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ICPE


Facilities Classified for Environmental Protection :
The CNPP regularly drafts  files for Facilities Classified for Environmental Protection ICPE (initial operating license application, approval, updating of the license application, operating balance, notification of discontinuance etc.).
We not only know the issues that manufacturers have to face, but also the expectations of the inspectors of Facilities Classified for Environmental Protection.
The CNPP can assist and advise you in all or part of the administrative formalities involved in drafting the ICPE files that have to be remitted to the various authorities.

Before creating or modifying a Facility Classified for Environmental Protection (ICPE) a file has to be drafted in order to notify the authorities of the activity in question, or to apply for its registration with the Prefecture.
We assist you during the drafting of the following :

Notification File, containing

  • Description of the facilities
  • Descriptions of the method and conditions of use, as well as the evacuation and treatment of wastewater and other any kind of emissions
  • Description of the waste disposal methods and operating residues
  • Description of the provisions taken in the case of a contingency

Registration Application File, containing

  • Description of the facilities
  • Proof of the compatibility of the project with the town planning provisions
  • Proof of compliance with the general requirements applicable to the facility
  • Where appropriate, a Natura 2000 impact assessment
  • If necessary, proof of the compatibility of the project with certain plans, schemes and programs (e.g. Water Development and Management Master Plan (SDAGE), waste management plans, etc.)
We assist you during the drafting of the following 

Impact Study, containing

  • An analysis of the initial state of the site and its environment
  • An analysis of negative and positive effects, direct and indirect, temporary and permanent, in the short, medium and long term of the facility on the environment
  • An analysis of the cumulative effects with other known projects
  • A search for compensatory measures for the nuisance caused by the facility
  • An analysis of Best Available Techniques (BAT)
  • An analysis of site remediation requirements
  • A non-technical summary
 

Danger Analysis

  • Identification of the potential dangers of the site
  • Analysis of the accidentology for the activity
  • Preliminary risk analysis
  • Detailed risk reduction analysis
  • A search for measures to control the risks (in terms of prevention and protection)
  • A non-technical summary

Third-Party Appraisal

  • Participation in the kick-off meeting with the administration and an analysis of its needs
  • Conduct of the assignment in accordance with the recommendations of the third-party appraisal 

Impact study

  • An analysis of the initial state of the site and its environment
  • An analysis of negative and positive effects, direct and indirect, temporary and permanent, in the short, medium and long term of the facility on the environment
  • An analysis of the cumulative effects with other known projects
  • A search for compensatory measures for the nuisance caused by the facility
  • An analysis of Best Available Techniques (BAT)
  • An analysis of site remediation requirements
  • A non-technical summary

French regulation:

The fire prevention plan is required by :
  • The amending Decree of 2 October 2015, relative to above-ground storage tanks of flammable liquids or for crude oil storage settled in Facilities Classified for Environmental Protection (ICPE)*.
  • The Decree of 16 July 2015, relative to mobile storage tanks of flammable liquids settled in Facilities Classified for Environmental Protection (ICPE)*.
  •  The Decree of 1 June 2015 concerning facilities subject to registration under headings 4331 à 4734.
*ICPE subject to authorization under headings: 1436, 4330, 4331, 4722, 4734, 4742, 4743, 4744, 4746, 4747, 4748, 4510 or 4511.
The fire prevention plan will allow the ICPE to:
  • Study the resources available in terms of water and fire-fighting foam to extinguish a fire in less than three hours.
  • Define whether the resources are self-sufficient or whether they would require the use of the local Departmental Fire and Emergency Services (SDIS).
 

Your goals

  • Choose the equipment necessary for sustainable, effective fight-fighting, correctly sized according to the fire risk and reference scenarios.
  • Define and identify the organizational and human resources in particular with respect to the kinetics of the hazards, the exposure to heat flow and the range of your fire-extinguishing systems.
  • Ensure the ability of the fire-fighting team (first and/or second response) to intervene effectively, quickly and safely
 

We assist you in the following :

  • Studying the scaling and availability of resources available in terms of water and fire-fighting foam, substantiating their sufficiency (application rate, positioning, preparation in conjunction with the requirements of the Departmental Fire and Emergency Services (SDIS), etc.
  • Fire-fighting master plan, in particular the timing for the implementation of the resources, their sourcing and implementation lead-time, the availability of water and firefighting foam resources, reasoning in terms of technical, economic and regulatory feasibility.
  • Assistance in drafting the request to use SDIS resources, on a temporary or permanent basis, and assistance in relations with the public authorities concerned: the Departmental Fire and Emergency Services (SDIS), and the Regional Directorate for the Environment, Development and Housing (DREAL).
  • Technical assistance: numerical modelling the fire kinetics, heat flow and analysis of the range of fire-extinguishing systems, definition of the technical specifications, technical examination of tenders, acceptance-testing of facilities.
  • Support in organizing response teams and training of the staff responsible for implementing the fire-fighting facilities.

Regulatory references

 
The operators of Facilities Classified for Environmental Protection (ICPE) must notify the Prefect of any cessation in activity, whether total or partial, at least three months before the decommissioning of facilities subject to authorization or registration. This period is extended to one month respectively for facilities subject to declaration and six months for waste storage facilities, geological storage sites for carbon dioxide and quarries.
The notification of decommissioning is an administrative document, the purpose of which is to inform the Prefect of the decommissioning of a facility, and to present the measures taken in particular :
  • The disposal of hazardous products,
  • The prohibitions or limitations on access to the site,
  • The elimination of any risks of fire or explosion,
  • Monitoring the effects of the installation on the environment.
 
R.512-39-1 to R.512-39-6 of the Environment Code (Facilities Classified for Environmental Protection (ICPE) subject to authorization)
R.512-46-25 to R.512-46-29 of the Environment Code (Facilities Classified for Environmental Protection (ICPE) subject to registration)
R.512-66-1 to R.512-66-2 of the Environment Code (Facilities Classified for Environmental Protection (ICPE) subject to notification)
R.553-6 of the Environment Code (electricity generation plant using mechanical wind energy)
Circular of 8 February 2007
 

We assist you in the following :

  • Writing the notification of decommissioning file.
  • The management and redevelopment of polluted sites and soil within the meaning of the conceptual scheme,
  • Site pollution assessment (SPA) (outsourced)
  • The management plan (outsourced)

Regulatory references

Decree of 10 May 2000 / Decree of 26 May 2014 (1 June 2014)
Under the current regulations, the SMS must be subject to periodic audits in order to :
  • Compliance with the targets set as part of the major accident prevention policy
  • Assess the effectiveness of the SMS and its suitability for the prevention of major accidents.
  • Establish an SMS: Defining the human organization, the procedures, instructions and resources associated with the prevention and treatment of major accidents.
  • Conduct an audit of the Safety Management System: areas for improvement, assessment of the effectiveness of the organization in place.
  • Obtain an internal audit report on the SMS in order to make it available to the inspector of classified facilities on the site (Regional Directorate for the Environment, Development and Housing (DREAL) / Regional and interdepartmental Directorate for the Environment and Energy (DRIEE), etc.).
  • Positioning analysis: identification of the differences between the organization of the site and the requirements SMS reference document (decree of 10 May 2000 or 26 May 2014 to 1 June 2014), comprehensive study of the hazard study and assessment of the practices and organization for the management of major accidents (documentary audit and field audit)
  • The definition of the project structure and the SMS implementation action plan according to the positioning analysis.
  • Implementation of the action plan.

Your goals :

We support you in implementing the SMS by means of the following :

  • Help with monitoring the project (with participation in the meetings of the steering committee),
  • Assistance in defining the Major Accident Prevention Policy and site improvement objectives in that respect,
  • Assistance in drafting the SMS management manual, procedures and instructions,
  • Help in establishing SMS indicators and management tools,
  • Awareness-raising among staff about the SMS,
  • The preparation and facilitating of the management review, etc..
 
Auditing the SMS* :
  • Documentary audit: this step allows staff to become familiar with the SMS documentation and the various documents relating to the control of major accidents,
  • The on-site audit: audit of the organizational functions (safety, HR, maintenance, production), investigation of all the facilities and organizational items described as risk management measures (RMM) or important safety features (ISF)
  • Drafting of the audit report. This report highlights the strengths of the company’s SMS and notes the areas for improvement and nonconformities (major and minor) identified during the audit.
*In accordance with NF EN ISO 19011 "Guidelines for auditing management systems".

Danger Analysis

  • Identification of the potential dangers of the site
  • Analysis of the accidentology for the activity
  • Preliminary risk analysis
  • Detailed risk reduction analysis
  • A search for measures to control the risks (in terms of prevention and protection)
  • A non-technical summary
The overhaul of the nomenclature for Facilities Classified for Environmental Protection (ICPE) (introduction of 4xxx headings) related to the transposition of the Seveso 3 directive incorporating the consideration of the EC regulation on the classification, labelling and packaging of substances and mixtures (CLP) came into force on 1 June 2015. It affects the ICPE classification of the activities of any plant, whether it falls within the scope of Seveso or not.

Your goals :

  • Determine the comprehensive ranking of your establishment under the ICPE nomenclature and categories applicable to a specific activity and/or the presence of hazardous substances / mixtures.
  • Assign an ICPE category to each hazardous substance or mixture used, according to the new classification criteria.
  • Determine the Seveso status (high threshold and/or low threshold) for your plant.
 

Our solution :

We have developed Class’IC®© software, making it possible to :
  • Determine the comprehensive ranking of the plant under the new ICPE nomenclature :
    • 1xxx headings (hazardous substances / mixtures that are not dangerous and operations implementing hazardous substances / mixtures);
    • 2xxx headings (activities) ;
    • 3xxx heading (specific activities covered by the Industrial Emissions Directive (IED) and ;
    • 4xxx headings (Hazardous substances / mixtures under the Seveso regulation) ;
  • Automatic allocation for each hazardous substance / mixture, of an ICPE category based on the hazard indications, including in cases of multiple degrees of danger for the same substance / mixture ;
  • Automatic determination of the Seveso status applying the direct upper threshold and cumulation rules, incorporating the possibility of applying the 2% rule.
The Class’IC®© software marketed by CNPP was developed using Microsoft®© Office Excel and is compatible with versions of Microsoft®© Excel released after 2003.
 
In addition to acquiring Class’IC®©, our consultants can assist you at various levels :
  • Ascertaining the ICPE classification and Seveso status of your plant ;
  • Training in the use of Class’IC®© and support in its implementation.

Notification or Registration file, Operating Permit Application File, Health and Impact study, Fire Prevention Plan, Notification of Decommissioning, Safety Management System, Danger Analyses, Modelling,  Class'IC®© - Software of Ascertaining the ICPE classification and Seveso statut of facility, Safety of Seveso sites


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