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?

Technical Measures for Treatment of Industrial Pollution in Specific Industrial Sectors

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

Seiving and pH Regulation

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Dissolved Air Flotation

Biological Treatment

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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

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