Common Inspection Training Report Kosovo (UNHCR1244)
Common Inspection Training Report Kosovo (UNHCR1244)
Common Inspection Training Report Kosovo (UNHCR1244)
TRAINING EVALUATION
RENA Working Group 4 ECENA - Activity 4.1 Capacity building regarding compliance with
environmental legislation through better understanding of issues and identification of targeted
solutions (training of inspectors and permit writers) , 12 15 April 2011, Pristina, Kosovo under
UNSCR 1244/99
Table of Contents
page
1. Introduction 2
2. Background 2
3. Delegates ` 3
4. Training Materials 4
5. Course Content 4
7. Conclusions 5
Contact:
Dr. Ir. Ike van der Putte
Tel: +31 15 750 16 00
Mob: +31 653 948 067
Fax: +31 15 750 1610
e-mail: [email protected]
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Training Evaluation report Kosovo under UNSCR 1244/99
1. Introduction
The second training course in the series of eight courses was given in Kosovo in the AFA Hotel, Pristina
from 12 15 April 2011. The total number of participants was 30 (inspectors and permit writers),
including a representative from the EC delegation, two inspectors from Albania and two inspectors from
Croatia. The SHARRCEM Cement factory at Hani i Elezit (40 kilometres from Pristina) served as the site
where a site visit and a common inspection were held. The training was given by Rob Glaser and Ike
van der Putte.
Figure 1. The Common Inspection at the SHARRCEM Cement Factory at Han I Elezit
2. Background
Within the defined RENA WG 4 ECENA programme a series of national training programmes in eight
RENA beneficiary countries are to be held. The basic elements are in brief:
Implementation of 3.5 days training workshop on permitting and inspection in each individual country for
20 participants (10 permit writers max and 10 inspectors max), or depending on the country on any other
identified weakness in the regulatory cycle element (20 participants max.).
A site visit with around 2 invited participants (inspectors) from other RENA countries, is included
(common inspection) in order to promote the exchange of experience within the region. However, if the
expertise for a defined topic is not available within the RENA countries, the inspectors from other MS
will be invited.
The priorities indicated in the inception mission reports and filled in questionnaires for each country are
used as a basis for composing the national trainings aiming at a tailor made approach to the trainings. The
selected topics and preliminary programmes for the first batch of four countries (Albania, Kosovo, Bosnia
and Herzegovina, and Turkey) have been assessed (see separate report).
The topics to be covered in the 3.5 day training programme will be generally composed of:
Day 1: General subjects (management of inspections, priority setting, reporting feedback, exercises, and
introduction to special subjects)
Day 2: IPPC/IED requirements
Discussion on integrated permit content (permit application, BREFs/BATs selected industry); on
content of translated permit for the selected pilot.
Presentation of selected pilot factory specialist
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Training Evaluation report Kosovo under UNSCR 1244/99
3. Delegates
The participants in the training in Kosovo were 17 persons from the Ministry of Environment and Spatial
Planning and 8 persons from the municipal agencies and inspectorates. A representative of the EC
delegation also participated in the course. Croatia and Albania have each sent two inspectors respectively
to be involved in the common inspections and presentations:
1. Muhamet Malsiu, Director of the Department for Environment Protection MESP (Ministry of
Environment and Spatial Planning)
2. Florije Kqiku, Construction and Environmental Inspector ,MESP
3. Mustaf Hyseni, Environmental Inspector, MESP
4. Vehbi Ejupi, Environmental Inspector, MESP
5. Ismet Dervari, Environmental Inspector, MESP
6. Isak Pllana, Environmental Inspector MESP
7. Qefsere Mullaku, Environmental Inspector MESP
8. Shqipe Buzuku, Water and Environmental Inspector MESP
9. Safete Kuqi, Environmental Inspector, MESP
10. Shukri Shabani, Permit writer (EIA), Chief of Sector , MESP
11. Merlinda Bllata Di Brani,, Permit writer (EIA) , MESP
12. Ahmet Ahmeti, Permit writer (IPPC),Chief of Sector, MESP
13. Naim Alidema, Permit writer (IPPC) , MESP
14. Adem Tusha, Permit writer (SEVESO II), MESP
15. Jehona Mavraj, Chief of sector for Environmental Protection, Prishtin
16. Sylejman Selishta, Municipal Environmental Inspector Gjilan
17. Xhelal Shabani, Chief of sector for Environmental Protection, Mitrovic
18. Miftar Shala, Municipal Environmental Inspector, Pej
19. Bajram Berisha, Municipal Environmental Inspector, Prizren
20. Lulzim Mjekiqi, Municipal Environmental Inspector, Obiliq
21. Ahmet Ahmeti, Municipal Environmental Inspector, Drenas
22. Nadire Mici, Municipal Environmental Inspector, Hani I Elezit
23. Tringa Gjikoli (MESP)
24. Fatbardha Bushi (MESP)
25. Jemin Bytigi (MESP)
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Training Evaluation report Kosovo under UNSCR 1244/99
Representative EC delegation
Gazmend Selimi
Inspectors from Albania
Enver Halipaj
Adi Madhi
Inspectors from Croatia:
Ante Belamaric
Ivan Pusic
Trainers
Rob Glaser
Ike van der Putte
4. Training Materials
All delegates were provided with printed copies of the manual and presentation materials. A digital version
can be found on the RENA website (www.renanetwork.org).
Simultaneous translation was provided throughout the workshop with presentations given in both English
and Albanian. A translator English/Croatian was also provided for,
As special subjects Kosovo has chosen IPPC/IED and SEVESOII, with the SHARRCEM cement
factory as the pilot site for site visit and common inspection.
The training materials included those in the manual developed in specific for Kosovo in which also the
selected special subjects were taken up. Example IPPC permits for the cement industry, with BAT and
BREF information materials were incorporated. In the manual also extra materials were included covering
other items which have not specially been selected by Kosovo, but which are of general relevance for the
ECENA countries.
5. Course Content
The agenda, containing a summary of the content of the training and presentations, is given in Annex.1
Introductions and explanations were given on the regulatory cycle with the human resources aspects in
permitting and inspection. Special attention was given to the IED and consequences for the inspection
and enforcement.
About 40% of the course was devoted to the site visit, group discussion and feedback and to practical
exercises with the delegates divided into three working groups dealing in specific with the following units
in the cement factory operations:
1) Quarry operation and rehabilitation (including transport and storage)
2) Kiln area (dust measurements/maintenance/accidents and incidents)
3) Laboratory (monitoring (SOx, NOx, dust)) and dispatch area (bags,dust abatement)
The site visit was executed according to a checklist prepared by the participants.
SHARRCEM is an existing cement plant with following history in production capacity and ownership:
1936 Start of production, one vertical kiln with production capacity of 4 415 t/year
1972 rotary kiln with production capacity of 180 000 t/year
1980 rotary kiln with production capacity of 525 000 t/year
2000 Holcim entered into a 10 year leasing contract to operate the plant
From January 2011, Sharrcem is a privatized company managed by the Titan group.
.A summary of the environment consent (Annex 2a) and EIA for SHARRCEM was provided and
discussed against the BAT/BREF requirements.
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Training Evaluation report Kosovo under UNSCR 1244/99
In the course a presentation was given by the SHARRCEM environmental manager (Annex 2b). The
invited inspectors from Albania and Croatia made presentations to share their experiences in IPPC
permitting and enforcement with special reference to the cement industry.
These materials are included in Annex 2c-d.
Formal feedback forms were distributed at the end of the course, and are analyzed below. 21 responses
were received from the participants form Kosovo as the formal target group for the training. In addition
responses were received from the four invited inspectors from Albania and Croatia.. The questions refer
to
1. expectations of the participants
2. the training and presentations
3. comments and suggestions
The results are given in summary tables in Annex 3a covering the feedback from the participants from
Kosovo, and in Annex 3b covering the response from the invited inspectors from Croatia and Albania..
The expectations were generally and in specific met (almost all respondents). One respondent from the
invited inspectors answered that expectations were partially met. In the latter case it should be mentioned
that the target group of the training were the participants from Kosovo and not the more experienced
invited inspector, who has already a considerable level of know how on integrated permitting and
inspection.
The training and presentations were in various ways considered as excellent to good (96% of the total
score). The quality of the training materials, the practical work and the quality of the trainers (knowledge
and preparation) were especially highly rated, next to the logistical arrangements. A similar response was
given by the invited inspectors fro Croatia and Albania.
On comments and suggestions the following can be mentioned:
From 4 participants a recommendation was received to translate the manual into the Albanian language;
More of such training are needed in future ( 8 respondents).
In general the training was considered important with the level of training being in accordance with the
needs.
.
7. Conclusions
The second training course held in Kosovo was also well received. The contributions of the inspectors
from Albania and from Croatia were excellent and especially contributed to the understanding of the
permits and permitting process in their respective countries. Presentations were well prepared.
The site visit was very illustrative for the limited possibilities industry has in solving problems in enclosed
urban areas. The cement factory is located in a valley in which it is very difficult to avoid dust problems.
Also the quarry is very close to the urban area aggravating the situation.
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Training Evaluation report Kosovo under UNSCR 1244/99
Rehabilitation of the factory will be very expensive and requires measures including: installation of:
- bag filters
- continuous monitoring system
- enclosure of all activities that show dust emissions (dispatch area, loading of cars etc.)
The SHARRCEM factory is presently operated based on the issued Environmental Consent and an EIA.
There is no Integrated Permit issued yet, although the factory would like to have one, on which basis
investments can be done for monitoring systems and emission control (bag filters).
The course was well received and a good exchange of views took place onsite of the factory with the
management and operators. The conditions were surveyed and comments from the inspectors were
discussed with the management of the factory.
The materials provided, were very well compiled and printed. There was a strong wish to have more of
such trainings.
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ANNEX 1. Training programme Kosovo under UNSCR 1244/99
Training Programme Kosovo under UNSCR 1244/99
DAY 1
08.00-08.45 Registration
08.45 Opening
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Training Programme Kosovo under UNSCR 1244/99
2
Training Programme Kosovo under UNSCR 1244/99
DAY 2
Session 10 08.45 -09.30 (45 minutes)
IED in context with IPPC and other directives
(General information on developments and current situation of the environmental legislation with
consequences for enforcement mechanisms in EU)(IP)
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Training Programme Kosovo under UNSCR 1244/99
4
Training Programme Kosovo under UNSCR 1244/99
DAY 3
At the site.
Preliminary discussions in the office
Review documentation (monitoring data, quality checks, site plans, permits)
is necessary documentation in place?
Divide into groups with chairman and reporter in each. Chairman has allocated
specific responsibilities to each member of the group
Site visit:
Request site staff to provide guides: groups to see all of the site, but focus on
areas: like handling and storage, dust abatement, waste handling and filling
stations, cleanliness of factory, evaluate surrounding area.
Each member of the group will make their own inspection and make notes and
compare results later in the group.
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Training Programme Kosovo under UNSCR 1244/99
DAY 4
6
ANNEX 2. Presentation materials of Invited Inspectors and Environmental consent
Factory
GOEVERNMENT OF KOSOVO UNDER UNSCR 1244/99
MINISTRY OF ENVIRONMENT AND SPATIAL PLANNING
Subject: Answer to the request to review the report of Environmental Decision for
reconstruction of the cement plant,, Sharrcem in Hani Elezit
Number: 1431/ZSP-256
Date: 06.02.2004
According to your request protocol number 1431, the commissions for Environmental
estimation, in the meeting they reviewed the report of Environmental Assessment and
decided, see the attached Decision.
On the basis of clause 20, paragraph 1,2 and clause 21, paragraph 3 of Environmental Law ,
Regulation nr. 2003/9 and clause 202 this law , ministry of Environment and Spatial Playing,
considering the opinion of competent body for report of environmental assessment ,
brought a:
DECISION
The request for Environmental Decision (ED) for reconstruction of the cement plant
,,Sharrcem in Hani Elezit is APPROVED
Justification
The Ministry of Environment and Spatial Planning (MESP) reviewed the report for EIA and
visited the factory. From the report we can see clearly the situation of the plant prior to
reconstruction (end of 2000). Unacceptable environmental situation.
Also at the report, the investments and planned measures from the investor, that impact
positively in the environment during the production, are indicated. Based on this, MESP
approve the report for ED, which should be understood as initiative for environmental
improvement at the cement factory SHARRCEM. This should be accomplished in close
cooperation between Sharrcem and MESP, under MESP recommendations.
Having in mind the investors initiative for environment improvement in long-term plans,
then the fact that the Environment Law aim in Kosovo is to achieve European standards
while Sharrcem is still under the reconstruction, also lacks of environment datas, MESP
recommends the measures for environment improvements, that should be achieved by the
investor till the end of 2004.
To have the continuous monitoring system for dust and standard components
(first of all components coming from the kiln chimney): NO2, SO2 and CO2, during the
regular production, starting no later than March / April 2004.
In manner that MESP will have clear and real picture of the environment and
improvements done to the end time frame, request from the management oh
Sharrcem a annual report, for other efforts in the future to comply with standards
regulated by the Law.
These measures should be mitigating circumstances for the investor, when we have
in mind the monitoring of the air, soil and water, also the criterias for their limit, will
be obligatory to the regulations and laws, and approved in short period of time.
So, since the, mandate of the competent body is to do the estimation, it has been
decided on availability of this decisions.
Legal Advice / Complaints: Unsatisfied party has the right to initiate the process
of Administrative Dispute at the Supreme Court of Kosovs, within 30 days of the
data of this decision.
Attn:
1.Submitter
2.Commission for ED
3.Inspectorate
4.Archive
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Major equipment:
End discharge tube mill
4.4x15m, x2 off BDP: 130 t/h
End discharge tube mill
3.2x10m, x1 off BDP: 26 t/h
Standard cement capacity
volume: 650,000 t
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Reconstruction
Reconstruction activities
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Extraction Dust
Noise
1 Dust
Noise
Raw
Material Raw Meal Shipping
Preparatio Preparation Clinker Production Cement Grinding Station
n
3 4 5 6
2
Before After
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Indicators
Environment
performance indicators
900
ELV: - SO2 400 mg/m
800 - NOx 800 mg/m
- Dust 50 mg/m
700
[mg/Nm dry,10%O2]
600
500
400
300
200
100
0
AY03 AY04 AY05 AY06 AY07 AY08 AY09 YTD 10
Annual average SO2 emission at kiln stack Annual average NOx emission at kiln stack Annual average Dust emission at kiln stack
Indicators
CO2 performance
indicators
1,000 4,400
900
4,200
[kg CO2/tcemnt], [Mj/tclink]
800
700
4,000
600
[kt CO2]
500 3,800
400
3,600
300
200
3,400
100
0 3,200
AY03 AY04 AY05 AY06 AY07 AY8 AY09 YTD 10
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Social CSR
Corporate Social Responsibility
Social CSR
Corporate Social Responsibility
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Social CSR
Corporate Social Responsibility
Fides award
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Overview
Albania currently are 3 cement manufacturing plant in
Elbasan, in Fushe Kruje and the other in Kruja
trumpeters belonging to the "TITAN
Are given an environmental permit and for 5 other
factories in the area Kruje-Lezhe-Shkoder.
The plant production capacity ranges from 1 to 1.5
million tons / year
Cement production plants in Elbasan and Fushe
Kruje were built prior to 1990 but that are
reconstructed by the company that has privatized
Cement production factory "Titan" group was built in
2010 and is a modern factory with latest technology.
Construction of the factory has cost 200 million
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Documentation
The application of the operator for operating
Legal documentation, registration form consists
of the NRC of activity, registration form to the Court as a
legal person of Tax Form.
Technical documentation consists of:
Characteristics of the project (description of technology,
key processes, capacity, raw materials, energy, auxiliary
materials, intermediate products and final.
Location of the project (with limits spatial layout of the
project, maps and photographs showing the project
location, existing plans of the territory where the project
will be developed).
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Documentation
Profound Report on Environmental Impact Assessment
drafted by experts licensed by the Ministry of
Environment, Forests and Water Administration.
Information on the data in consultation with the public
which identify problems that may have areas on the
environmental impacts from this activity.
Rehabilitation Plan Limestone quarries, quarries clay
and gypsum quarries.
Plan of emergency
Opinion of the municipality or commune
The invoice for the payment of environmental permit fee
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ENVIRONMENTAL IMPACTS ON
FOREST
Quarries limestone has an area of 100 ha.
Quarries clay has a surface of 55 ha.
Quarries of gypsum has an area of 20 ha.
Square for the construction of 70 ha
Opening up the road from the factory on the
highway about 5 ha (5.7 km)
The total area of 250 ha
Reforestation
The surface area of 250 ha has been removed
from the forest fund by special laws.
Operator according to the law must reforest area
of 250 ha.
Reforestation Project approved by and is
controlled by DFS MoEFWA of project.
REHABILITATION
The operator has the obligation to make the
rehabilitation of the area that used for Limestone career,
career clay and gypsum career.
The rehabilitation project is part of the documentation
and prepare environmental permit before approval.
CMD operator pays cash value as bank guarantees
needed for rehabilitation.
Institution that controls the process of rehabilitation is
AKBN (National Agency of Natural Resources)
In case when the operator does not rehabilitate the
deadline as required AKBN engage private operators to
rehabilitate the bank guarantee funds
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Elements of Rehabilitation
Creation of stairs (use the roof top-down). Width of stairs
is usually 8-10 m
Planting trees for greening the landscape
Erosion protection measures by clearing drainage
channels on the basis of any escarpments that make the
waters in case of fall rains.
Collection and protection of upper soil layer (10 - 30 cm).
This layer is rich in N, P, K, which are important
elements that will feed on vegetation planted. This layer
will be used for filling the holes where trees will be
planted for the staircase and garment planting grass
surface protection from erosion.
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THE OVEN
Quality control of materials and products
As operating furnace - burner method
As the gases are prohibited powders
Stored as coal, quality, impact
As developments in the furnace checked
What happens to heavy metals
Temperatures min - max
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Thank you !
8
Ministry of Environmental Protection,
Physical Planning and Construction
.
1
Contents of presentation
National legislation
General overview of cement industry in Republic of
Croatia
Cement plants in Republic of Croatia
1
Article 28.
Article 28.
Artical 162
2
Article 163
The ELVs of existing stationary sources prescribed
pursuant to this Regulation may be exceeded by no
more than three times the prescribed value prior to
31 December 2009 and, after that period, by no more
than 1.5 times prior to the time lines prescribed in
Articles 160, 161 and 162 of this Regulation, unless
other deadlines are laid down in the provisions of
this Regulation.
3
Dry process
Emissions CO2
Wastes of one
Substitutes Alternative By-products Recycled industry are the
fuels / waste from other building starting
materials industries materials materials of
Industrial another
Ecology
10
12
4
HOLCIM
13
HOLCIM
14
15
5
Normal working conditions (Holcim)
16
HOLCIM d.o.o.
co-processed in 2009:
18
6
Discontinuous emission measurements
at the rotary kiln in HOLCIM
19
20
Naice cement
21
7
NAICECEMENT d.d. in 2006
Production
1.500.000 t cement
22
23
Sv. Kajo
24
8
Sv. Jure the modernest coal transport from the boats
25
DALMACIJACEMENT d.d.
PRODUCTION CAPACITIES
26
27
9
www.cemex.hr
28
30
10
Used tyres co-processing
installation
31
32
CEMEX NAICE
HOLCIM LV
Sv. Kajo CEMENT
Dust mg/m3 9 4,76 1,76 30*
3
SO2 mg/m 35 42,2 431,73 400
3
NO2 mg/m 911 508,16 1131,06 800
HCl All values are
2,29 0,39 10
HF mg/m3 below LV
0,2 0,027 1
Dioxini/furani
0,0014 0,00043 0,0014 0,1
g/m3
33
11
Falimenderit pr vmendje
34
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ANNEX 3. Summary course evaluation forms
Training Evaluation Form
POST-TRAINING EVALUATION
FULL TITLE OF THE TRAINING: RENA WG4 ECENA Activity 4.1 Capacity
building regarding compliance with environmental legislation through better
understanding of issues and identification of targeted solutions (training of
inspectors and permit writers
1. Statistical Information
1.3 Name and Surname of See participants list participants from Kosovo
Participant (evaluator) under UNSCR 1244/99
opportunity to implement
acquired knowledge and skills
Training Session: was considered all excellent to good, and very valuable, with a rating of
96% of the total score. The duration of the course was also considered to be meeting the
expectations (90% of the participants), whereas two participants have given this aspect a
lower rating. The latter is presumably linked to the expressed need for more training (see
other remarks)
Trainer: the trainers were considered very experienced and good in transfer of know-
how. The rating was good to excellent (100%)
Training level and content: All participants considered the training good (9) to excellent
(12) and in accordance with the needs of the participants.
Other:
1) From 8 participants a recommendation was received to have more of such training in
the future.
2) The manual should be translated into Albanian (4 participants)
3) The training itself was considered important for a number of participants and the level
of training was in accordance with the needs.
Training Evaluation Form
POST-TRAINING EVALUATION
FULL TITLE OF THE TRAINING: RENA WG4 ECENA Activity 4.1 Capacity
building regarding compliance with environmental legislation through better
understanding of issues and identification of targeted solutions (training of
inspectors and permit writers
1. Statistical Information
1.3 Name and Surname of Invited inspectors from Croatia and Albania. See
Participant (evaluator) participants list
opportunity to implement
acquired knowledge and skills
Training Session: was considered by the majority as good, with one of the inspectors
giving a lower rating
Training level and content: the majority considered the training good .
Other: Preference for a per diem instead of fixed meals at the hotel (1 participant)