Trabiana SRL waste prevention plan

PROGRAM FOR PREVENTION AND REDUCTION OF WASTE GENERATED

(drawn up in accordance with the requirements of GEO 92/2021 regarding the waste regime)

    SC TRABIANA SRL

content                                                                     

1. GENERAL DATA
2. Presentation of the owner of the activity
3. General considerations regarding the waste prevention and reduction program
4. Legislative regulations in the field of waste management

1. DESCRIPTION OF THE ACTIVITY

III. CATEGORIES OF WASTE GENERATED

3.1 Types of waste

3.2. Methods of collection, temporary storage, storage of waste

3.3 Transportation of waste

IV MEASURES TO PREVENT AND REDUCE THE QUANTITIES OF WASTE GENERATED

4.1. Measures to prevent and reduce waste

4.2. Responsibilities within the organizational structure

4.3. Expenses related to waste management

1. GENERAL DATA
2. Presentation of the owner of the activity

     Registered office of the company SC TRABIANA SRL – the municipality of Constanta, sos. Mangaliei, no. 74, Carmeco SA premises, Constanta county.

    Company identification data/contact data:

• ORC Constanta registration number: J1994000926138;
• unique registration code: RO 5408591;
• telephone 0722/203 191/ e-mail: office@trabiana.ro;
• The activity regulated by Environmental Authorization no. 315/07.12.2020 takes place at the headquarters in the municipality of Constanta, sos. Mangaliei, no. 74, Carmeco SA premises, Constanta county.

2. General considerations regarding the waste prevention and reduction program

       The proper management of waste represents a problem and at the same time an obligation of major importance for every economic operator, communities and individuals. In accordance with the provisions of GEO 92/2021 regarding the waste regime, waste management must be carried out without endangering human health and without harming the environment, especially without creating risks for environmental factors (water, air, soil, flora and fauna), without creating discomfort through smells or noise and without affecting the landscape or areas of special interest.

    In accordance with the provisions of GEO 92/2021 regarding the waste regime, but also with other normative acts in force, a series of obligations and responsibilities result for economic operators that carry out economic activities that generate waste.

Economic operators that generate waste as a result of import or production activity, according to current legislation, are obliged to draw up and implement a program to prevent and reduce the amount of waste generated from their own activity or, as the case may be, from any manufactured product, including measures that respect a certain product design, and to adopt measures to reduce the dangerousness of waste.

A prevention plan must take into account some basic considerations, namely:

• Management of resources and, respectively, of waste on site;
• The design of a product in such a way as to take into account the principles of the circular economy, namely the reduction of the consumption of raw materials and energy, based on an economic circuit built from the design phase so that the resulting waste is reintegrated into the process;
• Establishing objectives;
• Other tools.

    The understanding of these obligations and responsibilities, the implementation of the legal provisions in the field of environmental protection as well as the application of the principle of waste hierarchy, will determine the way of success in order to prevent and reduce the amount of waste generated.

  The waste prevention and reduction program will be analyzed and updated periodically, throughout the activity period, depending on the legislative changes in the field of environmental protection, new regulations but also based on the managerial analysis, the observations issued by internal and external analysts.

3. Legislative regulations in the field of waste management

    The program for the prevention and reduction of waste generated within SC TRABIANA SRL takes into account both the Regulations and Directives of the European Union as well as the normative acts of the Romanian legislation in the field of waste management.

   Waste management must be carried out without affecting human health and without harming the environment, in compliance with the legal provisions in the field of environmental protection.

The specific regulations regarding waste management are contained in normative acts, such as:

• GEO no. 195/2005 - regarding environmental protection, with subsequent amendments;
• GEO 92/2021 - regarding the waste regime, with subsequent amendments and additions;
• Government Ordinance no. 2/2021 regarding waste storage;
• Order of the Minister of Environment and Water Management no. 95/2005, Acceptance criteria and preliminary procedures for accepting waste at warehouses and the national list of waste accepted in each class of waste warehouse;
• Order of the Minister of Environment and Water Management no. 757/2004, Approval of the technical regulations regarding waste storage - construction, operation, monitoring and closure of a waste storage facility;
• HG 856/2002 regarding the record of waste management and the approval of the list including waste, including hazardous waste
• Government Decision 128/2002 regarding waste incineration;
• Government Decision no. 268/2002 and HG 427/2005 - for the amendment and completion of HG 128/2002 regarding waste incineration;
• Law no. 278/2013 regarding industrial emissions, with changes and additions;
• Government Decision no. 124/2003 regarding the prevention, reduction and control of environmental pollution with asbestos, with changes and additions;
• Government Decision no. 734/2006 for the modification
• LAW no. 249 of October 28, 2015 regarding the way of managing packaging and packaging waste, with changes and additions;
• EMERGENCY ORDINANCE no. 5 of April 2, 2015

regarding electrical and electronic equipment waste;

• Government Decision no. 992/2005 regarding restrictions on the use of certain hazardous substances contained in electrical and electronic equipment;
• DECISION no. 1,132 of September 18, 2008 (*updated*)

regarding the regime of batteries and accumulators and the waste of batteries and accumulators

• Government Decision no. 170/2004 regarding the management of used tires;
• Law no. 212/2015 regarding the management of vehicles and end-of-life vehicles.
• Government Decision no. 788/2007 regarding the establishment of measures for the application of the EP and EC Regulation 1013/2006 regarding the transfer of waste;
• Government Decision no. 1453/2008 for the amendment and completion of HG 788/2007 regarding waste transfer;
• Government decision no. 1061/2008 regarding the transport of hazardous and non-hazardous waste on the territory of Romania;
• Order of the Minister of Environment and Water Management no. 344/2004 and Order of the Minister of Agriculture, Forests and Rural Development no. 708/2004, Approval of the technical norms regarding the protection of the environment and especially of the soil when sewage sludge is used in agriculture;
• Government Decision no. 173/2000, Regulations regarding the management and control of polychlorinated biphenyls and similar compounds modified by Government Decision no. 291/2005;
• Law 101/2006, Locality Sanitation Service, with amendments and additions;
• GEO 71/2010 regarding the establishment of the strategy for the marine environment;
• Water Law no. 107/1996, with subsequent amendments and additions.

1. DESCRIPTION OF THE ACTIVITY

The activity carried out by the company is "VEHICLE MAINTENANCE AND REPAIR - (car service with paint shop)" - according to CAEN code (Rev.2): 4520.

III. CATEGORIES OF WASTE GENERATED

3.1 Types of waste

The waste management activity involves the temporary storage, reuse, collection, transport, treatment, recycling and disposal of waste, with the main goal of saving raw material by reusing recyclable waste, thus contributing to reducing the pressure on natural resources.

In accordance with GEO 92/2021 on the waste regime, the meaning of some terms is presented below:

• waste - any substance or object that the owner throws away or has the intention or obligation to throw away;
• holder of waste - the producer of waste or the natural or legal person who is in possession of it;
• waste producer - any person whose activities generate waste, waste producer or any person who performs pretreatment, mixing or other operations that lead to the modification of the nature or composition of this waste;
• waste management - the collection, transport, recovery and disposal of waste, including the supervision of these operations and the subsequent maintenance of disposal sites, including the actions taken by a trader or an economic operator dealing with the recovery/disposal of waste on behalf of other persons;
• valorization - any operation whose main result is the fact that the waste serves a useful purpose by replacing other materials that would have been used for a certain purpose or the fact that the waste is prepared to be able to serve that purpose in businesses or in the economy in general;
• disposal - any operation that is not a recovery operation, even if one of its secondary consequences would be the recovery of substances or energy.

The waste generated in the activity carried out by SC TRABIANA SRL is technological waste and waste resulting from the administrative activity of the company:

The following table shows the types of waste generated, the waste code in accordance with GEO 92/2021 on the waste regime and the DECISION OF THE COMMISSION of December 18, 2014 amending Decision 2000/532/EC establishing a list of waste pursuant to Directive 2008/98/EC of the European Parliament and of the Council), methods of temporary storage, storage, recovery/disposal.

Waste is divided into two large categories: non-hazardous and hazardous and is classified according to Commission Decision 2014/955/EU of December 18, 2014 amending Decision 2000/532/EC establishing a list of waste pursuant to Directive 2008/98/EC of the European Parliament and of the Council.

Hazardous waste (those represented with an asterix) must be stored separately depending on the physico-chemical properties, compatibilities and the nature of the extinguishing substances that can be used for each category of waste in case of fire, so that a high degree of protection of the environment and the health of the population can be ensured, including ensuring traceability from the place of generation to the final destination.

  In accordance with the provisions of GEO 92/2021 regarding the waste regime, for each type of hazardous waste generated/owned, the company will draw up the waste specification sheet (characterization) which will also include data on the properties that confer its hazardous character.

   The table presented the types of waste generated, their coding, methods of temporary storage, storage, recovery/disposal.

    It is found that both waste that can be recovered (paper-cardboard, plastic, toner cartridge, lighting equipment) is generated as well as waste that must be eliminated (household waste, packaging that is contaminated with dangerous substances, laboratory residues). The recovery and disposal of waste will be done only in authorized installations, based on the contracts concluded with authorized economic operators in this regard.

3.2 Methods of collection, temporary storage, storage of waste

   The generated waste will be selectively collected and temporarily stored until their handover, in labeled containers and specially arranged spaces so as not to create the risk of negatively affecting the environmental factors (water, air. soil, flora and fauna), not to create discomfort through smells and noise and not to affect the landscape.

The temporary storage space for recyclable/recyclable waste is a closed space, with a waterproofed floor and provided with adequate facilities for storing the generated waste, with equipment to prevent and reduce accidental pollution, with adequate ventilation to ensure low temperatures that do not allow the decomposition of organic material from the composition of hazardous waste.

The collection and temporary storage will be done depending on the physico-chemical properties of the waste, the compatibilities and the nature of the extinguishing substances that can be used in case of fire, so as to ensure a high degree of protection of environmental factors and human health.

Hazardous waste is stored in metal containers, resistant to mechanical and thermal shock, sealed, or on metal shelves, arranged accordingly.  

The formation of stocks that could endanger human health and damage the environment (risks of water, air, soil, fauna, flora, generation of odors, risk of fire for the neighborhood) will be avoided, ensuring a rhythmic delivery of them.

   Household waste is collected and temporarily stored in plastic containers (Eurobins) or metal containers.

   The record of waste management will be kept in accordance with the provisions of HG 856/2002 regarding the record of waste.

    For the proper management of waste, so as not to endanger human health and not to damage the environment, measures are required, such as:

• ensuring sufficient storage capacities;
• the labeling of all waste collection/storage containers, regarding content and capacity and the application of a unique identification element;
• establishing a register for all generated waste.
• the use of a storage space / warehouse equipped with all the necessary measures to eliminate the specific risks presented by the respective waste;
• monitoring the operational surface and applying measures to prevent or quickly remove any leaks and accidental spills;
• use of biodegradable absorbent material for possible substance/hydrocarbon leaks.

  3.3 Transportation of waste

     The transport of waste generated within the company will be carried out by third parties - professional companies, depending on the category/type of waste, in compliance with the legal provisions.

     The transport of waste will be carried out only to companies that have environmental authorization for collection/temporary storage/treatment/utilization or disposal activities.

     Non-hazardous waste will be transported with non-specialized vehicles and hazardous waste will be transported with specialized vehicles.

     When handing over waste, the forms proving the traceability of hazardous or non-hazardous waste are requested and kept according to the law. Thus, the provisions of HG 1061/2008 regarding the transportation of hazardous and non-hazardous waste on the territory of Romania will be applied to the transport of waste, as follows:

- the transport of non-hazardous waste will be based on the loading-unloading form (Annex 3 to HG 1061/2008);

- the transport of hazardous waste will be carried out on the basis of the dispatch-transport form (Annex 2 to HG 1061/2008) and the transport approval form (Annex 1 to HG 1061/2008) as the case may be.

    In order to carry out the transport in safe conditions for the environment and human health, the company will take measures regarding the packaging and appropriate labeling of the waste, in accordance with the legal provisions and the recommendations from the waste characterization (specification) sheet, in the case of hazardous waste

IV MEASURES TO PREVENT AND REDUCE THE QUANTITIES OF WASTE GENERATED

4.1. Measures to prevent and reduce waste

    A proper waste management is achieved only by implementing and complying with the legal provisions in the field of environmental protection. Preventing the occurrence of waste cannot be done effectively without a plan, through momentary actions that only solve current problems.

In the list regarding the waste hierarchy, waste prevention is a priority. Prevention aims to encourage waste management in order to reduce their negative effects on the environment.

The waste disposal stage must be applied only after all other means have been used to the maximum, responsibly, so as not to produce negative effects on the environment.

In the figure below, the hierarchy of recommended methods for waste management is presented - THE WASTE PYRAMID.

Fig.1 – Waste pyramid

The main objectives of the waste prevention and reduction plan for SC TRABIANA SRL are:

• prevention of waste generation (encouraging action to prevent waste generation, so as to reduce their negative impact on the environment);
• minimization of waste generation;
• preparation for reuse;
• waste recycling;
• waste recovery;
• waste disposal;
• ensuring the traceability of waste from the place of generation to the final destination.

The prevention of genarivers ofsthe selves – the company will take measures to implement policies and practices such as:

• efficient use of resources;
• reusing products or extending their lifespan
• reducing waste at source - e.g. restrictions on buying some products that are overpackaged;
• the purchase of reliable, high-quality, long-lasting materials and equipment;
• the purchase of modern machines that can efficiently process a product;
• monitoring the flow of materials used and results;
• the use of materials and equipment in compliance with the requirements/technical instructions for use so that the duration of operation is as long as possible;
• ensuring the maintenance and repair works of the equipment, machines, to ensure the functioning within the parameters and to avoid technical wear and tear;
• encouraging the repair of defective products;
• employee training;
• establishing a waste recycling program;
• drawing up the list of hazardous/non-hazardous waste;
• risk assessment regarding hazardous waste management;
• identification of companies specialized in the transport, disposal and recycling of waste.

Starting from the selective collection of waste in order to valorize it, the amount of waste that is eliminated through storage is reduced.   

RE sand recycling ofsWASTE

Waste will be recycled to minimize the rate of generation.

Waste with potential recycling value are:

• paper from administrative activities,
• plastic packaging
• paper/cardboard packaging,

All categories of recyclable waste will be sent to authorized collection and processing/recycling units.

For the equipped cars, the purchase of car batteries will be done with priority from suppliers that apply the deposit system, in order to recover used batteries;   the purchase of car tires will be done with priority from suppliers with a recovery and retreading program. Otherwise, tires will be disposed of by authorized economic operators for co-incineration activities, in order to recover energy in the authorized installation.

Waste recovery/disposal - it will be done only by authorized economic operators, in authorized installations.

Ensuring the traceability of waste from the place of generation to the final destination the company will ensure waste traceability in accordance with the provisions of GEO 92/2021 regarding the waste regime and HG 1061/2008 regarding the transport of hazardous and non-hazardous waste on the territory of Romania.

Specific measures to prevent or reduce the amount of waste generated:

• monitoring the flow of materials used and results;
• efficient use of resources (efficient management of paper/cardboard, reuse of plastic bags or use of textile packaging, for example);
• the optimal location of the facilities for the selective collection of packaging waste generated on site;
• the purchase of unpackaged products or products without excessive packaging; Restrictions on the purchase of products that are overpackaged;
• reducing the amount of contaminated packaging (purchasing liquid products in large volume containers to avoid the production of packaging waste that contains residues or is contaminated with dangerous substances, analyzing suppliers in order to select those that promote eco cleaning products or substances used in technological processes, inventorying products based on their validity period to avoid their expiration; handling substances and mixtures according to the information in the safety data sheets to avoid damage to the packaging of dangerous products; supplying chemicals/dangerous substances only as needed, based on orders and in minimum quantities to avoid the formation of stocks and to avoid the expiration of the substances; returning the empty packaging to the suppliers, where appropriate);
• encouraging the repair or reuse of defective products or their components;
• extending the life of electrical and electronic equipment;
• the use of lighting fixtures based on LEDs instead of fluorescent tubes, considering that LEDs have a longer lifespan; predominantly use of natural lighting;
• opting for rechargeable batteries instead of batteries;
• reuse of toner cartridges;
• the selection of traders/distributors who sell a predominant range of "green" products, as far as it is technically possible;
• the purchase of machine materials and reliable equipment;
• training employees for the selective collection of recyclable waste, with emphasis on the following aspects:

the importance of preventing waste generation and the obligation to reuse products and selective waste collection;

awareness and attention regarding the printing of documents, for the purpose of using documents primarily in electronic format,

using the database and documents in electronic format, as well as electronic mail and saving and archiving them in electronic format

4.2. Responsibilities within the organizational structure

  The person responsible for waste management is part of the staff of SC TRABIANA SRL, being subordinate to the company administrator. The entire staff of the company will be trained on how to manage waste, in order to achieve the main objectives and comply with the legal provisions in the field of environmental protection.

   The proposed measures will be periodically analyzed by the person in charge of waste management and reported to the administrator. In case of non-conformities in the way of waste management and/or inconsistent with the provisions of this Plan, the person in charge of waste management will inform the administrator in due time for the elimination of non-conformities and compliance.

   The waste prevention and reduction plan will be reanalyzed and periodically updated if necessary, depending on legislative changes in the field of environmental protection, new regulations, but also based on managerial analysis, observations issued by internal and external analysts.

  Any substantial change that may lead to a change in the authorized conditions for carrying out the activity will be notified to the environmental authority.

4.3. Expenses related to waste management

The producers/holders of waste are obliged to hand over the waste generated from their activity to economic operators authorized by the competent public authority and to carry out collection, transport, valorization and/or waste disposal operations under the conditions of the environmental legislation in force. The costs of waste management operations are borne by the waste producer according to the "polluter pays" principle.

For the management of the waste resulting from the activity as well as for the implementation of the measures proposed by this plan, the company will allocate the necessary funds in order to ensure the selective collection as well as for the valorization or disposal of the waste, depending on the need, from its own, private sources.

SC TRABIANA SRL