this project is funded by the european union projekat finansira evropska unija project implemented...

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This project is funded by the European Union Projekat finansira Evropska Unija Project implemented by Human Dynamics Consortium Projekat realizuje Human Dynamics Consortium LAW ENFORCEMENT IN THE FIELD OF INDUSTRIAL POLLUTION CONTROL, PREVENTION OF CHEMICAL ACCIDENT S AND EST A BLISHING THE EMAS SYSTEM EUROPEAID/131555/C/SER/RS SRB EUROPEAID/131555/C/SER/RS

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This project is funded by the European Union

Projekat finansira Evropska Unija

Project implemented by Human Dynamics Consortium

Projekat realizuje Human Dynamics Consortium

LAW

ENFO

RCEMENT

IN T

HE FIE

LD O

F IN

DUSTRIA

L

POLL

UTION C

ONTROL,

PREVENTI

ON OF

CHEMIC

AL

ACCIDENTS

AND E

STABLIS

HING T

HE EMAS

SYSTE

M

EUROPEAID

/131555/C

/SER

/RS

SRB

EUROPEAID

/131555/C

/SER

/RS

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

1. SASTANAK ODBORA ZA PRAĆENJE PROJEKTA

1st PROJECT STEERING COMMITTEE MEETING Belgrade, 17th December 2012

Beograd, 17th December 2012

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

AGENDA

1st Steering Committee Meeting

Chair: Mr. Hranislav Stojkovic, Assistant Minister, Ministry of Energy Development and Environmental Protection

10.00 -10.05

Opening and welcome Hranislav Stojkovic

Assistant Minister

10.00 -10.10

Adoption of the agenda Hranislav Stojkovic

Assistant Minister

10.10 - 10.20

Adoption of SCM procedures Hranislav Stojkovic

Assistant Minister

10.20 – 10.30

MERZ IPPC Department introduction and expectations to the Project

Nada LukacevicHead of Department for

Integrated permits

10.30 – 10.40

MERZ Seveso Department

introduction and expectations to the Project

Blagica Budimir Head of Department for Chemical Accidents

10.40 – 10.50

MERZ EMAS Department

introduction and expectations to the Project

Rade OstojicHead of Department for Standards and Cleaner

production

10.50 – 11.20

Presentation of the Inception Report

Hans Lauritzen Team Leader

11.20 – 11.50

Discussion all

11.50 – 12.00

Adoption of the report all

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Presentation of Inception Report

Introduction

Inception Activities

Update on Background

Assumptions and Risks

Overall Work Plan(General)

Work Plan for the next period (Detail)

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

IntroductionContract No. 2012/295-223

Contractor: The Delegation of the European Union to the Republic of SerbiaVladimira Popovica Street 40, 5th floor (GTC Avenue building, block

19a), 11070 Belgrade, Republic of Serbia

Beneficiary: Ministry of Energy, Development and Environmental ProtectionOmladinskih brigada 1, 11070 Belgrade, Republic of Serbia

Consultant: Hulla & Co. Human Dynamics KGLothringerstrasse 16, A-1030 Vienna, Austria

Project Team: Project OfficeOmladinskih brigada 1, 1st floor, Office No. 130, 11070 Belgrade,

Republic of Serbia

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

SYNOPSISStarting Date : 02 September

2012

Closure: 01 September 2014

Value: €

Main Beneficiary:

Republic of Serbia,

Ministry of Energy, Development and Environment Protection;

Other Beneficiaries:Ministry of Agriculture, Forestry and Water

Management

Ministry of Interior

Ministry of Labour and Social Policy

AP Vojvodina

Municipalities within the Project area

Accreditation Board of Serbia

Chamber of Commerce of Serbia

Početak projekta: 02. septembar 2012

Završetak: 01. septembar 2014

Vrednost: €

Glavni Korisnici projekta:

Republika Srbija,

Ministarstvo …….;

Ostali Korisnici:

Ministarstvo

O PROJEKU

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Ruza Radovic Project Manager

Hans Lauritzen Team Leader

Riccardo Quaggiato IPPC Expert

George Mouzakis Seveso Expert

Milka Tesevic Project Logistic Manager

Project Team:

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Project Objective:

Assist the Ministry of Energy, Development and Environmental Protection in the process of implementation of the environmental legislation on IPPC, Seveso II Directive and the Eco-Management and Audit Scheme (EMAS)

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Project Purpose:

Build and enhance capacity for enforcement of regulations aligned with the EU Environmental Directives, specifically for Industrial Prevention and Control (IPPC), prevention of chemical accidents and the EMAS

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Inception activities - 1

Mobilization of experts (3 September 2012)

Setting up project office and recruitment of support staff

Meeting with key stake holders and review of documentation

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Inception activities - 2

Setting up Project Steering Committee and first meetingInception meetings with LSG’s in Belgrade and Novi Sad with attendance of 24 LGSProject Environment AnalysisAction PlanningPreparation of Tor for Non-key expertsPreparation of draft Inception ReportBased on comments a final

version will be submitted for official approval

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Working GroupsTo strengthen network of stakeholders involved in IPPC/IED, Seveso and EMAS implementation it is proposed to establish:

WG1 - Procedures development

WG2 - Technical Group for IPPC/IED implementation

WG3 - Permanent IPPC/IED network

WG4 - Seveso Contact Group

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Update on BackgroundCurrent Government priorities full

implementation of the environmental legislation

EU progress report:

Integrated approach to permitting must be institutionalized and the administrative capacity strengthened

Risk management groups administrative capacity remains to be improved

Government decision: Merge energy and environmental protection issues into Ministry of Energy, Development and Environmental Protection

Decisional levels has been changed. New systematization of sectors and departments is expected

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

IPPC/ IED:

• Current situation: 161 operators under IPPC, 96 applications submitted

• Light modifications made in light of on-going project:

Training activities have been anticipated to fit better Dynamic Program and better support operators and permit writers in the initial phase of permitting;

Details on criteria and methodology adopted to implement operative activities have been set up;

Goals, composition, frequency of meetings and activities of workgroups have been set, foreseeing 2 technical groups (for procedures and technical documents) and a Permanent network for IPPC/IED, involving MERZ, Province of Vojvodina and LSGs.

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Accommodating for the new extended legislative framework introduced by IED and in the context of industrial policy and the need for integrated permitting taking into account other sectoral permitting and supervisory obligations, e.g. under Waste Directive, EIA etc.

Strengthening the institutional structure for integrated permitting of installations, including the enforcement regime;

Establishment of technical standards for BAT and determining ELV;

Further development of legislative changes related to monitoring compliance with permitting conditions, periodic review of permits and inspections.

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Seveso:

105 notification studies (59 lower tier and 46 upper tier) have been submitted

37 safety reports have been submitted. 3 safety reports have been evaluated.

Focus will be given to:

Absence of technical procedures – guidelines for the compiling (operator’s side) and evaluating (authority’s side) of a Safety Report. Training courses are needed to representatives of institutions and industries to compile and evaluate the Safety Reports;

Guidelines for the drawing up external emergency plans are needed to be adopted;

Inspections to the to all upper and lower tier hazardous establishments;

Information to the neighbour to the hazardous establishments people regarding the existing hazards and what to do in case of emergency;

Adoption of critical emergency protection zones. By this way all the stakeholders will know how the consequences of an accident scenario will be estimated, presented and evaluated;

Adoption of risk acceptance criteria. It should be essential if an activity is acceptable or not, in a specified place. It should be very useful for all the stakeholders. The operator will know in advance if the risk of a scheduled project is acceptable or not. The authorities will establish a Land Use Planning Policy, and they should know the accepted or not risk for any kind of proposed project or activity;

Adoption of a Land Use Planning policy regarding the major hazard establishments

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

EMAS:

Until now no organisations in Serbia have applied for EMAS and it is unknown whether any organisation intends to do so. The Project will attempt to identify potential candidates for EMAS registration, support them to prepare for it and assist in developing the environmental verification structures.

Verification of the Environmental Statement under EMAS takes place by a third party, The verifier. Verifiers are either individuals or organisations who are accredited by Accreditation Board of Serbia (ATS).

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Assumptions and Risks

Change of government following the 2012 general elections

Medium risk Medium impact

The elections held in May 2012 have led to the changes in the administrative structures. Main project beneficiary MEMSP has been replaced with the merged Ministry of Energy, Development and Environmental Protection. In addition, upon the elections, Serbian Chemicals Agency and Environmental Protection Fund has been closed. This has caused changes in the administrative structures and systematisation within the MERZ and other stakeholders that at the time of drafting of this report has not been completed; hence the affect of these changes on the project activities has not been fully assessed. However, since the project has just started, the project team will invest efforts to adjust implementation modalities to the changed project environment.

Serbian government

Affecting Result 1 – LEGAL ASPECTS Inadequate or inconsistent available human or material resources within the main beneficiary institutions

Low risk Low impact

Although there is always room for increase of human or material resources, the experience of the project team gained during the inception phase shows that beneficiary staff is fully available and committed to cooperation with the project team and that this will not pose the risk for achievement of results. To achieve the best possible results the Consultant will maintain close interaction with beneficiary staff.

MERZ, MAFWM, MoI

Change of staff, turnover of staff or transfer of staff during project implementation

Medium risk Medium impact

Changes in the staffing in the Beneficiary institutions have been initiated after the elections held in May 2012 and this process has not been finalised yet, pending the finalisation of new systematisation. Since this is happening at the beginning of the project, the impact is reduced, however if this continues to be the risk during implementation, the project team will provide for transparent and well documented project activities, in line with visibility guidelines, which will enable the hands on information on the project.

Consultant, MERZ

Lack of commitment by other institutions regarding project involvement, input and training

Low risk Medium impact

The relevant institutions have been visited during the Inception Phase, and are included in the list of PSC members. The general impression is that there is sufficient commitment to participation in the project activities.

MAFWM, MoI

Affecting Result 2 – CAPACITY BUILDING Inadequate or inconsistent buy-in, goodwill and commitment at top level

High risk Medium impact

The political and administrative changes led to the inadequate commitment of the top level management of MERZ during the Inception phase. Project team invested necessary efforts to inform and involve management in the project activities, however without achieving desired results.

MERZ, MAFWM, MoI, MLSP, AP Vojvodina

OVERALL

WORK P

LAN (G

ENER

AL)

SRB

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Component 1:

Assist the Serbian administration in completing the transposition of the EU Acquis in the areas of PPC/ IED, Seveso and EMAS.

Activities:

• Undertake a legal gap analysis and prepare a ToC in the field of IPPC and make recommendation for improvement of the equivalent law on IPPC and secondary legislation

• Undertake a legal gap analysis and prepare a ToC for Seveso II Directive 96/82/EC as extended and amended by Directive 2003/105/EC, with recommendation for improvement

• Assist with drafting Serbian legislation to implement the EMAS Regulation (EC) No. 1221/2009, ensuring a legal framework ready for full implementation of the EC Regulation

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Component 2:

enhance capacities at the national level on IPPC permitting, evaluation of Safety Reports and Emergency Plans, and EMAS certification

Activities:

• Carry out a SWOT analysis, in the three thematic areas, with a view to augmenting the existing arrangements

• Completion of three (3) procedures manuals, one for each of the three (3) thematic areas: IPPC/IED, Seveso and EMAS (c. f. description under scope of work component2)

• Undertake training needs assessment and prepare training plans for all relevant stakeholders as well as training materials

• Organise and implement a series of workshops for IPPC, Seveso II and EMAS departments of the MESMP and stakeholders

• Organise and implement indicatively five (5) workshops for IPPC owners/operators and also include consulting companies

• Organise and implement indicatively 4 training courses for representatives of relevant institutional sectors included in the process of issuing approvals for Safety Reports and EP

• Organise and implement indicatively three (3) training courses for operators and also include consulting companies on the development of Safety Reports and Emergency Plans

• Organise and implement training for selected EMAS verifiers in line with the Law on Accreditation (Official Gazette, RS No. 44/05)

• Organise and implement study visits to competent bodies in the EU in order to strengthen the capacity of the MEMSP in the fields of IPPC, Seveso and EMAS

• Needs assessment for - and design of an IT solution for meeting the data management, document handling, public information and reporting requirements in the three areas

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Component 3: increase public awareness and to support proactive participation of public in decision making

Activities:

• Prepare a target group of public audience interested or likely to be impacted on by IPPC/IED or Seveso facilities (Safety Reports and Emergency Plans).

• Prepare and print promotional materials in order to inform the public about their rights

• Prepare promotional activities to facilitate public debate in the field of prevention of chemical accidents and IPPC

• Organize workshops in order to promote EMAS and other voluntary instruments (Eco label, ISO 14001, Cleaner production, etc.) to pertinent organizations

• Re-design website of Serbian Ministry of Environment, Mining and Spatial Planning/competent authority

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Component 4: assist Serbian Seveso operators in developing their Safety Reports and Emergency Plans through 3 pilot projects.

Activities:

• Review/develop methodology and criteria (i.e. risk analysis) to select target sectors and select most appropriate ones

• Review/Develop methodology and criteria (i.e. risk analysis) for selection of target enterprises and select those that are most appropriate

• Provide assistance to the selected enterprises for the preparation of Safety Reports and Emergency Plans and upgrade checklists for Safety Reports, as necessary

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Component 5: support the actual IPPC/ IED permitting process both through direct involvement of the project experts in this process and the development of tools for permit writers.

Activities:

• Provide technical assistance for implementation of BAT; draft a guidance document on the use of BREF documents

• Translate 10 appropriate BREF documents into Serbian language

• Assist in determining conditions in the draft integrated permit for selected activities, with determination of emission limit values (ELVs)

• Assist in establishing plans for monitoring of emissions in selected installations

• Assist in drafting three (3) permits based on submitted applications

• Prepare a generic "permit template" in accordance with Serbian legislation

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Component 6: support further implementation of EMAS certification and registration in Serbia.

Activities:

• Provide an EMAS market analysis and develop methodologies for at least three (3) companies from three (3) different industrial sectors

• Translate new EMAS Regulation (EC) No. 1221/2009 into Serbian language

• Provide assistance to three (3) chosen enterprises to support the EMAS process

• Provide assistance to the EMAS Department in setting up a Serbian Competent Body as an environmental verifier.

PLAN O

F OPE

RATIO

NS FOR T

HE

NEXT

REPORT

ING P

ERIO

D

(DET

AILED)

SRB

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Act. I4– Action planning

A detailed visibility strategy will be finalized, considering all relevant stakeholders and possible media (WS, press, web)

Scheduled activities: STEs activity: definition of

detailed visibility strategy Definition of contents and

structure of project website

Expected Results Visibility strategy Project website pubblication

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Act. 1.1 , 1.2 – Legal Gap Anlaysis

Existing documentation will be collected and checked, as well as legislation. Legal Gap Analysis and Table of Concordance for IPPC and IED Directives will be drafted, as well as for Seveso II and III

Scheduled activities: STEs activity: collection and

analysis of existing legislation

Expected results First draft of Legal GA and

ToC for IPPC/IED and Seveso

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Act. 2.1– SWOT Analysis

Inception meetings findings will be integrated with additional information coming from meetings with secondary stakeholders; a specific will be organized to discuss about strengths and weaknesses of the system.

Scheduled activities: STEs activity: analysis of

findings from inception meetings

Definition of methodology and tools for dynamic SWOT analysis

SWOT meeting with relevant stakeholders (4° week of 2013)

Expected results: SWOT meeting report

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Act. 2.2 - Completion of 3 procedures manuals, one for each of the 3 thematic areas: IPPC/IED, Seveso and EMAS

Starting from the analysis of existing procedures, the manuals will:

• define the responsibilities of all involved authorities and stakeholders

• show detailed flow charts of the work processes in this area;

• Avoid bottlenecks with detailed timing

Scheduled activities: Establishment of WG1

(scheduled 17 january) STEs mobilization: collection

and analysis of existing procedures

Expected results: WG1 meeting report

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Act. 2.3 – Training Needs Assessment

TNA will be developed analysing number and contents of past training activities and consulting officers of involved Institutions withtypical tools of Needs assessment.

Scheduled activities: STEs mobilization:

collection and analysis of past training activities

Definition of methodology and tools for TNA

Expected results: Mission reports

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Act. 2.10 – IT needs assessment and solutions

Analysis of existing IT systems and workflows will be conducted, as well as consultation of officers involved to achieve information on perceived needs.

Scheduled activities: STEs: collection and analysis

of IT systems and workflows of MERZ

STEs: consultation of MERZ officers to identify IT needs

Expected results: Mission reports

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Act. 3.1 – prepare a target group of public audience interested on IPPC/IED and Seveso

Identification of NGO, organizations, groups and areas likely to be impacted by the presence of installation will be done. According to the strategy, a selection of groups and areas to be involved into the project will be done.

Scheduled activities: STEs: identification of potentially

impacted groups or areas STEs: first selection of target

group

Expected results: Mission reports Draft of target groups for

IPPC/IED and Seveso

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Act. 4.1 , 4.2– Seveso: methodology and criteria to select target sectors and enterprises for pilot projects

Content and methodology of selection has been agreed with MERZ, analysis of potential sectors and enterprises will lead to list of pilot projects drafted

Scheduled activities: STEs: identification of potential

target sectors and installations STEs: selection of pilot projects

Expected results: Report on methodology and

criteria for selection of target enterprises

3 target sectors for pilot projects 3 installations for pilot projects

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Act. 5.1 , 5.6 – IPPC/IED: support for implementation of BAT and development of a generic Permit Template

Methodology for implementation of BAT will be defined and a collection of best practices and tools used in this field will be provided.

WG2 will be established and will validate methodology as well as cooperate in defining structure of the permit template

Scheduled activities: STEs: identification of best practices

and tools in the field of BAT implementation and assessment

STEs: definitiono of a drafted structure of integrated permit

WG2 first meeting (2° week of fwebruary)

Expected results: Methodology for implementation and

assessment of BAT Structure of permit template WG2 meeting report

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Act. 5.2 – IPPC/IED: Translation of BREFs

List of BREF documents to be translated will be finalized, as well as the order of translation.

Translator will be appointed and begin the activity

Scheduled activities: Definition of list of BREFs

to be translated Translator deployment

Expected results: 2 BREFs translated

This Project is funded by the European Union

Project implemented by Human Dynamics Consortium

Act. 6.2 , 6.4– EMAS: Translation of EMAS regulation and assistance in setting up a Serbian Competent Body

Translator will be appointed and EMAS Regulation and case studies will be identified and translated. Strategy and methodology to set up a Serbian Competent Body, according to EU and Serbian regulation will be defined.

Scheduled activities: Definition of list of regulations,

guidelines and case studies related to EMAS

Identification of possible strategy and methodology to set up a Serbian Competent Body

Expected results: EMAS regulation and EC guidelines

translated List of case studies on EMAS Report on strategy and methodology

to set up a Serbian Competent Body