water.
Inspection
The State Ecological Inspectorate reviews compliance. If regulations or permit provisions are violated,
it is authorized to temporarily close down the polluting activity and to impose a penalty or sue the
polluter. However, the complexity of the permits and the lack of staff hinder enforcement of permit
provisions.
Industrial pollution
The main industry branches are coal mining, electric power production, ferrous and nonferrous metals,
machinery and transport equipment, chemicals, food processing (especially sugar)
The main pollution problems include inadequate supplies of potable water; air and water pollution;
deforestation; radiation contamination in the northeast from the 1986 accident at the Chernobyl'
Nuclear Power Plant
Industrial reform and the development of policies and legislation towards the reduction
of nutrients and dangerous substances
61
3.4 Water Legislation and Institutional Summary
The first part of this section contains a summary and discussion of the relevant water legislation and compared to the major EU water related legislation. In the
second part an overview of the institutional situation is provided. This followed by a discussion of steps to be taken in addressing the legislative gaps.
3.4.1 Water legislation summary
Country/
Water Framework
Dangerous Substances
Integrated Prevention and
Seveso Environmental
Impact
Environmental Management
Directive
Pollution Control
Assessment
and Audit Schemes
Bosnia &
Not implemented and changes
Not implemented and
Not implemented and
Not implemented and
Not implemented and changes
Not implemented and changes
Herzegovina not planned to transpose the EU
changes not planned to
changes not planned to
changes not planned to
not planned to transpose the EU not planned to transpose the
directive
transpose the EU directive
transpose the EU directive
transpose the EU directive
directive
EU directive
Bulgaria
Partially implemented using as
Transposed and
Partially implemented using
Partially implemented
Fully implemented in National
Partially implemented using as
future framework for national
substantially implemented
as future framework for
using as future framework
Legislation
future framework for national
legislation
in National Legislation
national legislation
for national legislation
legislation
Croatia *
Not implemented and changes
Not implemented and
Not implemented and
Not implemented and
Not implemented and changes
Not implemented and changes
not planned to transpose the EU
changes not planned to
changes not planned to
changes not planned to
not planned to transpose the EU not planned to transpose the
directive
transpose the EU directive
transpose the EU directive
transpose the EU directive
directive
EU directive
Czech
Transposed and substantially
Fully implemented in
Fully implemented in
Fully implemented in
Fully implemented in National
Fully implemented in National
Republic
implemented in National
National Legislation
National Legislation
National Legislation
Legislation
Legislation
Legislation
Hungary Transposed
and
substantially Fully implemented in
Transposed and substantially Fully implemented in
Fully implemented in National
Fully implemented in National
implemented in National
National Legislation
implemented in National
National Legislation
Legislation
Legislation
Legislation
Legislation
Moldova
Not implemented and changes
Not implemented and
Not implemented and
Not implemented and
Not implemented and changes
Not implemented and changes
not planned to transpose the EU
changes not planned to
changes not planned to
changes not planned to
not planned to transpose the EU not planned to transpose the
directive
transpose the EU directive
transpose the EU directive
transpose the EU directive
directive
EU directive
Romania
Partially implemented using as
Partially implemented
Partially implemented using
Partially implemented
Transposed and substantially
Partially implemented using as
future framework for national
using as future framework
as future framework for
using as future framework
implemented in National
future framework for national
legislation
for national legislation
national legislation
for national legislation
Legislation
legislation
Serbia -
Not implemented and changes
Not implemented and
Not implemented and
Not implemented and
Not implemented and changes
Not implemented and changes
Montenegro
not planned to transpose the EU
changes not planned to
changes not planned to
changes not planned to
not planned to transpose the EU not planned to transpose the
directive
transpose the EU directive
transpose the EU directive
transpose the EU directive
directive
EU directive
Slovakia Transposed
and
substantially Fully implemented in
Fully implemented in
Fully implemented in
Fully implemented in National
Fully implemented in National
implemented in National
National Legislation
National Legislation
National Legislation
Legislation
Legislation
Legislation
Slovenia Transposed
and
substantially Fully implemented in
Fully implemented in
Fully implemented in
Fully implemented in National
Fully implemented in National
implemented in National
National Legislation
National Legislation
National Legislation
Legislation
Legislation
Legislation
Ukraine
Not implemented and changes
Not implemented and
Not implemented and
Not implemented and
Not implemented and changes
Not implemented and changes
not planned to transpose the EU
changes not planned to
changes not planned to
changes not planned to
not planned to transpose the EU not planned to transpose the
directive
transpose the EU directive
transpose the EU directive
transpose the EU directive
directive
EU directive
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3.4.2 Institutional summary
The following table summarizes the institutional arrangements for the countries for comparative purposes.
Country
National level responsible for water
County/local levels
Permitting authority
Inspection authority
Monitoring agency for
institutions
related issues
responsible (cooperating)
industrial polluters
for water related issues
Bosnia and
Ministry does not exist at federal level, F B&H: cantons
F B&H: Ministry of
F B&H:
F B&H:
Herzegovina
issues coordinated by Commission for
RS: municipalities
Agriculture, Water
Federal Inspectorate
Self-monitoring
Water
Management and Forestry,
Cantons
FB&H:
cantons
RS: The Ministry of
Federal Ministry of Agriculture, Water
Urbanism, Housing-
RS:
Management and Forestry
RS: Ministry of Agriculture, Communal Services, Civil
Self-monitoring
Federal Ministry of Physical Planning
Forestry and Water
Engineering and Ecology
Water Institute Bijeljina
and Environment
Management
RS:
Directorate for Water
Ministry of Agriculture, Forestry and
Water Management
Bulgaria
Ministry of Environment and Waters
Regional offices
Water Basin Directorates
Regional inspectorates
Self-monitoring
Executive Agency of the Environment Municipalities
Bulgarian Environmental Agency
Water Basin Directorate
Regional inspectorates
Croatia
State Water Directorate,
Economic county offices
State Water Directorate
State Water Management
Croatian Waters ( Hrvatske
Croatian Waters (Hrvatske Vode)
Environmental county offices Croatian Waters
Inspection
Vode)
Economical county offices
County Water Management
Inspectorate
Czech
Ministry of Environment,
District offices
District offices
Regional inspectorates
Self-monitoring
Republic
Ministry of Agriculture
Regional offices
Regional offices
Hydrometeorological Institute
River basin administration
Water Research Institute
Municipalities
Hungary
Ministry of Environment and Water
Water directorates at districts Regional environmental
Regional environmental
Self-monitoring
Management
Regional environmental
inspectorates
inspectorates
Regional environmental
inspectorates
inspectorates
Municipalities
VITUKI
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of nutrients and dangerous substances
Country
National level responsible for water
County/local levels
Permitting authority
Inspection authority
Monitoring agency for
institutions
related issues
responsible (cooperating)
industrial polluters
for water related issues
Moldova
Ministry of Ecology, Construction and Regional water inspectorates MECT and Sanitary-
Ecological Inspectorates
Territorial Development (MECT)
and municipalities
Epidemiological Services
(Ministry of Health)
Romania
Ministry of Waters and Environmental Basin Committees
Environmental Protection
Environmental Protection
Self-monitoring
Protection
Municipalities
Inspectorates
Inspectorates
Apele Romane
Serbia-
Serbia
Municipalities Ser:
Municipalities
Self-monitoring
Montenegro
The Ministry of Agriculture, Forestry
Ministry of Protection of
Mon:
Hydrometeorological Institute
and Water Resource Management
Natural Resources and
Ministry of Environmental
Montenegro
Environment
Protection and Physical
Ministry of Environmental Protection
Water Resource Management Planning
and Physical Planning
Inspectorate
Municipalities
Mon:
Ministry of Environmental
Protection and Physical
Planning
Slovakia
Ministry of Environment
District offices
District offices
Regional Inspectorates
Self-monitoring
Regional Offices
Regional offices
River Basin Enterprises
River Basin Enterprises
Water Research Institute
municipalities
Hydromet. Institute
Slovenia
Ministry of Environment and Spatial
municipalities
Ministry of Environment and Environmental inspectorate Environmental
Agency
Planning
Spatial Planning
Environmental Agency
Ukraine
Ministry of Environmental Protection
Counties
Ministry of Environmental
State Ecological
Self- monitoring
and Nuclear Safety
municipalities
Protection and Nuclear
Inspectorate
Committee on Water Resources
Safety
Committee on Water
Resources
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Of the 11 countries 9 have an institution responsible for water management at the national level. In
one country the national agency is purely a coordinating mechanism. In four countries the
responsibilities are shared by than more that one organization. The remaining two countries have a
more decentralized structure. In 10 of the 11 countries municipalities play a role in the process. Four
have specialized river basin organizations and these along with regional district or county offices are
key organizations. Those countries with existing river basin authorities may find that an advantage in
implementing the Water Framework Directive. Three of the countries have a centralized permitting
process with the others having a decentralized capability. Each of the countries has an inspection
structure in place. Monitoring systems vary but there is a substantial reliance on self monitoring. The
ICPDR should facilitate seminars and staff exchanges among the countries focusing on institutional
organizational issues. In addition, the ICPDR should provide technical assistance and where necessary
financial support new positions on a limited basis to influence positive institutional change.
As can be seen from the summary chart above and including Germany and Austria, the legislative
situation groups the ICPDR countries into three groups; those which have implemented the EU
legislation; those which have partially done so and those which have not implemented the EU
legislation virtually at all. The first group includes Austria, Czech Republic, Germany, Hungary,
Slovakia and Slovenia. Bulgaria, and Romania which are in the second group are at different stages in
harmonizing their legislation with Croatia being the most recent to initiate the process. During the
preparation for entrance to the EU substantial funding is available through the EU pre-accession funds.
New EU Member States have Structural and Cohesion Funds available to them. Based upon the
period of adjustment of the Czech Republic, Hungary, Slovakia and Slovenia the funds available will
facilitate the process of improvements in industrial pollution legislation and enforcement in a timely
manner.
3.5 BAT Implementation
BAT may be implemented as a legislative requirement or by more informal means. This section is
divided into two parts. Sections 3.5.1 to 3.5.6 address the implementation of BAT at the level of the
national government. Section 3.5.7 is targeted to the level of the individual industrial installation.
3.5.1 Implementation of BAT at the National Level.
It could be argued that the easiest way for the remaining countries to implement BAT would simply to
adopt national IPPC legislation. Before adopting new environmental legislation several factors need to
be considered including:
· Priority
· Impact
· Administration
· Inspection and Enforcement
· Cost to Government
· Cost to Industry
· Implementing Cost Effective Approaches
· Information and awareness activities
· Strategic negotiation
· Incremental approach
Each is discussed in the following sections.
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of nutrients and dangerous substances
3.5.2 Priority
The nations not involved in the EU process are developing and revising their legislation generally.
This means that new environmental legislation must compete with legislation from other fields in the
economic and social spheres. There are scarce resources for monitoring and enforcement after the
legislation is passed. Therefore, Ministries of Environment with limited access to the legislative
process have to decide which legislation has priority. IPPC legislation has only relatively recently
been introduced in the EU countries. It is what might be referred to as a second level legislation in that
it assumes those media specific standards and other basics measures are in place. Countries are more
likely to place basic legislation before introducing IPPC making IPPC legislation a lower priority.
3.5.3 Impact
National Governments also have to look at potential impact of new legislation and prioritize those
with the largest potential impact. IPPC is limited impact legislation in that it only applies to those
industries using the proscribed technology. Therefore, each country needs to look at the number of
installations which would be required to implement BAT under national IPPC legislation and further
to estimate the reduction in pollution. In economies in transition it is also necessary to determine the
life expectancy of the operation. The shorter the life expectancy of the operation the less likely BAT
will be introduced. From a water management point of view while the introduction of BAT may
improve the discharges to water it is not aimed only at water management. Taking into account both
that only selected industrial facilities will be included and the reduction of water pollution is not the
specific objective of the legislation it may only have a marginal affect on water management in
individual countries.
3.5.4 Administration
IPPC legislation needs a significant administrative structure to be effective. This includes a permitting
capability and a BAT Center as well as a dedicated monitoring and inspection capability. The
permitting process is lengthy and detailed. The need for the introduction of new organizational units
and additional staff and equipment are prerequisites for the implementation of IPPC legislation. The
process must be supported by extensive training programs.
3.5.5 Inspection and Enforcement
The introduction of IPPC legislation requires a dedicated inspection and enforcement capability.
Because of the complexity of the process inspectors will have to be trained. The focus is on
technology therefore technology experts will also have to be included in the process.
3.5.6 Cost to Government
The cost to government including new organization units, permitting staff hired and trained, a
technology pool of experts identified and a capable enforcement function established may in some
cases be equal or higher that the total budget for existing national government environmental
expenditures.
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3.5.7 Cost to Industry
The most cost effective time to apply BAT is when the installation is initially being constructed. Since
many of the installations in the transitional economies are quite old the technology is also outdated. It
is likely that the legal requirement to introduce BAT would cause installations to close due to
economic reasons.
3.5.8 BAT Application at individual industrial installations
Full implementation of BAT at the national level can be a time consuming and expensive process. An
alternative is to encourage the voluntary introduction of BAT at individual industrial installations. The
UNIDO TEST project has developed a detailed methodology and provided examples of the benefits of
applying environmental sustainable technologies to individual industrial installations in the Danube
River Basin. The approach is based upon a number of tools including an initial review, an
environmental management system, cleaner production assessment, environmental sound technology
assessment and a sustainable enterprise strategy. The approach is fully integrated addressing
management and employee involvement and both technological and non technological improvements.
The framework of sustainable economic and environmental performance eliminates the jobs versus the
environment debate by showing the positive interrelation between productivity and pollution
reduction. By providing an approach which is both economic and environmentally advantageous it is
an approach which can be supported by industry and those advocating pollution reductions.
This section provides a discussion of the benefits to these installations from the voluntary
implementation of BAT. It also examines data from 5 case studies to examine the initial steps
necessary to implement BAT based in these specific industrial installations. The main objective of the
case studies is to provide examples of how existing installations can implement BAT. There were 11
installations considered as possible case studies. The greatest potential for pollution prevention and
reduction occurs in those installations which will continue to operate. In industrial installations using
older, out of date, highly polluting technologies there is little potential for the implementation of BAT
for technical and economic reasons. The focus for the five case studies presented in Appendix 4 is on
those installations which are similar to others which may implement BAT.
Case studies are useful in a number of ways. Case studies may stimulate other installations to
recognize the benefits and better understand the process of applying BAT. In the DRB this could cause
more rapid introduction of BAT in installations so that pollution reduction and production efficiencies
benefits will be gained sooner. Case studies are also useful to national governments in removing any
policy or legal barriers which may exist and therefore promote further application at BAT. Also, case
studies may be used to project the total potential impact of the introduction of BAT application on a
sector, country, or region. The selection of the case studies focused on outdated techniques in the most
polluting industrial sectors in the DRB. Selecting case studies within these sectors means that the case
studies clearly incorporate the specific characteristics of the DRB and the objectives of this project.
Reasons for Voluntary Implementation of BAT
For industrial institutions to implement BAT on a voluntary basis there must be a business
justification, that is, the installation must benefit economically.
Experience shows that there are a number of potential incentives for an industrial enterprise to
implement BAT. The implementation of BAT can reduce pollution fees and fines. In addition to the
reduced pollution load, production efficiencies are also likely to be achieved, and profitability
enhanced. BAT also makes the enterprise more attractive to investors and may open new markets.
New industrial technical development generally provides both production improvement and pollution
reduction. Often, the additional revenue from the introduction of new technological developments may
not only cover the investment costs but also increase profits over time.
Final Report: Industrial reform and the development of policies and legislation towards the reduction
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of nutrients and dangerous substances
The implementation of BAT makes the installation more attractive to potential investors. Investors in
the DRB are moving away from investing in existing installations, preferring instead to develop
completely new "green field" installations. Greenfield development has advantages in that the
investor controls the facility and the technology design and does not have the risk attached to updating
older buildings and technology . Also there is no risk of finding pollution loads on the site which
would require costly clean up . This means that the availability of investment funds for existing
industrial installations has decreased and therefore the competition for these funds has increased
among existing installations. Industrial installations which have adopted BAT are in a better position
to attract investment funding because it shows that they are modernizing. In BAT installations in the
DRB there is more production and pollution reduction information available. The introduction of BAT
may also provide access to additional markets. Many existing installations in the DRB were built at a
time when production output was the key requirement and environmental pollution was not a
significant consideration. With the introduction of BAT new markets may become available, for
example where the purchaser requires certification that the product has been produced according to the
highest environmental standards. BAT signifies that the installation has been upgraded and therefore is
attractive to customers which require a continuous flow of consistent, high quality, production.
Case Study Analysis
The main objective of development of case studies is to demonstrate this potential in terms of change
of pollution volumes and toxicities as well as to estimate scale of costs incurred by BAT
implementation. Industrial installations in the DRB can be grouped into three categories; new
installations, existing viable installations and existing non viable installations. While both viable and
non viable installations may be using outdated polluting technologies the viable ones are those which
have a sustainable future if upgrading occurs. The non viable category includes those which are both
economically and environmentally inefficient and therefore will not be able to survive. At these
installations full pollution reduction will be achieved by plant closure. Since ultimately the changes
occur at the level of the individual installations case studies provide an analysis at the primary level of
change. The emphasis is placed on those which are starting the process since these are most relevant to
others who wish to start the process.
Out of 11 originally assessed companies, 5 case studies were developed with focus on priority sectors
but also some other water extensive sectors were included (electro technical and food-processing). The
experience from the initial stages of Zaharni Zavodi AD, a TEST project, has been included as one of
the case studies to show the broader information which becomes available when installation enters
into a full process of upgrading.
The analysis is based upon the following five installations producing fertilizer, batteries, polyethylene
and polystyrene and pulp and paper and a vertically integrated food production facility. The case
studies were provided by the Slovak Cleaner Production Center in cooperation with other DRB
Clearer Production Centers. In Appendix 4 basic descriptive information and a summary chart are
provided containing available information on emissions and discharges, company reference data, and
certification information for each of the installations.
Information Availability
Review of the initial information suggests that there is a wide variation in the amount information
available. Generally, the technical process information is at a minimum level and there is little or no
economic data included. Many private companies prefer to release as little information as possible for
a number of reasons. Historically, virtually no information was made available to anyone so that
industrial installations have no experience with sharing information even when it will benefit the
installation. The installation management may feel the outsiders are trying to "steal the company
secrets" to use for themselves. Ironically, this is often encountered with respect to the technology used
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in production which is outdated and not useful to others. Also, once the information is made public it
is open to interpretation and may be used for purposes which are inappropriate, for example, using
minimum financial data to project profit figures by the newspapers or tax authorities. Public
information may give competitors ideas on how they can be more competitive with the installation, for
example, by installing more cost effective technology. The installation may fear that it could become a
target for an unwelcome ownership bid without consultation with the company if a potential investor
can acquire sufficient information from public sources without contacting the company. There is also
the added factor that many of the companies are formerly government owned and may not be familiar
what company information is generally available in market based economies. Cost saving is a key
consideration as an incentive for an installation to voluntarily apply BAT. However, without sufficient
information in the initial stage, it is not possible to predict an estimate of potential savings or even
whether or not cost savings can be achieved. Many installations are changing their accounting systems
to meet new national or international standards of accounting. The estimation of cost savings may be
more difficult when the installation has changed accounting systems. With different accounting
systems meaningful comparisons become difficult or even impossible.
Certification
Four of the five case study installations have one or more ISO certificates. Certification indicates that
the installation has already met a set of international standards. This has a number of implications for
BAT. By meeting the requirements of ISO 9000 or 14000 the installation is in fact meeting some of
the BAT requirements. This is particularly true for ISO 1400 which explicitly requires the
identification of environmental impacts. By going though the certification process the enterprise has
been reviewed against specific criteria and has made any necessary changes. This means that these
companies will be more prepared for the review and changes required to implement BAT. These
installations recognize that changing and upgrading is necessary in an increasingly global market
place.
Lessons Learned
The analysis above identifies a number of observations which will be useful to industrial installations
in the DRB which are considering adopting BAT on a voluntary basis:
- BAT is a very new concept for most installations in the DRB. Senior managers are not
familiar with the concept. Environmental managers may have some information about BAT
but usually do not have enough information to understand what the benefits would be to their
installation.
- Companies will voluntarily introduce BAT when there is a financial incentive for them. For
companies which are economically viable there is a stream of benefits in the short and longer
term which can provide the necessary financial incentive.
- General public data is insufficient to identify potential benefits. Potential benefits may be
identified from comparing the experience of other similar installations or from an initial
screening process based upon installation specific installation
- Support materials and other assistance are becoming more readily available for voluntary BAT
implementation. The substantial body of information related to implementing the EU IPPC
Directive is public information and can be used by the installation. Also, the UNIDO TEST
Project in the DRB has fully developed a complete process for implementing BAT as part of a
larger framework for industrial productivity improvement and pollution reduction.. There are
Final Report: Industrial reform and the development of policies and legislation towards the reduction
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of nutrients and dangerous substances
increasing numbers of experienced consultants available to assist individual installations in the
voluntary implementation of BAT.
- BAT can be implemented in phases. Installations which have gone through an ISO
certification process are more likely to be prepared to implement the process of introducing
BAT.
Therefore, it can be concluded that, in the absence of a specific legal requirement industrial
installations in the DRB have the opportunity to implement BAT on a voluntary basis. There are
additional benefits for those installations which are in countries which will have legal requirement in
the future. In these cases the voluntary introduction of BAT allows the installation to implement BAT
in a time frame which fits the circumstances of the installation rather than a timetable which is legally
binding for all installations.
3.5.8 Applying BAT at the DRB level
Consistency in industrial prevention and reduction programs across the DRB is important for the
overall improvement of the Danube River water quality. In developing the ICPDR's role in the future
it is necessary to put it in the context of the mandate of the ICPDR, and current contribution of the
EMIS EG and existing BAT implementation components which from other sources are already in
place.
BAT is applied at the level of the individual installation. The ICPDR is focused on the river basin
generally with the cooperation of the Danube countries. Therefore, one of the options is for the ICPDR
to encourage all of the Danube countries to adopt and implement IPPC legislation. The majority of the
countries have a mandatory obligation to the EU to do so and need no further encouragement or
involvement of the ICPDR. In fact, the implementation of IPPC legislation is so complicated and time
consuming the involvement of an additional party in the process would be counter productive. The
remaining countries could be encouraged to adopt legislation requiring the application of BAT.
However, given the legislative priorities and the stage of transition of these countries it would likely
be a difficult and lengthy process to get BAT implemented through the development and enforcement
of national legislation in countries not involved in the EU accession process.
BAT is a concept that may be implemented without the need for a specific legal framework. When
BAT is implemented it often results in cost savings in the operation of the industrial installation so
there may be an economic incentive. There are also country based Cleaner Production Centers capable
of providing cost effective support for the implementation of BAT. The UNIDO TEST project
substantially improved the number of such centers and their capabilities with respect to the
implementation of BAT at the level of the individual installation.
As part of this project a BAT workshop was held in Bratislava in December 2004 to discuss the issue
with selected stakeholders. In the presentations and discussions the contribution of the ICPDR through
the development of BAT industrial sector guidelines by the EMIS EG was recognized. The
participants also identified other BAT initiatives such as the BAT facility established in Seville by the
EU and the BAT activities of the Cleaner Production Centers. The Seville facility produces
information on industrial technologies BREFS, some of which are over 1000 pages. These need to be
adapted to national conditions as a legal requirement under the IPPC Directive. In summary the
number of information and support programs for the implementation of BAT in the DRB is growing
rapidly. The application of BAT occurs at the level of the individual installation with specific
conditions mandated by national governments. The workshop participants looked at a number of
options for the ICPDR in the implementation of BAT in the DRB. The consensus suggested that the
ICPDR should have an awareness and information dissemination role.
UNDP/GEF Danube Regional Project
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3.6 Recommendations and Next Steps
With the expansion of the EU within the Danube River Basin three categories of countries emerge;
member states, accession countries, and those not yet part of the current EU expansion process.
Countries that are Member States or will become Member States in 2004 have a common legislative
framework dictated by the EU Directives. While the negotiation for membership was conducted on an
individual country basis there is a similar pattern across all new Member States in terms of
institutional structure, legislation and enforcement including the implementation of BAT, which is a
legal requirement under the EU IPPC Directive. There are also three countries which are in the process
of meeting the requirements of EU membership and therefore they are working within the same
framework of the EU legislation but are not yet as far advanced . Effectively this means that the
majority of the Danube countries (9 out of 13) have a consistent approach to environmental
management including the management of their water resources, most importantly the Danube River.
The ICPDR has been very successful in developing data bases, conducting special studies, identifying
hot spots and sensitive areas and raising awareness. These activities have facilitated improvements in
water management practices in the Danube River Basin. With the majority of the countries now within
or working toward the same legislative framework new strategies emerge. It is now possible to
develop a more broadly based policy approach. The advantage of a policy approach is that it affects
change over a large number of similar situations without having to work on a case by case basis. This
makes it both more efficient and also cost effective.
3.6.1 ICPDR and EU Legislation Development
The EU legislation will dictate the approach taken to industrial pollution reduction and prevention in
the majority of the DRB countries. The EU is already involved in the ICPDR so input from the EU
perspective is considered in ICPDR decisions. The DRB would benefit from more input from the
ICPDR in the legislative development process to ensure that DRB issues are fully taken into
consideration in future EU legislation.
Recommendation
The ICPDR should establish a mechanism to support the six ICPDR national governments which are
also EU Member States to advocate future EU policy and decisions which are directed toward the
reduction and prevention of the industrial water pollution in the DRB. This mechanism also could be
used to support other ICPDR policy initiatives.
3.6.2 Capacity building support programs
However, only EU Member States and those preparing for membership will be affected by this
approach therefore a second approach is needed.
·
For each of the ICPDR member countries, not involved in EU accession, it is recommended
that a targeted three year support program for industrial pollution reduction policy and capacity
building be developed. The components should include legislation drafting, institutional development,
technical assistance and training among others. The program would be developed in cooperation with
the individual national government and tailored to the needs of each country. These activities should
be complementary similar activities by other international organizations which are either underway or
planned for these countries.
The initial step would be to do a needs analysis in each country. Based upon the analysis a country
specific work plan would be developed in cooperation with national officials. A key factor in
developing the country work plans would be sustainability. Sustainability is dependent upon a number
of factors; however, the key factor is the priority and commitment of the host government. This can
best be assured by detailed discussions and agreement during the needs analysis phase and a flexible
Final Report: Industrial reform and the development of policies and legislation towards the reduction
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of nutrients and dangerous substances
approach to implementation. As part of the country needs analysis other donor initiatives will be
reviewed. This review can identify not only gaps but also extension possibilities. These are situations
where a previous project can be extended by the ICPDR to obtain additional benefits to the country in
a very cost efficient way because it builds upon the prior resource allocation.
Several types of support might be provided including the following:
· short term research and analysis of a specific issue (3-6 months). This type of project might be
for example an inventory of approaches of other countries in addressing a specific issue
· medium term analysis and institution building aimed at a small number of issues in a single
institution. (6-12 months). For example, assisting in developing a revised organization
structure to more efficiently analyze policy options or deliver an industrial pollution initiative.
In addition, it would be useful to establish a central information center which the countries could
contact to receive either specific information or sources of information as appropriate. The center
includes those involved in the country specific support program and other experts as needed.
This approach would reflect the current situation in the Danube Basin by ensuring that EU Directives
address the priority issues. At the same time it would allow the non EU countries to strengthen their
individual approaches to industrial pollution control.
3.6.3 BAT
The concluding discussions of the BAT workshop combined with the analysis conducted by the
project team identified a rapidly growing number of sources for BAT in the DRB. BAT is not a water
management tool per se but addresses other media as well. Those other media are not within the
mandate of the ICPDR.
Recommendation
The role of the ICPDR should be to provide information links to the appropriate sources of BAT
information specifically included BAT experts which have worked with the EMIS EG. This should be
done by creating a BAT information link on the ICPDR website. The EMIS EG should review the
current sources of BAT and select the most appropriate BAT information sources. The links to these
sources and the EMIS EG BAT experts should be placed on the ICPDR website. The sources should
be reviewed and upgraded annually. In this way the ICPDR supports the pollution reduction potential
of BAT by providing a basin wide service in support of BAT implementation without duplicating the
activities of other organizations.
The first step is to identify information sources and individual experts on BAT in the DRB. A link
should then be created on the ICPDR website.
Final Report: Industrial reform and the development of policies and legislation towards the reduction
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of nutrients and dangerous substances
3.7 Appendices
Final Report: Industrial reform and the development of policies and legislation towards the reduction
75
of nutrients and dangerous substances Appendix 1: Comparison of EMIS Inventory Parameters and Other Data Sources
Appendix 1: Comparison of EMIS Inventory Parameters and Other Data
Sources
Final Report Industrial reform and the development of policies and legislation towards the reduction
77
of nutrients and dangerous substances
APPENDIX 1.
COMPARISON OF EMIS INVENTORY PARAMETERS AND OTHER DATA
SOURCES
The following chart compares the current EMIS categories and threshold limits with the EU
IPPC categories and threshold limits.
The EMIS industrial inventory deals with selected industries that are grouped into 11 sectors following
a classification system developed for the EMIS inventory. The main related EU Directive, the IPPC
directive uses an internationally recognized coding system which has very similar coding.
Current ICPDR Industrial Sectors IPPC
Source
Categories
1
Food industry
1
Energy industries
2
Chemical industry
2
Production and processing of metals
3
Pulp&paper industry
3
Mineral industry
4
Fertilizer industry
4
Chemical industry and chemical installations
5 Mining
5
Waste
management
6
Iron and steel industry
6
Other Annex I activities
7
Metal surface industry
8 Textile
industry
9 Leather
industry
10 Agriculture
11 Other
relevant
industry
The EMIS industrial inventory includes those polluters that produce 2 tons of COD per day and 1 ton
of BOD per day. The data for IPPC installations will be kept according to the EPER Decision that
prescribes the threshold values of pollutants of pollutants.
Current ICPDR polluters Kg/day EPER list of threshold values
Kg/year
threshold value
COD
2 000
Total N (as N)
50 000
BOD
1 000
Total P (as P)
5 000
As and compounds (as As total)
5
Cd and compounds (as Cd total)
5
Cr and compounds (as Cr total)
50
Cu and compounds (as Cu total)
50
Hg and compounds (as Hg total)
1
Ni and compounds (as Ni total)
20
Pb and compounds (as Pb total)
20
Zn and compounds (as Zn total)
100
Dichloroethane
1,2
(DCE)
10
Dichloromethane
(DCM)
10
Chloro-alkanes
(C10-13)
1
Hexachlorobenzene
(HCB)
1
Hexachlorobutadiene
(HCBD)
1
Hexachlorocyclohexane
(HCH) 1
Halogenated organic compounds (as AOX)
1 000
Benzene, toluene, ethylbenzene, xylenes (as BTEX)
200
Brominated
diphenylether
1
Organotin compounds (as total Sn)
50
Polycyclic aromatic hydrocarbons
5
Phenols (as total C)
20
Total organic carbon (as total c or COD/3
50 000
Chlorides (as total Cl)
2 000
Cyanides (as total CN)
50
Fluorides (as total F)
2 000
UNDP/GEF Danube Regional Project
78
Water
EU WFD priority
Danube priority
Emission
TNMN JDS
substances
substances
inventories
Alachlor
µg/l
µg/l
n.d.
Anthracene
µg/l
µg/l
Atrazine
µg/l
µg/l
µg/l
µg/l
Benzene
µg/l
µg/l
µg/l
Brominated diphenylethers
µg/l
µg/l
Cadmium and its compounds
µg/l
µg/l
µg/l
µg/l
t/a
C
-chloroalkanes
10-13
µg/l
µg/l
Chlorfenvinphos
µg/l
µg/l
n.d.
Chlorpyrifos
µg/l
µg/l
n.d.
1,2-Dichloroethane
µg/l
µg/l
µg/l
Dichloromethane
µg/l
µg/l
n.d.
Di(2-ethylhexyl)phthalate (DEHP)
µg/l
µg/l
Diuron
µg/l
µg/l
n.d.
Endosulfan
µg/l
µg/l
n.d.
(alpha-endosulfan)
µg/l
µg/l
n.d.
Fluoranthene
µg/l
µg/l
Hexachlorobenzene
µg/l
µg/l
n.d.
Hexachlorobutadiene
µg/l
µg/l
Hexachlorocyclohexane
µg/l
µg/l
(gamma-isomer, Lindane)
µg/l
µg/l
µg/l
n.d.
Isoproturon
µg/l
µg/l
n.d.
Lead and its compounds
µg/l
µg/l
µg/l
µg/l
t/a
Mercury and its compounds
µg/l
µg/l
µg/l
n.d.
t/a
Naphthalene
µg/l
µg/l
n.d.
Nickel and its compounds
µg/l
µg/l
µg/l
µg/l
t/a
Nonylphenols
µg/l
µg/l
(4-(para)-nonylphenol)
µg/l
µg/l
Octylphenols
µg/l
µg/l
(para-tert-octylphenol)
µg/l
µg/l
Pentachlorobenzene
µg/l
µg/l
Pentachlorophenol
µg/l
µg/l
Polyaromatic hydrocarbons
µg/l
µg/l
(Benzo(a)pyrene)
µg/l
µg/l
(Benzo(b)fluoranthene)
µg/l
µg/l
(Benzo(g,h,i)perylene)
µg/l
µg/l
(Benzo(k)fluoranthene)
µg/l
µg/l
(Indeno(1,2,3-cd)pyrene)
µg/l
µg/l
Simazine
µg/l
µg/l
n.d.
Tributyltin compounds
µg/l
µg/l
(Tributyltin-cation)
µg/l
µg/l
Trichlorobenzenes
µg/l
µg/l
µg/l
(1,2,4-Trichlorobenzene)
µg/l
µg/l
µg/l
Trichloromethane (Chloroform)
µg/l
µg/l
µg/l
µg/l
Trifluralin
µg/l
µg/l
n.d.
Chemical Oxygen Demand (COD)
mg/l
mg/l
t/a
Ammoniacal Nitrogen (NH -N)
4
mg/l
mg/l
mg/l
t/a
Organic Nitrogen
mg/l
mg/l
Total Nitrogen (tot N)
mg/l
t/a
Total Phosphorus (tot P)
mg/l
mg/l
mg/l
t/a
Arsenic and its compounds
µg/l
µg/l
µg/l
t/a
Final Report Industrial reform and the development of policies and legislation towards the reduction
79
of nutrients and dangerous substances
EU WFD priority
Danube priority
Emission
TNMN JDS
substances
substances
inventories
Copper and its compounds
µg/l
µg/l
µg/l
t/a
Zinc and its compounds
µg/l
µg/l
µg/l
t/a
Chromium and its compounds
µg/l
µg/l
µg/l
t/a
p,p'DDT
µg/l
Carbon tetrachloride
µg/l
µg/l
Trichloroethylene
µg/l
µg/l
Tetrachloroethylene
µg/l
µg/l
Iron
mg/l
t/a
Manganese
mg/l
t/a
Magnesium
mg/l
t/a
Aluminium
µg/l
µg/l
t/a
Sulphates
mg/l
t/a
Phenols
mg/l
t/a
Fluorides
t/a
Petroleum Hydrocarbons
mg/l
t/a
Chlorides
mg/l
t/a
Detergents
mg/l
t/a
Sulfide
t/a
Formaldehyde
t/a
Methanol
t/a
AOX
µg/l
t/a
Nonpolar extractables
t/a
Dissolved inorganic substances
t/a
Chlorinated hydrocarbons
t/a
Suspended solids
mg/l
mg/l
t/a
Nitrate (NO3-N)
mg/l
mg/l
t/a
Nitrite (NO2-N)
mg/l
mg/l
t/a
Ortho-phosphate (PO4-P)
mg/l
mg/l
t/a
Active chlorine
t/a
Dissolved silicate
mg/l
t/a
UNDP/GEF Danube Regional Project
80
Suspended solids and sediments
EU WFD priority
Danube priority
Emission
TNMN JDS
substances
substances
inventories
Anthracene
µg/kg
µg/kg
mg/kg
Atrazine
µg/kg
µg/kg
Brominated diphenylethers
mg/kg
mg/kg
n.d.
Cadmium and its
compounds
mg/kg
mg/kg
mg/kg mg/kg
t/a
C
-chloroalkanes
10-13
µg/kg
µg/kg
n.a.
Chlorpyrifos
µg/kg
µg/kg
Di(2-ethylhexyl)phthalate
(DEHP)
mg/kg
mg/kg
mg/kg
Endosulfan
µg/kg
µg/kg
(alpha-endosulfan)
µg/kg
µg/kg
Fluoranthene
µg/kg
µg/kg
mg/kg
Hexachlorobenzene
µg/kg
µg/kg
mg/kg
Hexachlorobutadiene
µg/kg
µg/kg
mg/kg
Lindane (gamma HCH)
µg/kg
µg/kg
mg/kg mg/kg
Lead and its compounds
mg/kg
mg/kg
mg/kg mg/kg
t/a
Mercury and its compounds
mg/kg
mg/kg
mg/kg mg/kg
t/a
Naphthalene
µg/kg
µg/kg
mg/kg
Nickel and its compounds
mg/kg
mg/kg
mg/kg mg/kg
t/a
Nonylphenols
µg/kg
µg/kg
mg/kg
(4-(para)-nonylphenol)
µg/kg
µg/kg
mg/kg
Octylphenols
µg/kg
µg/kg
mg/kg
(para-tert-octylphenol)
µg/kg
µg/kg
mg/kg
Pentachlorobenzene
µg/kg
µg/kg
mg/kg
Pentachlorophenol
µg/kg
µg/kg
n.d.
Polyaromatic hydrocarbons
µg/kg
µg/kg
mg/kg mg/kg
(Benzo(a)pyrene)
µg/kg
µg/kg
mg/kg mg/kg
(Benzo(b)fluoranthene)
µg/kg
µg/kg
mg/kg mg/kg
(Benzo(g,h,i)perylene)
µg/kg
µg/kg
mg/kg mg/kg
(Benzo(k)fluoranthene)
µg/kg
µg/kg
mg/kg mg/kg
(Indeno(1,2,3-cd)pyrene)
µg/kg
µg/kg
mg/kg mg/kg
Simazine
µg/kg
µg/kg
Tributyltin compounds
µg/kg
µg/kg
mg/kg
(Tributyltin-cation)
µg/kg
µg/kg
mg/kg
Trichlorobenzenes
µg/kg
µg/kg
(1,2,4-Trichlorobenzene)
µg/kg
µg/kg
Trichloromethane
(Chloroform)
µg/kg
µg/kg
Trifluralin
µg/kg
µg/kg
Organic Nitrogen
mg/kg Mg/kg
Total Nitrogen (tot N)
mg/kg
t/a
Total Phosphorus (tot P)
mg/kg
mg/kg Mg/kg
t/a
Arsenic and its compounds
mg/kg
mg/kg Mg/kg
t/a
Copper and its compounds
mg/kg
mg/kg Mg/kg
t/a
Zinc and its compounds
mg/kg
mg/kg Mg/kg
t/a
Chromium and its
compounds
mg/kg
mg/kg mg/kg
t/a
p,p'DDT
mg/kg Mg/kg
PCB
mg/kg Mg/kg
Petroleum Hydrocarbons
mg/kg Mg/kg
t/a
Source: (Rodeco Consulting, Draft Report, August 2003)
Final Report: Industrial reform and the development of policies and legislation towards the reduction
81
of nutrients and dangerous substances Appendix 2: EU Water Legislation
Appendix 2: EU Water Legislation
Final Report: Industrial reform and the development of policies and legislation towards the reduction
83
of nutrients and dangerous substances Appendix 3: Report from the BAT Workshop
Appendix 3: Report from the BAT Workshop
Final Report: Industrial reform and the development of policies and legislation towards the reduction
85
of nutrients and dangerous substances Appendix 3: Report from the BAT Workshop
UNDP/GEF Danube Regional Project
Strengthening the Implementation Capacities for Nutrient Reduction and
Transboundary Cooperation in the Danube River Basin
Report from the BAT Workshop
Bratislava, on December 4th-5th, 2003
Project Component 1.5:
Industrial reform and the development of policies and
legislation towards the reduction of nutrients and
dangerous substances
December 6, 2003
Prepared by:
Ramboll
Authors Stanislav Kosina, Danka Jassikova-Thalmeinerova, Tom Owen
Final Report: Industrial reform and the development of policies and legislation towards the reduction
87
of nutrients and dangerous substances Appendix 3: Report from the BAT Workshop
1. INTRODUCTION
The workshop is an activity of the industrial pollution reduction policy analysis component 1.5 of the
UNDP-GEF Terms of Reference. One approach to the reduction of industrial pollution is to have
installations apply Best Available Techniques (BAT). BAT has been introduced into the Danube River
Basin. It is a legal requirement in all EU and accession countries for industrial installations which fall
under the IPPC Directive. It has also been a requirement for World Bank project support in Bulgaria.
UNIDO has also sponsored the TEST programme on a voluntary basis for a selected number of
industrial installations in the basin.
Levels of awareness and knowledge of the BAT concept are very different among countries in the
region as well as among different ministries and stakeholder groups within individual countries.
This workshop in addition to country representatives will bring together experts working with BAT in
the region including the UNIDO TEST Project and Cleaner Production Centres.
1.1 Objectives:
The workshop is designed to facilitate cooperation in the region to achieve full utilisation of the
potential of BAT to improve industrial water pollution in the DRB.
Specifically the objectives are to:
provide the basis for a common understanding of BAT potential in the Danube River Basin
particularly as it relates to the implementation to the Water Framework and IPPC Directives
exchange information and experience from different countries in the region, and
share experience from recent regional or local industrial case studies.
identify the potential contribution of BAT in the management of water resources in the
Danube River Basin
UNDP/GEF Danube Regional Project
88
2. SUMMARY OF TOPICS DISCUSSED
The two major EU Directives relating to the reduction of industrial pollution in the DRB are the Water
Framework Directive and the Integrated Pollution Prevention and Control Directive. The WFD is the
primary tool for water management and the IPPC is directed at the control of large industrial
installations. On the first day these two directives were presented in the morning following the
introductory remarks. The EMIS EG of the ICPDR has had several activities relating to industrial
pollution reduction ranging from being responsible for the Emission Inventory which identifies
industrial installations which are pollution sources through to developing sectoral guidelines for the
application of BAT. Following the lunch break the presentations moved toward a more methodology
and installation specific focus with the presentation of the UNIDO-TEST methodology and case
studies being presented. This was followed by a presentation with respect to the pulp and paper sector.
This provided not only an overview of the sector issues but also an insight into how the private sector
views the implementation of IPPC. The final presentation focused on the practical considerations
through the discussion of the application of BAT to a pulp and paper installation. The presentation
included both environmental and financial considerations. At the end of the day it could be seen that at
least some of the participants found the information somewhat confusing. Whether it was because of
the complexity or volume of information or some other factor was unclear.
The second day was devoted to country presentations. The presentations were very good focusing on
the issues raised in the material sent to participants prior to the seminar. Because they were focused on
real situations in the countries the participation was much higher. In addition, there were informal
discussions among countries on questions of mutual interest for example on the method of
transboundary communication. The wrap up discussions summarized the role of the ICPDR role in
reducing industrial pollution, namely to assist in the development of priorities, track progress and how
best to influence the use of BAT in the DRB. Specifically with respect to BAT, the role of other
bodies such as EU and UNIDO was discussed along with the growing number of Cleaner Technology
Centers. While it was agreed to wait until the final report of The Industrial Pollution Project (1.5) there
was noticeable support for a website link to the main sources of BAT information.
Final Report: Industrial reform and the development of policies and legislation towards the reduction
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of nutrients and dangerous substances Appendix 3: Report from the BAT Workshop
3. SUMMARY OF PRESENTATIONS
Speaker:
Ivan Zavadsky
Presentation: Danube Regional Project: Strengthening the Implementation Capacities for Nutrient
Reduction and Transboundary Cooperation
Summary: Overview of UNDP-GEF Project which is the overall framework for the workshop.
Speaker:
Tom Owen
Presentation: UNDP Regional Project: Industrial reform and the development of policies and
legislation towards the reduction of nutrients and dangerous substances
Summary:
Outline of the activities of section 1.5 of the ToR of the UNDP-GEF. The workshop is
part of 1.5 with the objective of facilitate cooperation in the region to achieve full
utilisation of the potential of BAT to improve industrial water pollution in the DRB.
Speaker:
Ursula Schmedtje
Presentation: UNDP Regional Project: Industrial reform and the development of policies and
legislation towards the reduction of nutrients and dangerous substances
Summary:
A detailed description of the philosophy behind the WFD and the implementation
issues including the ICPDR role in providing the Roof Report.
Speaker:
Margareta Stubenrauch
Presentation: Council Directive 96/61/EC of 24 September 1996 concerning Integrated Pollution
Prevention and Control (IPPC)
Summary:
An overview of the history, philosophy and implications for implementing the IPPC
Directive.
Speaker:
Philip Weller
Presentation: The ICPDR Framework on emission control
Summary:
An overview of the organizations and activities within the ICPDR which form the
framework for pollution reduction in the DRB
Speaker:
Ursula Schmedtje
Presentation: UNDP Regional Project: Industrial reform and the development of policies and
legislation towards the reduction of nutrients and dangerous substances
Summary:
A detailed description of the philosophy behind the WFD and the implementation
issues including the ICPDR role in providing the Roof Report.
Speaker:
Mihaela Popovici
Presentation: Role of the EMIS EG in reducing industrial pollution
Summary:
A detailed history of the involvement of the EMIS EG in relation to industrial
pollution control including the introduction of selected sector guidelines
Speaker:
Roberta de Palma
Presentation: UNIDO-TEST Project: An Integrated Approach for Introducing BAT
Summary:
The UNIDO Test Project has developed methodology for the analysis of the
application of BAT in individual installations. The methodology has been used to
develop case studies in the DRB. The presentation included the UNIDO-TEST results.
Speaker:
Philip Weller
Presentation: Future Role of ICPDR in addressing Industrial Pollution
Summary:
ICPDR assist governments to identify priorities in reducing industrial pollution
track the progress in reducing emissions. The question is how best to identify the
influence of the introduction of BAT on pollution prevention. The role of the ICPDR
in future will have to be developed recognizing the roles and responsibilities of other
UNDP/GEF Danube Regional Project
90
organizations for example the EU and UNIDO. Also a suggestion was made that
perhaps a webpage link to other BAT information sites might be a good idea. The
ICPDR will make a decision following review of the report for component 1.5 of the
UNDP-GEF ToR which will make specific recommendations
Speaker:
Josef Zboril (Czech Republic)
Presentation: IPPC in the Czech (Pulp and Paper) Industry, Romanian Experience
Summary:
A detailed discussion of BAT in the Pulp and Paper Industrial sector based upon the
experience in Romania and the Czech Republic. Provided insight into industry issues
and expectations with respect to legal introduction of BAT through IPPC
Speaker:
Viera Feckova (Slovakia)
Presentation: Company Case Studies
Summary:
Presentation of the approach to BAT in operating countries with illustrations of the
types of issues addressed at the company level, and the financial impact of the
application of BAT. BAT implementation often leads to very quick payback periods
which can be finance by the cost saving of that activity. However there is also the
need to include more costly BAT changes in the company's long term investment
plan.
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of nutrients and dangerous substances Appendix 3: Report from the BAT Workshop
4. SUMMARY OF COUNTRY SITUATIONS
Speaker:
Juliana Chidu (Romania)
Presentation: Administrative responsibilities for
transposition and implementation of IPPC Directive in ROMANIA
Summary:
IPPC transposed. Inventory of IPPC ready (~2500 installations). Transition period
2007-2014 is expected but not yet approved
Speaker:
Teodor Lucian Constantinescu (Romania)
Presentation: WFD Implementation in Romania
Summary:
New Water Act (ready in 2004) will transpose WFD. It is still not clear an integrated
permit will be issued
Speaker:
Maria Boyadjiiska (Bulgaria)
Presentation: Implementation of Best Available Techniques (BAT) within the overall EU Water
Framework Directive (WFD) and the specific requirements of the EU IPPC Directive
Summary:
Permits are done by sites! 255 site applications have already been received.
Methodologies for applications, permits, inspection and BAT are ready.
The discussion between Bulgaria and Romania took place with respect to
communication of transboundary impacts.
Speaker:
Hristina Stevanovic (Serbia and Montenegro)
Presentation: IPPC and WFD in Serbia and Montenegro.
Summary:
New Act on Environment is being prepared 840 IPPC Installations identified. Permits
will be delayed until 2010. Currently permitting is split among different authorities
Speaker:
Mladen Borso (Croatia)
Presentation: Implementation WFD and IPPC in Croatia
Summary:
IPPC not yet considered. Link between MoE and MW not good Commitment to
harmonization declared but not yet implemented. Some research on BAT done.
Speaker:
Szilvia Gondar and Gyorgy Botond (Hungary)
Presentation: IPPC in Hungary
Summary:
IPPC Act adopted. Around ~1000 IPPC installation identified. 23 permits issued .
Speaker:
Jan Marsak (Czech Republic)
Presentation: Implementation of IPPC in the CR.
Summary:
IPPC and WFD implemented. Permitting in Progress ~30 permits issued
Speaker:
Stanislav Kosina (Slovakia)
Presentation: Implementation WFD and IPPC in Slovakia.
Summary:
IPPC and WFD laws are in place. Permitting in Progress. Around 540 IPPC
installations identified, among them there are 33 new ones.
UNDP/GEF Danube Regional Project
92
5. RECOMMENDATIONS OF THE WORKSHOP
The IPPC Role to meet objectives of the DRB needs to be further refined
The benefits of BAT implementation to improve water quality in DRB needs to be further assessed
The role of water managers in BAT implementation with respect to WFD needs to be better defined
The ICPDR should review and refine its strategies to reduce industrial pollution (via BAT, Cleaner
production)
The Workshop has been a good start with knowledgeable presentations and excellent country and
raised issues where addition is required.
The role of ICPDR with respect to BAT needs to be refined, however given the information presented
at the Workshop the most common suggestion was that the ICPDR set up a link on the web page that
would refer to sites that provide and update the most relevant information.
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of nutrients and dangerous substances Appendix 3: Report from the BAT Workshop
List of participants:
Name Institution
Country
Philip Weller
ICPDR
Austria
Ivan Zavadsky
UNDP-GEF
Austria
Ursula Scmedtje
ICPDR
Austria
Michaela Popovici
ICPDR
Austria
Margareta Stubenrauch
Fed.MoAFEandWM
Austria
Roberta de Palma
UNIDO
Austria
Georgi Ivanov
MoEW BG/Water
Bulgaria
Maria Boyadjiiska
MoEW BG/IPPC
Bulgaria
Mladen Borso
MoEW CR
Croatia
Marijan Host
CPC Croatia
Croatia
Tomas Zelinka
MoEW Czech/Water
Czech Republic
Jan Marsak
MoEW/Czech/IPPC
Czech republic
Josef Zboril
Private Consultant,Czech
Czech republic
Association of Industries and
Transportation
Pia Jorgenssen
Ramboll
Denmark
Gyuyla Zilahy
CPC Hungary
Hungary
Gyorgy Botond
MoEW HU/Water
Hungary
Szilvia Gondar
MoEW HU/IPPC
Hungary
Juliana Chidu
MoAFWE Ro Water
Romania
Teodor Lucian Constantinescu
Romanian Waters
Romania
Dragan Povrenovic
University Belgrade
Serbia
Hristina Stevanovic
MoE Serbia
Serbia
Tanja Popovicki
MoE Serbia
Serbia
Stanislav Kosina
Ramboll
Slovakia
Tom Owen
Ramboll
Slovakia
Danka Thalmeinerova
Ramboll
Slovakia
Zdena Kelnarova
MoE SK Water
Slovakia
Viera Feckova
CPC Slovakia
Slovakia
UNDP/GEF Danube Regional Project
94
Workshop Agenda
4 Dec. 2003 (Thursday)
Sessi
Time Topics
Speaker Session
Chair
on
8.00
Coffee and registration
9.00
Welcome to participants
Ms.Eleonora Bartkova
Ivan
r
oduction
Zavadsky
9.10
Ivan Zavadsky
The GEF Danube Project
UNDP/GEF Project
Manager
9.25
Objectives, expected results.
Tom Owen/Industrial
Session I - Int
Introduction of participants
Reform Project Manager
9.45
Ursula Schmedtje
Water Framework Directive
ICPDR Secretariat
10.15
Discussion
10.25
Margareta
Stubenrauch/Unit for EU
Tom Owen
IPPC Directive
Affairs, Min. Agr.,
Forestry&Water Mgmt
and Env.
Session II EU
Legislation
10.45
Discussion
11.05
Coffee Break
11.30
The ICPDR Framework
Phil Weller/ ICPDR
Ivan
on emission control
Executive Secretary
Zavadsky
11.45
Role of the EMIS EG
Mihaela Popovici
in reducing industrial pollution
Discussion
Session III Role
of ICPDR
12.30
Lunch
13.45
UNIDO TEST PROJECT
Ms.Roberta De
Palma/UNIDO Test
Project Director
Studies
14.15
Discussion
14.30
BAT in the pulp and paper sector
Mr.Josef Zboril
Consultant, Czech
Republic
Tom Owen
15.00
Discussion
15.15
Coffee Break
15.45 17.45
Company Case studies
Ms.Viera
Feckova/Director CPC
Session IV Country Case
Slovakia
18.30
Dinner
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of nutrients and dangerous substances Appendix 3: Report from the BAT Workshop
5 Dec. 2003 (Friday)
Time Session
Topics
Speaker
Session Chair
9.00-
Country
10.30
representatives
Country presentations
Ivan Zavadsky
10.45
Session V -
Country
experience
Coffee break
11.00-
Future Role of ICPDR in
Philip Weller
12.30
Addressing Industrial Pollution
Tom Owen
12.30
Mr. Ivan Zavadsky,
Session
VI
Conclusi
ons
Conclusions
Mr. Tom Owen
13.00 Lunch
UNDP/GEF Danube Regional Project
96
Invitation to participants letter
To:
ICPDR - Heads of Delegation
From: Ivan
Zavadsky
Project Manager
Subject:
BAT workshop in Bratislava
December
4th and 5th 2003
Vienna,
30/9/2003
Dear colleagues,
The Danube Regional Project is organizing a workshop on the implementation of Best Available
Techniques (BAT) within the overall EU Water Framework Directive (WFD) and the specific
requirements of the EU IPPC Directive.
The workshop will begin with a presentation and discussion of the EU Water Framework Directive
(WFD) and the IPPC Directive. There will also be presentations on the methodology to analyze
individual industrial installations, a sectoral appraoch to BAT implementation and several case studies
from DRB countries.. The current and possible future role of the ICPDR in industrial reform will also
be discussed.
With regard to the preparation of this workshop, I would like to ask you to nominate two participants.
One person should be a person responsible for water management, particularly industrial pollution
control programs who is prepared to comment upon the real potential impact of implementing IPPC on
industrial water pollution in that country. The other person should be a person responsible or involved
in the application of BAT generally in your country. It may be that this person may come from the
water field but in other cases may be in another field and may be in another ministry.
I will appreciate to receive the nomination of the experts from your country by 12 November 2003.
Thank you for your attention and cooperation
Yours sincerely,
Ivan Zavadsky
Project Manager
(Signed)
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of nutrients and dangerous substances Appendix 3: Report from the BAT Workshop
Questions to participants
There will be an opportunity for each country to make a presentation on the existing and planned
activities. We are looking for two types of information. The first group of questions is directed toward
understanding the context for the implementation of BAT. The second will help participants
understand the potential impact of BAT on the reduction of water pollution in the industrial sector.
As a starting point for the context presentation:
1) What is the countries relationship the EU i.e. New Member, Accession partner etc? If your
country is not part of the formal process it would be interesting to know how EU legislation
affects your national legislation i.e. we are implementing some of the principles, acts, or EU
legislation is not considered
2) How much of the EU environmental legislation has been transpose into your national legislation
3) Who are the responsible authorities for the implementation of the WFD and IPPC?
4) At what stage of development are the enforcement and monitoring systems?
5) What are the major issues with respect to the implementation of BAT at this time?
6) What is industry's reaction to the implementation of BAT through the IPPC legislation?
For the water impact discussion it would be interesting to know:
1) How many installations which discharge to water will be covered by the BAT requirement in
IPPC? Can you give us an idea what is the relevant importance of IPPC installations for
example, a rough percentage of total installations with water pollution discharges or the rough
percentage of the total water pollution which will be accounted for by IPPC installations.
2) Please try to estimate what will be the water pollution reduction impacts of BAT
implementation in your country, compared to the situation without BAT. Please identify the
specific components of BAT that are most important in contributing to the pollution reduction.
UNDP/GEF Danube Regional Project
98
Information for participants
Venue:
Congress Centre UVS (Ustav vzdelavania a sluzieb)
Bardosova 33
Bratislava
Tel:
++421- 02- 54772060, 54772123
How to get to the Hotel:
When we have more detailed information on arrival times we will make common arrangements for
those arriving at the same time.
From Vienna airport to Bratislava bus station
There is a regular bus connection from Vienna Schwechat Airport to the Bratislava Bus Station. The
bus stop for Bratislava is right in front of the Vienna airport. The name of Bratislava station is
Mlynske Nivy. The bus leaves from Vienna to Bratislava every hour. The ticket can be purchased
form the driver. The price is cca 10 EURO. Extra 1 2 EURO is paid for luggage and the payments
must be made in Euro.
The detailed schedule of departures from Vienna airport is: 10:40, 11:40, 12:55, 13:25, 14:25, 15:25,
17:25, 18:25, 18:55, 20:40, and 22:25
From Bratislava bus station Mlynske Nivy to the Hotel UVS
There is a trolleybus No. 206 that departs directly from the bus station Mlynske Nivy to Bardosova
Street (the ninth stop). The trolleybus departs every 15 minutes. You will need a 30 minute ticket that
can be purchased at a kiosk. The price is 16 SK. The hotel is located at Bardosova Street 33. The name
of locality is Kramare.
You can take a taxi; the price is approx. 400 SK (10 EURO). The taxi will not be reimbursed.
By Car
From the west and south when you pass customs take the road to Brno. You will come to a set of
traffic lights. Go straight through the traffic lights on Stromova St. up the hill and past the hospital.
Then you will come to traffic lights at the corner of Na Revine St. Turn left and it will take you to
Hotel UVS. From the Czech Republic proceed directly into Bratislava and turn left on Stomova street
( the third traffic light) and follow the directions above.
A Bratislava map can be found on http://mapy.zoznam.sk.
By Train
Take a taxi from the main railway station.
Visas:
Those who need assistance with a visa for Austria and Slovakia should please let us know as soon as
possible. We will send you a nominal invitation and inform the Embassy in your country about your
participation at the meeting.
The letter to CPC's, letter to invitees, Copies of the presentations are still missing and should be put in
the annexes.
Final Report: Industrial reform and the development of policies and legislation towards the reduction
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of nutrients and dangerous substances Appendix 4: BAT Case Studies
Appendix 4: BAT Case studies
Industrial reform and the development of policies and legislation towards the reduction
of nutrients and dangerous substances
Company Info
Name: ELHIM ISKRA JSC
Branch: Electrochemical
industry
Address: 4400
Pazardzhik
9 Iskra Str.
BULGARIA
Date of establishment: 25 December 1960
Production: The company ELHIM ISKRA JSC is the biggest Bulgarian
producer of starting and traction batteries of different types:
Starter batteries:
· for motorcycles ( 6V/7Ah, 6V/14Ah, 12V/4Ah)
· standard (from 12V/44Ah to 12V/210Ah)
· max Energy (from 12V/44Ah to 12V/85Ah)
· maintenance free (from 12V/44Ah to 12V/100Ah)
Traction batteries:
· pasted
· panzer
· with enhanced resource
· according to the wish of the client
The company has its distributors in the bigger cities of Bulgaria,
and the total number of the sites where its products
are sold comes to 65.
Number employees:
app. 500
Turnover:
Telephone:
+359 34 444 548
Fax: +359 34 443 438
E-mail: elhimiskra@mbox.digsys.bg
UNDP/GEF Danube Regional Project
102
Brief history
1960
In November 1960 the first ebonite boxes and lids were produced. The
production of first starter storage battery "Iskra" 12V/82Ah and motorcycle
battery type 12V/14Ah was started.
25.12.60
The inauguration of the battery factory in Pazardzhik city
1962
The production of the first 5 types of traction batteries was started
1964
The first reconstruction and modernisation began. The technological process was
improved.
1968
The first reconstruction ended. As a result the battery factory in Pazardzhik city became
the largest one on the Balkans.
1981
The most modern technologies and equipment for the production of traction panzer
batteries and starter batteries in plastic boxes with reduced maintenance were
introduced into the factory.
Beginning The end of the reconstruction. It gave the ability to "ELHIM-ISKRA" JSC to produce
of the 90's even at the moment products comparable to the products of the world leaders in this
branch. At the same time the production is done with up-to-date equipment, modern
technologies and by highly qualified specialists and excellent workers.
2000
The battery factory was certified for the first time according to ISO. The factory
received also for the first time a certificate of conformity according to the
Ukrainian certification system UkrSEPRO..
After 2000 Despite the conditions of keen competition in the branch, "Elhim-Iskra" JSC continues
to offer fair prices and products with high quality. The factory realizes successfully its
new types of starter batteries "maintenance free" (Ca) and "Max Energy" (ME), and
at the same time continues its work for the creation of new products.
Production Process and Facilities
The factory is equipped with up-to date machinery and whole production process is under control. The
central factory's laboratory monitors all incoming raw materials and components for battery
production as well as of the production processes and thus ensuring needed quality of the final
products. Several are the important sections: incoming control of the raw materials, fast monitoring of
wide range of purity of water lead and other components
Production process begins in the grid casting department where the grids for the starter and traction
batteries are produced. Low antimony alloys are used in the casting area and they prolong the life of
the batteries and make the production competitive on the local and international markets.
The next unit is paste mixing department, which consists of three areas: the mill, pasting and acid
mixing. The production of the lead powder is carried out on the installation from USA. The high
purity of the Bulgarian lead 99.99% is a prerequisite for production of good quality batteries.
In the acid mixing area mixing, storage and dispensing of acid is carried out. By means of pumps the
acid is fed to paste mixing area and formation department.
In the paste mixing area mixing of lead powder with purified water, electrolyte and other additives is
done. The process is automated and accomplished with count-current mixers. The mixture is than pot
into the feeders and after fed to machine, which press the mixed paste onto the batteries' grids.
Formation process is done by means of reversing current charging units, which are controlled by local
computerised system. Complete control is performed by computer data system for following the
operation of the current charges and formation groups.
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of nutrients and dangerous substances Appendix 4: BAT Case Studies
Formed starter and industrial plates are dried in electric and steam tunnels as well as in glide drying
ovens. After drying double plates are parted and ready for pre-assembling.
The containers for the automotive batteries and the traction cells are manufactured in the plastics
department. There are different sizes depending of the battery capacities.
In the assembly department whole range of automotive and traction batteries are made. The area is
equipped with up to date machines like TBS-UK, DAGA-Italy and HADI-Germany.
The production cycle finished with the stand for dry charge test of the batteries in accordance with
DIN, BDS, IEC and GOST standards.
For laid acid wastewater treatment the purification plant was designed and putted into operation in the
factory. The plant is designed mainly for reducing the content of the heavy metals in the wastewater
and most of them lead. The capacity of the plant is 300 m3/h and the laid content in purified water is
less than 0,1 mg/dm3. The operation of plant is continuous and there is a laboratory for monitoring
and observation of the wastewater parameters.
There is at present an open area depot for temporary storage of the waste laid pastes achieved after the
mechanical filtration of the waste steams resulted from the factory operation. When the waste laid
paste is approximately dried due to the atmospheric conditions it is transported to the nearby laid
processing factory.
Certificates
1. ISO 9001:2000 Design and manufacturing of lead acid batteries
UNDP/GEF Danube Regional Project
104
Company: ELHIM ISKRA JSC
Sector: Electrochemical Industry
Country: BULGARIA
DATA FOR YEAR
BAT emission level
2000
2001
2002
CO2 emissions (tons of CO2 equivalent)2
2 050,0
1 560,0
1 260,0
Emissions
to air
Sulphur dioxides / SOx(tons)
Nitrogen oxides / NOx (tons)
3,40
2,59
2,09
Volatile Organic Compounds / VOC (tons)
Amonia (tons)
Fluorides as fluorine (tons)
PM (mass particle) (tons)
Hydrogen sulfide (tons)
Aquatic Release of Phosphorous Compounds (tons of P)
Aquatic Release of Nitrogen Compounds (tons of N)
Ammonia NH4-N (tons)
Nitrate nitrogen NO3-N (tons)
The quantities presented are based on the
Heavy Metals into water - after purification (kg for
measured content in mg/dm3 of each methal
each metal) 4
in the purified waste water and are less than:
- As
8,0 7,3 7,0
- Cu
1,6 1,5 1,4
- Cr
Discharges
- Cd
1,6 1,5 1,4
to water
- Pb
16,1 11,0 10,5
- Hg
- Ni
1,6 1,5 1,4
- Zn
Total heavy metals (kg)
AOX (kg)
BOD (tons)
TSS (total sulhur) (kg)
Total amount of water consumed (per year) m3
Total amount of water discharged (per year) m3
401 555,0
365 000,0
349 600,0
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DATA FOR YEAR
BAT emission level
2000
2001
2002
Hazardous Waste for Disposal (tons)
1 022,0
794,0
370,0
waste paste with high content of laid (tons)
662,0
304,0
200,0
waste paste with low content of laid (tons)
360,0
490,0
170,0
Waste
Non-hazardous Waste for Disposal ( tons)
cooper ( tons)
4,5
-
1,5
paper and card board (tons)
5,5
11,0
9,0
pieces of iron and steel (tons)
141,0
52,0
78,0
aluminum scrap (tons)
271,0
705,0
762,0
Number of employees
app. 500
app. 500
app. 500
Tons of production (tons)
Reference
Production of certain chemical, fertilizer, specify in (tons)
data
Turnover (millions of )
EMS
ISO 14 001 (preparation/ certified)
NOT YET
Date(year) of plant establishment launching production:
25 12 1960
Email: elhimiskra@mbox.digsys.bg
Name: Executive Manager
Telephone: +359 34 444 548
Telefax: +359 34 443 438
UNDP/GEF Danube Regional Project
106
PETROKEMIJA d.d., Kutina
COMPANY BACKGROUND
Petrokemija, d.d. Fertiliser Company was founded in 1965, although one of its businesses, carbon black
production, dates from as far back as 1926. The headquarters of the company are in Kutina, Aleja
Vukovar 4. The company manufactures fertilisers, clay-based products and carbon black as well as
various other products within secondary productions.
Petrokemija, d.d. delivers high-quality products that meet customer requirements. One of the proofs of
our commitment and also potential for competitiveness in the world market is the ISO 9001/94 Quality
System Certificate awarded for fertilisers and carbon black production.
TECHNOLOGY:
Production of Nitrogen and Phosphate fertiliser.
1. COMPANY IFORMATION:
No. of employees
2 800
Capacity of the factory
1,2 mill tons/year
Annual turnover:
264,5 mill USD
2. PRODUCTS:
Different formulations of fertilisers:
UREA
KAN
NPK
3. CERTIFICATE:
ISO 9001 & ISO 14001
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of nutrients and dangerous substances Appendix 4: BAT Case Studies
Company: PETROKEMIJA d.d., Kutina
Sector: Chemical
Country: Croatia
BAT emission
Data
WB
level
2002
draft
kg/NPK
Nitrogen oxides / NOx (tons)
0,2
0,03kg/ t P2O5
Emissions
Amonia (tons) NH3 as Nitrogen
0,3
<150mg/Nm3
to air
Fluorides as fluorine (tons)
0,02
0,3kg/ t P2O5
PM (mass particle) (tons)
0,3
50 mg/Nm3
Amonia NH4-N (tons)
0,01
Amonia NH4-N (tons)
98,2
0,012
Total heavy metals (kg)
Nitrate nitrogen(NO3-N) (tons)
72,2
0,03
Discharges
Fluoride (tons)
18
0,05
to water
P2O5 (tons)
122,2
0,06
Total amount of water consumed (per
year) m3
11 429 364
Total amount of water discharged (per
year) m3
4 078 863
Hazardous Waste for Disposal (tons)
Waste
Non-hazardous Waste for Disposal ( tons)
Number of employees
2 800
Tons of production (tons)
1 002 465
Production of certain chemical,
Reference
fertiliser.....specify in (tons)
data
264,5 mill
Turnover
USD
EMS
ISO 14 001 (preparation/ certified)
black as well as various other products within secondary productions
Production of Nitrogen and Phosphate fertiliser.
PRODUCTS:
Different formulations of fertilisers:
UREA
KAN
NPK
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DIOKI d.d. , Zagreb
1. COMPANY BACKGROUND
DIOKI d.d. was founded on 17 July 1995 as a merger of INA-OKI of Zagreb, DINA of Omisalj
and INA-Naftaplin's Ethylene Production Unit of Zagreb. OKI - Organic Petrochemical
Company was founded in 1959, and was the first producer of petrochemicals and plastics in the
country. DINA was established as a joint-venture of INA and DowChemicals early in the 1980s.
INA-Naftaplin's Ethylene Production Unit was founded in 1982. Until the end of 1996 the
present DIOKI d.d. (at that time named Polimeri d.o.o.) had been a member of the INA-Group;
then INA transferred it to the State Agency for Deposit Insurance and Bank Rehabilitation
(DAB). In the process of voucher privatization, a 51% stake in the company was transferred to
privatization and investment funds (PIF) on 16 December 1997. Since 20 November 1999, the
company has been operating by the name of DIOKI d.d.
2. TECHNOLOGY:
Production of ethylene from ethane as raw material.
ATO HP polyethylene unit.
DOW HP polyethylene
DOW polystyrene unit
3. COMPANY INFORMATION:
{PRIVATE} million US$
2000
2001
Operating income turnover
145
115
Production in tons
312.737
291.195
Number of employees
1.338 970
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of nutrients and dangerous substances Appendix 4: BAT Case Studies
Production
100
80
60
2000
000/ t
40
2001
20
2002
0
ZG
LDPE
LDPE
OM
PS
EPS
VCM
HI&GP
Ethylene
3. PRODUCTS:
LOW DENSITY POLYETHYLENE
POLYSTYRENE
General Purpose Polystyrene (PS-GP)
High Impact Polystyrene (PS-HI)
Modified Polystyrene
4. CERTIFIED:
ISO 9001 and ISO 14001
UNDP/GEF Danube Regional Project
110
Company: DIOKI d.d. , Zagreb
Sector:
Chemical
industry
Country: Croatia
Data
WB
BAT emission level
2002
draft
Emissions
Sulphur dioxides / SOx(tons)
500mg/Nm3
to air
Nitrogen oxides / NOx (tons)
300mg/Nm3
Hydrogen chloride
10mg/Nm3
PM (mass particle) (tons)
20mg/Nm3
BOD (tons)
30mg/l
COD (tons)
150mg/l
Discharges
to water
Nitrogen (total)
10mg/l
Total heavy metals (kg)
- Cu
0,5mg/l
- Cr
0,1mg/l
- Cd
0,1mg/l
TSS (total sulhur) (kg)
50mg/l
Oil and grease
10mg/l
pH
from 6 to 9
Hazardous Waste for Disposal (tons)
Waste
Non-hazardous Waste for Disposal (
tons)
Reference
Number of employees
970
data
Tons of production (tons)
Energy
Water consumption
Turnover
EMS
ISO 9001 and ISO 14001
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of nutrients and dangerous substances Appendix 4: BAT Case Studies
BELISE d.d. pulp and paper industry
1. COMPANY BACKGROUND
Belise is the biggest pulp and paper factory of packaging paper in Croatia, and one of the
biggest producers in South-East Europe. They produce all types of packaging paper needed
for final production of cardboard.
2. COMPANY INFORMATION
Number of employees: 1 700
CAPACITY: 200 000 tons/year
ANNUAL TURNOVER: 93 430 000 mill $
1.
TYPE
OF
PAPER GRAMM/M2
TESTLINER : BELLINER 1 (BL1)
140
TESTLINER : BELLINER 2 (BL2)
115, 120, 125, 130, 135, 140, 170, 175
TESTLINER : BELLINER 3 (BL3)
125, 135, 175
TESTLINER : BELLINER 4 (BL4)
135
RECIKL. FLUTING : BELWELL (BW)
100, 105, 110, 120, 127, 140, 150, 175
POLUKEM. FLUTING : SC FLUTING (SCF)
112, 120, 127, 140, 150, 175
SRENC
(S)
105,
110,
120
CERTIFIED: ISO 9002
UNDP/GEF Danube Regional Project
112
Company: BELISE d.d. pulp and paper industry
Sector:
Pulp and paper industry
Country: Croatia
DATA FOR YEAR
WB
BAT emission level
2002
BREF
kg/t ADP
kg/Adt
Sulphur dioxides / SOx(tons)
1
0,2 - 0,4
Emissions
Nitrogen oxides / NOx (tons)
1,5 - 2
1,0 - 1,5
to air
Dust
0,2 - 0,5
TRS as S
0,1- 0,2
Aquatic Release of Phosphorous Compounds (tons of P)
0,02 - 0,05
0,01 - 0,03
Discharges
Aquatic Release of Nitrogen Compounds (tons of N)
0,15 - 0,4
0,1 - 0,2
to water
AOX (kg)
0,2 - 2
<0,25
COD (tons)
15 - 35
23
BOD (tons)
0,2 -1,5
TSS (total sulphur) (kg)
0,3-1,5
Total amount of water consumed (per year) m3
Total amount of water discharged (per year) m3
Waste
Hazardous Waste for Disposal (tons)
Non-hazardous Waste for Disposal ( tons)
Number of employees
1 700
Reference
Tons of production (tons)
data
Production of certain chemical, fertiliser.....specify in (tons)
Turnover
93 430 000 mill $
EMS
ISO 14 001 (preparation/ certified)
Belise is the biggest pulp and paper factory of packaging paper in Croatia, and one of the
final production of cardboard
CAPACITY: 200 000 tons/year
TYPE OF PAPER
TESTLINER : BELLINER 1 (BL1)
TESTLINER : BELLINER 2 (BL2)
TESTLINER : BELLINER 3 (BL3)
TESTLINER : BELLINER 4 (BL4)
RECIKL. FLUTING : BELWELL (BW)
POLUKEM. FLUTING : SC FLUTING (SCF)
SRENC (S)
Final Report: Industrial reform and the development of policies and legislation towards the reduction
113
of nutrients and dangerous substances Appendix 4: BAT Case Studies
Company Info:
Name:
ZAHARNI
ZAVODI
AD
Branch:
Food
industry
Address:
5100
Gorna
Oriahovitza
29 Kniaz Boris I Str.
BULGARIA
Production:
The company ZAHARNI ZAVODI AD was established as a sugar
processing factory. Later on different businesses have been added
to achieve high levels of vertical integration. As a result today the
company consists of number of production units, which have
marketing and operational autonomy:
Sugar Production Factory (SPF);
Candy Production Factory (CPF);
Alcohol Production Factory (APF)
Printing & Packaging Materials Production Factory (PPMPF);
Machinery Repair Factory (MRF);
Thermal Power Plant (TPP).
Number employees:
1,360
(31.12.2001)
Turnover:
72,408 000 BGN (2001)
Executive Managers:
Rumen
Ivanov
Telephone:
+ 359 618 4 14 61
Fax:
+ 359 618 4 17 09
E-mail:
zz@matrix-bg.com
UNDP/GEF Danube Regional Project
114
Brief history
Situated in the town of Gorna Oriahovitza nearby Yantra, river (flows into the Danube river)
ZAHARNI ZAVODI AD is the biggest sugar and alcohol production company in Bulgaria.
The enterprise was established in 1913 as a sugar-processing factory. Later on different
businesses have been added to the company to achieve high levels of vertical integration.
Taking an advantage of possibility to use the sugar beet molasses generated during the sugar
processing as an input material for production of pure alcohol in 1922 the Alcohol production
factory (APF) was built. In 1959-60 Sugar production factory (SPF) was renovated, which
lead to increase of the quantity and quality of the final product. At the same time the Thermal
power plant (TPP) was erected and started to supply the different facilities with steam and
electricity. In 1969-70 the machinery repair factory and factory for the packing materials have
been putted into operation and together with the existing ones they formed the current
structure of the company.
As a result today the company consists of the following strategic business units, which have
marketing and operational autonomy:
· Sugar Production Factory (SPF);
· Candy Production Factory (CPF);
· Alcohol Production Factory (APF);
· Printing and Packaging Materials Production Factory (PPMPF);
· Machinery Repair Factory (MRF);
· Thermal Power Plant (TPP).
At present ZAHARNI ZAVODI AD is private enterprise, which has a workforce of 1360 workers and
annual turnover of 72 408 000 BGN.
1. General description of enterprise and its processes
APF is producing pure and technical alcohol by using molasses from the sugar beet as raw material.
There is a possibility also to use for these purposes either the molasses from sugar cane or product
received by hydrolysis of the maize (this product named "Glucoferm 310" is produced in Bulgaria
from Tzaramill factory situated in town of Razgrad). Currently for the production of alcohol a mixture
from molasses and Glucoferm 310 is used.
In order to simplify the description of process is divided into five separate processes:
· Pretreatment of molasses for fermentation;
· Production of yeast, including yeast culture;
· Fermentation of molasses;
· Production of CO2;
· Production of pure alcohol.
1.1 Pretreatment of molasses for fermentation
The main flow of molasses entering the Alcohol Production Factory is divided into two flows. The
first one is diluted with water to 25-27% content of dry solid (D.S.) using either fresh water or water
of Luther (from column 3 and 4) and then is passed to the fermentation tank. The second flow is
diluted with water to 48-50% D.S. and is used for production of yeast.
Final Report: Industrial reform and the development of policies and legislation towards the reduction
115
of nutrients and dangerous substances Appendix 4: BAT Case Studies
1.2. Production of yeast
Solution of molasses with 48-50% D.S. (black line) is treated for 6 hours with mixture of chemicals,
which is prepared in the mixing tank. These chemicals are:
· Sulfuric acid - to maintain pH;
· Urea (nitrogen food);
· Phosphoric acid (phosphorus food);
· Urotropine (disinfection agent);
· Antifoaming agent;
Later on the main solution of molasses is going to sterilization after dilution with water to 10-12%
D.S. Sterilization is done with steam for one hour. The sterilized solution of molasses is passed (after
cooling) to yeast culture machine where is mixed with yeast culture from laboratory and treated with
air. From this process yeast culture is received which is passed to yeast culture generator where is
mixed with solution of molasses (11-12% D.S.) for producing mature yeast (also with air treatment).
1.3. Fermentation
The process of fermentation is done in the fermentation tank periodically where the main molasses
stream (containing 25-27% D.S.) and the mature yeast are put. This process is exothermic and lasts
between 24-48 h. During this period of time the fermentation tank is cooled with water. After the
fermentation of molasses is over, the main product is received called beer alcohol with 8-10% content
of C2H5OH. The by-product received during the fermentation is carbon dioxide (CO2).
1.4 Production of carbon dioxide CO2
As known CO2 is a by-product generated during the fermentation of the molasses. Its production
consists of two major steps: purification of the CO2 (gas) and production of CO2 (liquid). These steps
include several consecutive procedures:
· Removal of the alcohol drops;
· Washing with the sodium carbonate;
· Washing with water;
· Compression (two stages);
· Filtration through activated carbon;
· Compression (third stage);
· Filtration through silica gel;
· Liquifation in freezing installation;
· Storage in bottles;
1.5. Production of pure alcohol
The production of pure alcohol consists of four steps using well-known technology of consecutive
distillation and rectification with four columns. The processes in these columns can be briefed as
follows:
Column 1 is used for distillation of beer alcohol: two products being received: crude alcohol (38-40%
C2H5OH) and non-alcoholic liquid called slop.
Column 2 is used for the epuration of crude alcohol; two products being received: ester aldehyds
fraction and pure alcohol (36-38% C2H5OH);
Column 3 is used for production of the final product pure alcohol (96%) by rectification of pure
alcohol (36-38% C2H5OH) from column 2. By-products here is so-called water of Luther, heavy
alcohol fraction and fusel fraction;
UNDP/GEF Danube Regional Project
116
Column 4 is used for rectification of the mixture from ester/aldehyds fraction (from column 2), fusel
fraction and heavy alcohols fraction (from column 3) Main product here is technical alcohol and by-
product fusel oil and water of Luther.
Almost all waste streams from this factory is liquid. These waste streams can be divided into three
principal flows:
· Waste water flow (wwf) - it is a water used either for cooling of heat exchangers (for instance for
reflux) or for washing of the single apparatuses;
· Slop water flow it is nonalcoholic residual water, received in column 1 and discharged in Yantra
river;
· Water of Luther it is non-alcoholic residual water received in column 3 and 4
Some small quantity of waste can also be mentioned as exhausted Na2CO3 solution, or exhausted
activated carbon, or silica gel, but this waste do not interfere with the environment.
2. Energy facilities
Heat and power are produced in the existing Thermal Power Plant (TPP), specially designed to cover
the needs of production facilities of ZAHARNI ZAVODI AD. TPP was built in 1960 and its main
equipment consists of:
· 2 steam boilers, producing superheated steam with capacity 2 x 75 t/h;
· 1 steam boiler, producing superheated steam with capacity 1 x 35 t/h;
· 1 steam boiler, producing saturated steam with capacity 1 x 12 t/h;
· 2 back pressure turbines with electrical capacity 6 MW each.
Electricity production covers the own needs of ZAHARNI ZAVODI AD as the rest of the production
(when it is available) is sold to the Regional Electricity Distribution Company (REDC). Coal, type G
from Ukraine is used as a main fuel and a heavy fuel oil with high sulfur content is used as additional
fuel.
3. Sources of pollution and inefficiency
3.1. The principal source of environmental pollution from APF to Yantra river water is the distillery
residue from distillation column called slop (or slop water flow). The slop is nonalcoholic dark brown
liquid with temperature 100-103°C and with high content of organic matter. The main data for the slop
obtained from sugar beet molasses is given in the table 1 as follows:
Table.1. Slop data
No
Slop from sugar beet molasses
unit
Values (approx)
1
Dry solid (D.S.)
%
6-8
2
pH
4.5 5.5
3
BOD5 (as oxygen demand)
mgO2/l 30
000
4
COD (as oxygen demand)
mgO2/l 65
000
5
Soluble matters (dissolved solids),
mg/l
70 000
6
Non soluble matters (suspended solids)
mg/l
10 000
"The output" of this waste liquid product received by on-site measurement (January 2003) was 19 000
l/h. Samples from slop (slop water flow) during the trials were examined and COD of the slop for a
single day obtained was 56000 mg/l (as oxygen demand). These data are reliable and confirm the
decision of enterprise to look for a solution to eliminate this detrimental flow to Yantra river.
Final Report: Industrial reform and the development of policies and legislation towards the reduction
117
of nutrients and dangerous substances Appendix 4: BAT Case Studies
In order to demonstrate the characteristics of overall unit effluents to the Yantra river, an extraction
from Analysis Report (for two days) is given on fig.1. As seen from fig. 1 due to the dilution of the
slop (and the water of Luther) from the APF (see table 1) BOD5 and COD of the final effluent
discharge in Yantra river are decreased. Nevertheless this wastewater does not meet the regulations
listing in Bulgarian State Standards. It means that industrial wastewater from APF could not be
discharged at Yantra river due to its composition; the main source being the flow of slop from
distillation/rectification system.
Extract
Ministry of Environment and Water
Republic of Bulgaria
Analysis Report
No240 / 17.04.2002 and No290 / 20.05.2002
Subject:
Analysis of waste water from "Sugar Production
Company", Gorna Oriahovitza (discharged point of
Yantra river)
No Physical/Chemical Unit Protocol Protocol
In accordance with
indicator
No 290
No 240
Regulation No7/86
II cat.
III cat.
1 pH
7.54
6.28
6-8.5
6-9
2 Oxygen
dissolved
mg/l
2.92
1.11
4
2
3 Saturated
with
Oxygen
%
33.3
12.1
40
20
4
Conductivity
S/cm
no data
no data
1300
1600
5
BOD
mg/l 170 2060 15 25
5
6 COD
mg/l
558
4526
70
100
7 Soluble
matters
mg/l
798
4586
1000 1500
8 Non
soluble
matters
mg/l
114
418
50
100
9 Hydrogen
sulfide
mg/l
-
0.18
no
O.1
10 Sulfides
mg/l
-
2.48
Fig.1
3.2. Slop water flow is a major source of waste high potential heat energy; its temperature being 103
°C. As can be seen from the detailed material and energy balances the loss of heat energy due to slop
water flow is 1 950 000 kcal/h (data received by on-site measurement).
3.3. Water of Luther is another source of waste heat energy. The energy balances made shown that the
loss of heat energy with water of Luther from both rectification and fusel columns is 769 690 + 63 013
= 832 703 kcal/h. With temperature 104 °C this water flow has a high thermal potential and in winter
time is used for heating of molasses. It means that a problem for recuperation of this waste heat exists
only in summer time.
3.4. Cooling water flows from heat exchangers in pure alcohol production section are significant
sources of waste heat energy and wastewater.
UNDP/GEF Danube Regional Project
118
The losses of high-potential waste heat energy from cooling water flows can be briefed as follow:
· epuration column
113 528 kcal/h;
· rectification column
1 710 436 kcal/h.
Total heat energy losses
= 1 823 964 kcal/h
The losses of cooling water flows are:
· separator
43
200
l/h;
· distillation column
65 818 l/h;
· epuration column
4 193, 8 l/h;
· rectification column
46 228 l/h;
· fusel column
21 225 l/h.
___________________________________________________________________________
Total losses of cooling water 180 664 l/h
3.5. According to on-site measurements done by CP team the following data can be given concerning
specific input and output of incoming energy (steam), outgoing waste energy (hot water) and outgoing
waste water (to 1000 l alcohol).
· outgoing waste cooling water (from all units)
112 774 l/1000 l;
· incoming
steam
6
242
kg/1000
l;
· outgoing waste heat energy (with cooling water)
1 138 554,3 kcal/1000 l;
· outgoing waste heat energy (with slop water)
1 217 228,5 kcal/1000 l;
· outgoing waste heat energy (with water of Luther)
519 789,6 kcal/1000 l.
As a conclusion, a detail analysis of material, energy and water cooling balances of alcohol production
section of APF discloses the major sources of pollution: (1) (slop water flow, water of Luther, (2) the
major losses of heat energy with waste liquid flows (slop water flow, water of Luther, cooling water
flow etc.) and (3) the major losses of water with waste water flows (cooling water).
4. Proposals for reconstruction and modernisation (Environmentally
Sound Technology option - EST)
Decision for reconstruction and modernisation of APF was done based on the detailed analysis of
material energy and water flows as well as taking into account the existing sources of pollution and
inefficiencies within the factory. The selected option was formulated as "Change of raw material in
conjunction with the change of technology" and its implementation consists of following activities:
· Delivery of cereals (wheat or corn);
· Storage of cereals;
· Wet milling of cereals;
· Hydrolysis of starch to glucose (by enzymes);
· Reconstruction of yeast production unit from periodic to continuous one;
· Reconstruction of the fermentation unit from periodic to "continuous" one;
· Reconstruction of distillation/rectification section, including reconstruction of columns for
distillation, purification and rectification with implementation of indirect steam for heating;
· Replacement of the fusel column with another column (for final purification) and appropriate
change of the material flow pipelines;
· Building of the new installation for the treatment of the slop water flow, including
centrifugation, multi-effect distillation (MED) and drying the solid residue to fodder;
· Reconstruction of whole steam pipelines following the principle that the steam from TPP is to
be used as primary steam in (MED) and the steam from evaporation of slop water flow would
be used to heat distillation/rectification columns;
· Reconstruction of water cooling system from once through to recirculation one.
Final Report: Industrial reform and the development of policies and legislation towards the reduction
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of nutrients and dangerous substances Appendix 4: BAT Case Studies
If this EST option would be implemented in APF the major problems would be resolved namely:
· The impact of the slop water flow for Yantra river pollution would be decreased to zero;
· Total heat energy losses would be decreased as the enthalpy of the slop water and the water of
Luther would be used in MED installation;
· Total discharge of cooling water would be decreased dramatically as in the future the
discharge water from APF would be only the blow down water from the cooling recirculatiing
system.
As seen from the above mentioned, the reconstruction of APF Gorna Oriahovitza is a complicated
and long-term process. The strategy of the factory owners is to divide this process into three
consecutive stages, as follows:
1. During the first stage, the raw materials (e.g. molasses) do not change. This stage includes:
· Reconstruction of the fermentation unit from periodic to continuous one. This provides
possibility to operate with two raw materials molasses or cereals. When molasses is used,
the process would be really continuous. When cereals are used, the process would be, as
mentioned above, "continuous" one.
· Reconstruction of the yeast generation unit.
· Reconstruction of DC/RC columns (internal).
· Implementation of indirect heating of the columns, when necessary.
· Installing a new column for final purification of ethanol (FPC).
· Reconstruction of all pipe-lines for products, steam, and water flows.
· Construction of recirculating cooling system (RCS).
2. The second stage includes all actions related to the change of the raw material from molasses to
cereals. These actions are:
· Construction of compartment for delivery, separation, and storage of cereals;
· Construction of compartment for wet milling of cereals;
· Installation of the all necessary equipment for enzymatic hydrolysis of starch to glucose,
including heat exchangers, reactor vessels, pump, mixing devices, etc.
3. The third stage is installing of slop water treatment unit. This step would significantly reduce the
environmental impact. This stage includes:
· Centrifugation of the slop water from DC.
· Evaporation of this water in MED units and receiving a concentrate with great content of dry
solids.
· Mixing of the concentrate with solid residue from centrifugation, drying the product received
in the drying cylinder, and producing a fodder.
· Storage and sale of fodder.
Estimated investment needed for reconstruction and modernisation of APF are estimated as follows:
First Stage
1,468,869 USD
Second Stage
969,493
USD
Third Stage
2,590,362 USD
Supplementary costs
992,457
USD
TOTAL COSTS (prices of 2003)
6,021,181 USD
UNDP/GEF Danube Regional Project
120
Company: ZAHARNI ZAVODI AD - Alcohol Production Factory (APF)
Sector: Food Industry
Country: BULGARIA
DATA FOR YEAR
BAT emission level
2000
2001
2002
CO2 emissions (tons of CO2 equivalent)2
76 589,0
72 040,0
96 933,0
Sulphur dioxides / SOx(tons)
1899,8
1776,8
2406,7
Nitrogen oxides / NO
Emissions
x (tons)
336,7
310,9
427,4
to air
Volatile Organic Compounds / VOC (tons)
Ammonia (tons)
Fluorides as fluorine (tons)
PM (mass particle) (tons)
Hydrogen sulfide (tons)
Aquatic Release of Phosphorous Compounds (tons of P)
Aquatic Release of Nitrogen Compounds (tons of N)
Ammonia NH4-N (tons)
Nitrate nitrogen NO3-N (tons)
Heavy Metals into water - after purification (kg for each
The quantities presented are based on the operation
metal) 4
of coal fired boilers in TPP of ZAHARNI ZAVODI AD
- As
- Cu
- Cr
- Cd
0,08 0,07 0,10
Discharges
- Pb
4,93 4,47 6,27
to water
- Hg
1,39 1,26 1,72
- Ni
- Zn
Total heavy metals (kg)
6,40 5,80 8,09
AOX (kg)
BOD (tons)
2 519,0
3 733,0
2 963,0
COD - from Slop and water of Luther (tons)
5 057,0
7 491,0
5 846,0
TSS (total sulphur) (kg)
Total amount of water consumed (per year) m3
Total amount of water discharged (per year) m3
948 139,0 1 404 560,0
1 114 781,0
slop water m3
83 986,0
124 427,0
98 756,0
water of Luther m3
35 298,0
52 162,0
41 400,0
cooling water m3
828 855,0 1 227 971,0
974 625,0
Final Report: Industrial reform and the development of policies and legislation towards the reduction
121
of nutrients and dangerous substances Appendix 4: BAT Case Studies
DATA FOR YEAR
BAT emission level
2000
2001
2002
Hazardous Waste for Disposal (tons)
Waste
Non-hazardous Waste for Disposal ( tons)
Number of employees
Tons of production - alcohol (tons)
7 335,0
10 867,0
8 625,0
Production of certain chemical, fertilizer.....specify in
Reference
(tons)
data
Turnover (millions of ) only of APF
4 473,0
6 959,0
4 535,0
EMS
ISO 14 001 (preparation/ certified)
Date(year) of plant establishment launching production:
1913
Email: zz@matrix-bg.com
Name: Rumen Ivanov
Telephone
: + 359 618 4 14 61
Telefax: + 359 618 4 17 09
Final Report: Industrial reform and the development of policies and legislation towards the reduction
123
of nutrients and dangerous substances Appendix 5: Mechanisms of data collection questionnaire summary
Appendix 5: Mechanism of data collection questionnaire summary
Annex 5: Monitoring of industrial polluters
Country Self-monitoring
of
National/regional
Monitored data on
Authorizatio Monitored
Availability of monitored data
Name of responsible
industrial polluters
monitoring of industrial
industrial emissions n of labs
parameters
institution responsible
required
polluters required
collected and
required
harmonized with the
for reporting to ICPDR
processed
EU DS Directive
Yes
no
Only
Yes no Only
centrall regio no yes no Yes
no
public Upon
request No-
specific
specific
y
nally
and prior
public
polluters
polluters
approval
R. Srpska (part ·
·
·
of FBiH)
·
·
·
Not in place
BiH (part of
·
·
· ·
·
·
Not in place, several
FBiH)
institutions designated
Bulgaria
Croatia
·
·
·
·
·
·
State Water
Directorate and
Croatian Waters
Czech Republic ·
·
·
·
·
·
Water Research
Institute
Hungary
· by ·
·
·
· ·
·
·
Ministry of
Environment and
2005
Water
Moldova
Romania
·
·
·
· ·
·
·
Romania Waters
Serbia -
Montenegro
Slovakia
·
·
·
·
·
·
Ministry of
Environment
Slovenia
Ukraine