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Environmental Fund for Lebanon Legal and Technical Frameworks for Environmental Compliance in...
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Transcript of Environmental Fund for Lebanon Legal and Technical Frameworks for Environmental Compliance in...
Environmental Fund for Lebanon
Legal and Technical Frameworks for Environmental Compliance in Lebanon
17 June 2011Monroe Hotel - Beirut
Most industries are small or medium sized
More than 90% employ <10 people (MoI, 2000)
Workforce of 114,000 people
Until April 2001, 3 classes of industrial establishments depending on degree of environmental threat (decree 4917)
At present amended to 5 industrial classes (class 1 serious, 2 significant, 3 limited, 4 insignificant, 5 no risk) (decree 5243)
Large number of not permitted but existing facilities
Industries in Lebanon
Uncontrolled dumping of industrial solid waste
Lack of industrial effluent treatment facilities
Uncontrolled emissions into the atmosphere
Heavy consumption of water
Occupational health related problems
High production costs
Environmental Problems and Challenges
Decree 8735 (1974) Prevent discharge of wastewater from industries within waterways and beachesEnforce industrial establishments to treat their wastewater before discharge
Decision 52/1 (1996) Standards for bathing water including sea, rivers and lakes and standards on WW quality
Decision 8/1 (2001) Standards for effluent discharge into the sea, surface water and sewers
Decree 5243 (2001) Classification of establishments into 5 categories
Law 444 (2002) Principles of Precaution (cleaner production), Prevention (best available technologies), polluters pay (for pollution prevention and control), prevention of natural resource degradation, environmental monitoring (pollution sources and pollution abatement), Economic incentives to encourage compliance
Legal Framework for Industrial Compliance (1)
Decree 8018 (2002) Classification of industrial establishmentsLicensing of new industrial establishments
Law 690 (2005) Set environmental conditions to license the establishment or investment in all classified establishments of all categories (including industrial and non industrial)Set environmental conditions to protect the marine coastline, rivers, springs, lakes, etc.
Decree 2275 (2009) Setting environmental conditions in license applicationsIdentification of classified establishments that require an environmental permit to discharge effluents before implementationIdentification of a procedure to license the discharge of effluents
Decision 75/1 (2000) Environmental conditions for the establishment of tanneriesManagement of industrial effluentsTreatment of effluents
Legal Framework for Industrial Compliance (2)
Classified establishments are required to apply for Environmental Compliance Certification (to be renewed every 3 years) from MOE following the proof that they are complying with environmental regulations and are applying an effective Environmental Management Plan.
The Certificate will allow the holder to benefit from the incentives stipulated in Law 444 and Law 690/2005
Proposed Environmental Compliance Decree for Classified Establishments
Categories– Existing Industrial Establishments, operating but not licensed– Existing Industrial establishments, operating, and having a construction
permit (w/o operation permit)– Existing Industrial establishments, operating, and having an operation permit
Procedures– Prepare a detailed Environmental Audit and submit to MOE– Implement the Environmental Management Plan indicated in the Audit
Report– Apply for Certification from MOE– Correct the legal status of the establishment and get the needed permits– MOE to respond accordingly and inform MOI and MOIM– MOE to publish the list of Environmentally Compliant Establishments
How to apply for a Compliance Certificate
Classified establishments are required to:– renew their compliance certificate before expiry (3 years)– Prepare a Self Monitoring Report and submit to MOE
• Self Monitoring report is a simple version of the Environmental Audit
MOE reviews the Self Monitoring Report and renew/cancel the environmental performance certificate
MOE to prepare a register for environmentally compliant establishments
Penalties in case of defects/Failure to comply
Renewal of Compliance Certificates
Direct/Indirect Enforcement measures
Better Environmental Performance/Compliance
Incentives & Enforcement Measures are used in parallel to help industries
achieve compliance
Direct/Indirect Incentives
•Financing Audits and studies•Accelerated depreciations•Reduction of taxable income•Tax credits
The Environmental Audit is a documented, periodic and objective process which assesses a facility operation with respect to the environment as well as health and safety.
It is the first step in an ongoing programme, which entails documentation, implementation, and continuous follow up of the Action Plan resulting from the Audit to optimize resource use and improve process performance.
What is an Environmental Audit?
The Audit Manual covers the following issues entirely through a series of checklists:
– Environmental management practices– Production processes used– Water consumption– Wastewater management– Air quality and gaseous emissions– Solid waste management– Noise pollution– Energy consumption– Occupational health and safety
Environmental Auditing Manual
Assessment of compliance with government legislation, regulations, and permit conditions
Assessment to adherence to internal policy and procedures
Assessment of the status of current practice
Identification of efficiency potentials and areas for improvement to minimize the impact on the environment
Objectives of the Environmental Audit
Promoting good environmental management
Ensuring cost effective compliance with laws, regulations, standards and company policy
Improving employee productivity, awareness and safety at work
Reducing operating costs
Incorporating the environmental dimension in a facility’s operation
Triggering new priorities in policies and practices
Improving the image of the facility and enhancing competitiveness
Benefits of Environmental Auditing
1: Pre Audit• To make the necessary preparations and arrangements for the on site audit
2: On Site Audit• To assess compliance with government legislation, regulations and permit
conditions• To assess adherence to internal policy and procedures• To identify areas of improvement to minimize the impact on the
environment
3: Post Audit• To produce an audit report that includes the findings and
recommendations• To promote the development of an Action plan for the continual
improvement of operations• To develop/adjust the environmental management system
Environmental Audit Procedure
Setting objectives and scope
Forming and organizing the audit team
Overview of the type of the facility
Visiting the top management
Conducting detailed background research
Tailoring the pre-audit questionnaire
Tailoring for checklists
Assigning tasks, responsibilities and timetable
Step 1: Pre-Audit/Audit Planning and Preparation
Introductory meeting with staff
Assessing the legal status and environmental management
Detailed on site inspection– Production Process– Water Supply– Wastewater Management– Air Emissions– Solid Waste Management– Noise pollution– Energy consumption– Occupational Health and Safety
Data Analysis
Concluding meeting
Step 2: On Site Audit
Focuses on final stages of the audit and covers the following issues:
Audit Report• Introduction• Site description• Results / findings and recommendations
Action Plan• Compliance strategy• Areas for further investigation• Blueprints for environmental auditing program• Blueprints for an environmental awareness and training program• Development of indicators• Blueprints for progress monitoring program• Time frame for implementation
Step 3: Post Audit
Self Monitoring report Annual consumption of fuel, types and associated costs
Air pollutants: Is there any abatement measures for air pollution, precise it, Are all air pollutants compliant with decision 8/1, send reports of air pollution analysis
Water consumption: Quantity consumed, surface water consumption, groundwater consumption, what are the measures to limit water consumption?
Wastewater treatment: Quantity treated, what are the method of final disposal of industrial waste, other wastewater (in sewers, on soil, underground, surface water, evaporation ponds, other). Are industrial effluents compliant with national standards? Provide analysis results.
Solid and Hazardous waste: Provide data regarding hazardous waste, solid waste, packaging waste, other (source of production, quantity generated, storage location, mode of transport to storage, final disposal site)
Other: are all criteria indicated in the operation permit followed?
PASSIVEIgnore pollution
REACTIVEDilution and dispersion
PROACTIVECleaner Production
Responses of Businesses to Pollution
CONSTRUCTIVEEnd-of-pipe treatment
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Responses to Industrial Pollution Implementation of Cleaner Production measures to
reduce the quantity and quality of the generated wastewater Good housekeeping Input substitution with less toxic materials or renewable materials Better process control Equipment modification Technology change On site recovery/re-use Production of useful by-products Product modifications
Pre-treatment of industrial wastewater to meet Environmental Limit Values for discharge into sewers set by the MOE (Decision 8/1)
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Priority Industrial SectorsSector Subsector
Food Products and Beverages
Production, processing and preserving of meat
Manufacturing of vegetable and animal oils and fats
Manufacturing of dairy products
Manufacturing of alcoholic products and beverages
Chemical Manufacture of paints and printing inks
Metals Treatment and coating of metals (Electroplating)
Annual quantity of meat products is 7,900 tons
The wastewater generated is 300 m3/d (mainly from washing and cleaning operations)
Discharged directly into surface waters
Wastewater characterized by high COD (3500 mg/l), BOD (1500 mg/l) and oil and grease (500 mg/l)
Got three offers from three suppliers (Aqua, Redox and Metito) to treat wastewater to levels that can be used for irrigation
Estimated treatment cost = 505,550 euro
WILCO: Poultry and Meat Processing
Step 1:– Proper sieving: to remove suspended solids greater than 1,5 mm - 2,5 mm– Sand traps: to prevent any clogging in the process – Equalization tank for pH adjustment.
Step 2:– Precipitation and / or flocculation followed by flotation: For removal of suspended
solids, fat, and grease
Step 3:– Aerobic Biological treatment for the removal of BOD, COD, Ammonia and nitrogen
followed by sedimentation and sludge dewatering
Proposed Effluent Treatment at WILCO
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Societe pour l’Industrie des Metaux (SIDEM)
Located in Zouk Mosbeh
Annual production of 12,000 to 13,000 t of mill finish, anodized and powder coated aluminum profiles
Two main effluent streams:
1- Wastewater from the electroplating process
is being treated on site to reduce CrVI to CrIII in a chemical physical treatment unit present on site
Sludge is being disposed of in coordination with Holcim
2- Wastewater from the anodizing line (around 1000 m3/d)
Wastewater from the anodizing of Al profiles (degreasing, etching, electrolytic anodization using H2SO4 and NaOH, and DC current) is highly acidic and is disposed of in the sewerage network of Zouk Mosbeh industrial zone
Wastewater is characterized by low pH (pH=4.47), High TSS (TSS=1,749 mg/l) and high Sulphates (1,040 mg/l)
Cooperation with Veolia to propose an offer for effluent treatment from the anodizing line to reach MOE standards
Anodizing Effluents
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Proposed Pre-treatment at SIDEM Build, equip and install a new chemical physical treatment
unit consisting of:
Equalization and storage tanks: to dilute and homogenize acidic and basic solutions and for proper mixing
Neutralization, flocculation and decantation to remove the acidity and reduce TSS, sulphates and precipitate the metals
Sludge dewatering by means of a filter press to facilitate co-processing at the cement factories
The cost for this pre-treatment unit is 754,000 euros.
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PULPER (Slim Oil) Located in Nahr Ibrahim
Process involves mechanical pressing, extracting and refining of crude sunflower oil
Annual production of 8,000 tons of sunflower vegetable oil
Discharge 150 m3/d of wastewater into the surrounding environment
Wastewater is characterized by very high levels of COD (125,000 mg/l), oil and grease (331,000 mg/l) and can be separated from the other effluents from the deodorizer
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Cleaner Production in PULPER Harburg, the company who installed and commissioned the
plant was consulted to propose a solution
Recommendations:
Either treating the wastewater through a chemical physical treatment followed by flotation to remove the oil & grease
Or doing some process modifications to reduce the pollution in the area (complete reduction of water consumption and minimization of odors) by improving the production and implementing a close water cooling circuit system.
Closed water circuit cooling (mainly through heat exchanger) at the vacuum system
Production efficiency improvement (mainly through a horizontal filter) at the Combined Degumming and Winterization Plant
Installation of a self cleaning chemical system for the deodorizer to control odors in the water
Refinery control extension and upgrade
The cost of this intervention is around 446,500 euros
Proposed Process Modifications in PULPER