------- UNITED STATES ENVIRONMENTAL PROTECTION AGENCY OFFICE OF ENFORCEMENT AND COMPLIANCE ASSURANCE EUROPEAN UNION NETWORK FOR IMPLEMENTATION AND ENFORCEMENT OF ENVIRONMENTAL LAWS (EU/IMPEL) INSPECTOR EXCHANGE PROGRAM (Project R69-11) IMPEL EXCHANGE PROGRAM - FINLAND Ministry of the Environment Helsinki, Finland June 23-27,1997 Richard Ida, OCEFT/NEIC NATIONAL ENFORCEMENT INVESTIGATIONS CENTER Diana A. Love, Director Denver, Colorado ------- BACKGROUND The European Union is made up of 15 Countries (Member States) that promote a common interests in a number of issues including finance, trade, travel, currency, and the environment. The EU/IMPEL (European Union Network for Implementation and Enforcement of Environmental Laws) was formed in 1992 to “create the necessary impetus in the European Community to make progress ensuring a more effective application of environmental legislation”. Since 1992, the Network has met in annual plenary sessions to consider broad issues on the environment and implementation plans. At present there are four main working groups and an Ad Hoc working group. Working Group I Technical Aspects of Permitting The group compares technical standards and technology in the Member States and provides guidance to regulatory bodies in the permitting process. Working Group II Procedural and Legal Aspects of Permitting The group addresses the legal experiences of Member States in permitting industrial facilities and application of EC legislation. Working Group III Compliance Assessment and Inspection The group compares the inspection and enforcement practices of the Member States and will examine the issues of self-monitoring. Working Group W Management of the Regulatory Process The group organizes the exchange program for inspectors to provide for an in-depth understanding of the regulatory systems and inspection processes in the Member States. Ad Hoc Working Group Transboundarv Shipment of Hazardous Waste The group is examining the monitoring and enforcement mechanisms for the trans-frontier shipment of hazardous waste within the EU. 1 ------- OVERVIEW The Ninth EU/IMPEL Exchange Program sponsored by Working Group IV, was held in Finland on June 23-27, 1997 and was hosted by the Finland Ministry of the Environment. IMPEL sponsors three exchange programs a year, each hosted by a different country. All 15 European Union countries were represented with 34 people participating (mainly inspectors and permit writers) [ Attachment 1]. Mr. Richard Ida (OCEFT/NEIC) represented the US EPA at the request of OECA management and Mr. Rob Glaser of the Netherlands and Chair of the IMPEL Working Group 1V. OBJECTiVES The exchange program was developed to provide an opportunity for inspectors, permit writers, chemists, and engineers to exchange information on environmental regulations, technology transfer, and enforcement practices, and to promote consistency and awareness throughout the European community on environmental laws and enforcement issues. The U.S. was invited to participate and exchange technical information and enforcement experiences with the European Community for the benefit of Member States and the U.S. PROGRAM Day 1 Travel, Reception and Briefing At the briefing, the itinerary was explained to be very ambitious, with long days, travel to 3 different cities by bus and air, and visits to a refinery and petro-chemical complex, a steel 2 ------- mill, pulp and paper mills, and a power plant. The Ministry prepared and distributed a briefing notebook containing summaries of the environmental laws and brief descriptions of the industrial sites to be visited. Day 2 (AM) Ministry of the Enviro iiment - Main Principles of Environmental Acts in Finland The morning session was devoted to a presentation by the Ministry on the structure and main elements of Finland Environmental Acts. • Air, Solid Waste, Noise, and Public Health are under the Ministry. The administration of the Water Act is under the Ministry, but water permits are issued and enforced by the Water Courts, a separate entity not related to the Ministry. • Water Courts (3 levels) were established because surface and groundwaters are privately owned. Waters can’t be enclosed, altered, or polluted absent the owner receiving proper compensation as determined by the Water Courts. The Water Courts: issue permits, hear disputes, determine compensation (professional fisherman are eligible for compensation). Issuance of a permit to discharge will normally include compensation, paid by the permittee to the water owners for the permitted discharge. The compensation would be in 3 ------- addition to permit fees paid to the Ministry and/or local authorities. Non-point sources are the main problem in Finland including agriculture runoff, pesticides, and phosphorus causing eutrophication and oxygen deficiency. Non-point sources are not specifically regulated and Finland has few standards for receiving waters. • Thirteen Regional Centers administer the environmental laws and regulations which includes permitting, inspections, and enforcement. Attachment 2 gives a brief description of Finland’s Environmental Administration and a map of the Regional Centers. • Finland has one hazardous waste treatment, storage, and disposal (TSD) facility which is operated by the Government, and funded by industry, government, and local municipali bies. - The facility utilizes incineration, chemical, and biological treatment, and a landfill for disposal of hazardous wastes. - There is no treatment for heavy metals such as Hg, Pb, and Cd. - The greatest proportion of hazardous waste is still treated by industry on case by case basis as required by permits or administrative decisions. 4 ------- • Industry is developing “responsible care” programs designed to minimize solid and hazardous waste production through process changes, recycle, and reuse. These industry practices are encouraged, but are not enforceable. • Permits are negotiated on a case by case basis and industry is responsible for environmental monitoring, testing, reporting, and applying appropriate controls. Permits are based on emission limit values rather than technical standards which are viewed by the Ministry as more restrictive. Day 2 (PM) Visit to the Neste Corporation Porvoo Refinery and Petro- Chemical Complex The plant visits were organized by the Ministry and included: (1) A Corporate presentation on environmental policy, history, and description of plant and general environmental program at facility; (2) Brief presentation by Regional Center on permits and enforcement history; (3) Short tour of facility operations and related control equipment. Tin e was allotted for questions after each session. • Neste Corporation has plants in Belgium, Canada, Denmark, Finland, France, Holland, Mexico, Portugal, Sweden, and the U.S. Two thirds of Neste employees work in Finland. 5 ------- • The Porvoo complex is a 220,000 bbl/day refinery with chemical plants producing ethylene, butadiene, benzene, cumene, phenol, PVC, polystyrene, MTBE, and TAME. Sulfur controls are similar to the U.S. refineries, but do not control fugitive VOC emissions to the same extent. Leak detection and repair (WAR) programs and wastewater emission controls are not required. • The facility employs about 4,000 people and meets ISO 14001 standards. The managers receive a 10% bonus if environmental goals are achieved. Neste has used double-hulled tankers since 1972 with a goal of converting entire fleet to double hulls. • Emission standards are similar to U.S., although they are less restrictive in some areas, e.g. monthly and annual emission and discharge rates versus hourly and daily limits. Some wastes are shipped to foreign or domestic plants for recycling or recovery. • The Ministry’s Regional Center staff presented comments on Neste’s past permit and enforcement history before the facility was toured. Day 3 Flew to Kemi to visit the Outokumpu Steel Company’s Steel Mill and Stainless Steel Finishing Mills • The mills employ 1700 people and produces ferrous 6 ------- chrome to produce stainless steel. Chromite ore is mined nearby. Plants in the Outokumpu complex include sintering plant, electric arc furnaces, steel melting shops, hot rolling mills, and cold rolling mills. Air emissions are controlled by wet scrubbers and baghouses. Dusts and sludges are collected and sent to Sweden (across the bay) for recovery of metals. Ninety percent of the wastewater is returned to process, while the remainder goes through settling ponds before discharge to the sea. Solid wastes are landfilled on-site or sent to the HW Disposal facility. Some slags are used as road base which could be a questionable practice depending upon the heavy metals content of the slags. When asked about the environmental impacts of such a practice, the Company representatives did not have an answer. • The Ministry’s Regional Center staff presented comments on the permit limits and the Company responded with their opinion of the permitting negotiations and permit limits. Company representatives conducted a walking tour of the steel mill and the finishing mills. • Observation: Limits on wastewater and solid waste are not as restrictive as U.S. Air pollution control equipment was comparable. 7 ------- Day 4 Bus to Enso Group, Veitsiluoto Pulp and Paper Mills and Power Station The facility includes: a sawmill, pulp mill, and a coated printing paper mill, and power plant. The pulp mill is rated at 1,000 air dried tons per day. The power plant is a co-gen plant producing steam and electricity for the mills. Power Plant is fired with hog-fuel (tree bark and wood waste) and oil, and the boiler is rated at 246 MW and electrical power output is 93 MW. • An ISO 14001 application has been submitted; all Enso facilities expected to be certified by the end of 1998. The mill was certified in April, 1997. • The air and water pollution control requirements are about the same as U.S. requirements. The pulp mill converted to oxygen bleaching in 1993, thus eliminating the handling of chlorine and potential dioxin problem. Presently, Enso is collecting and scrubbing weak odorous gases, but plan on collecting all streams and incinerate by 1999. Concentrated odorous gas streams are collected and incinerated, presently. • Solid wastes had been landfilled on-site, but the site has been closed and capped. HW is now sent to the State HW disposal facility and solid waste is sent to a municipal landfill. 8 ------- • The Regional Center staff provided a briefing and we toured the facility. The permits were re-issued in 1990 and include more restrictive measures than other permitted facilities. The staff indicated that the Enso permit was one of the better permits they have issued. Day 5 Debriefing and Return to Helsinki by air. General Observations: • The IMPEL program in Finland was very well organized and an ambitious schedule was maintained. Lunches and dinners were meant to be working sessions and a lot of questions and issues such as enforcement structure in the U.S., self monitoring practices, soil contamination and cleanup, etc., were raised and discussed during those periods. Since everyone spoke English, inspectors were able to exchange ideas, discuss facilities in their own country and compare to what is being done in Finland, their countries, and the U.S. • Most countries are relying on self-auditing and self- monitoring procedures to determine and maintain compliance. Some countries issue emission limit guidelines for certain industries, but the final permit limits (which are the only enforceable limits) are negotiated with industry. Some permits may only contain 9 ------- target emission limits. Attendees were interested in the U.S. perspective and enforcement issues were raised and EPA’s philosophy discussed. I raised issues such as quality of data, sampling points, sampling and analysis procedures, lab audits, and unannounced inspections. Inspections done by most IMPEL countries do not go into much detail and unannounced inspections are rare. Some agencies actually have to make appointments to conduct their inspections. However, inspectors can enter the facility if there is a complaint, a major spill, or if excess emissions are observed or reported. • Scandinavian countries have the most restrictive environmental regulations and more southern European countries are the least restrictive. • Transfer of wastes including HW between countries is a problem that is being addressed by the EU by making the laws consistent across the countries, thereby eliminating the impetus for transborder shipment of wastes. • Nuclear wastes are a problem. There are no disposal sites in Europe. Nuclear waste is being stored on-site until a disposal site is located and approved. • Noise is big concern for all European Countries and is addressed in most permits. 10 ------- • Solid and HW are being land filled on industrial sites. With landfills reaching capacity, countries are looking for options such as incineration, separating household from industrial wastes, recycling, and methods to reduce volume of wastes being generated such as responsible care programs in industry. Most countries are looking to incineration as an alternate hazardous waste disposal method. Generally, IMPEL countries don’t have standards for HW landfills other than groundwater monitoring. • Some countries are looking at soil contamination issues including clean-up options, identifying responsible parties, and how to pay for the clean-up. I provided summary of the Superfund program and IMPEL representatives were very interested in receiving more information. • IMPEL representatives were eager to learn about U.S. regulations, permitting, self auditing, self monitoring, inspection procedures, and enforcement practices. I had many requests for EPA information and documents and provided two pages of EPA website addresses for their use. Other documents shared with IMPEL representatives included the EPA Sector Based Notebooks and the NEIC Process Based Inspection Guide. IMPEL representatives were interested in visiting the U.S. to 11 ------- observe industrial controls and gain a better understanding of our regulatory framework. • Costs for the exchange program are shared by the EU general fund allocation, the host country (meals, materials, local transportation, misc. items), and the participant countries (travel). • Mr. Rob Glaser, Chair of Workgroup IV, was very enthusiastic about the U.S. participation in the exchange program and welcomes U.S. participation in the remaining exchange programs. The schedule is: September 1997 - Luxembourg; March 1998 - Spain; June 1998 - Sweden; September 1998 - Italy; March 1999 - Greece. Mr. Glaser felt, and Mr. Ida concurs, the exchange program offered an opportunity to transfer technology and enforcement experiences and was of mutual benefit. Mr. Glaser is also very much interested in exploring the possibility of an exchange with the U.S. 12 ------- ATTACHMENT EU/IMPEL EXCHANGE PROGRAM IN FINLAND, JUNE 23 TO 27, IN 1997 LIST OF PARTICIPANTS Name Country IRELAND Organisation Environmental Protection Agency Telephone 00-353-21-875540 Telefax 00-353-21-875545 Franz Berger AUSTRIA Amt der Landesregierung NiederOsterreich +43/1/531 1015248 +43/1/531 10/5280 Gerhard GOdI AUSTRIA Anit der Steierm rkischen Landesregierung +43 316 877 3809 +43 316 877 3490 Jean-Piere Janssens BELGIUM Brussels Institute for the Management of the Environment 0032-2-7757501 0032-2-7757505 ‘ Peter Schryvers BELGIUM Ministry of the Flemish Community +32 2 208 5234 +32 2 208 5111 Hanne Lorentzen DENMARK Viborg Amt 87 27 14 47 86 62 39 33 Leni Schãrfe DENMARK Building and Environmental Department - Environmental Office 45 39663366 45 39663395 Pekka Jalkanen FINLAND Ministry of the Environment +3589 1991 9100 +3589 1991 9716 Am Karvonen FINLAND Ministry of the Environment +3589 1991 9688 +3589 1991 9716 Markku Hietamaki FINLAND Ministry of the Environment +3589 1991 9703 +3589 1991 9716 OiIi Rahnasto FINLAND Ministry of the Environment +3589 1991 9689 +3589 1991 9716 Erkki Kantola FINLAND Lapland Regional Environment Centre +358 16 329 4491 +358 16 310 340 Leena Ruokanen FINLAND Lapland Regional Environment Centre +358 16 329 4467 +358 18 310 340 Juhani Itkonen FINLAND Lapland Regional Environment Centre +358 16 329 4455 +358 16 310 340 Jean Francois Guerin FRANCE Ministere de lEnvironnement +33 1 4219 1442 +33 1 4219 Pascal Barthe FRANCE Direction Régionale de l’lndustrie, de Ia Recherche et de l’Environnement +33 1 44 59 48 60 +33 1 44 5947 Jorgen Mayer GERMANY Ministerium für Umwelt und Verkehr +49-711-126-2948 +49-711-126-2822 33 33 97 Ulrich Sauerland GERMANY Staathches Umweltamt Duisburg (0203) 33 20 75/ 76 52493 (0203) ‘+301 86 52493 Katenna lacovidou-AnastaSSiadOU GREECE Ministry of Environment Physical Planning and Public Works 86 52493 Paraskevi Xenou GREECE Ministry of Environment Physical Planning and Public Works +301 86 52493 , Patrica Reidy ------- EU/IMPEL EXCHANGE PROGRAM IN FINLAND, JUNE 23 TO 27, IN 1997 LIST OF PARTICIPANTS Name Country Organisatlon Telephone Telefax Guido Palma ITALY National Environmental Protection Agency +369 5007 2866 +369 5007 2856 Francesco Lollobrigida ITALY . Agenzia Regionale per Ia Protezione Ambientale del Piemonte 0039 11 4017 617/628 0039 11 4017 651 Angela Spagnoletti ITALY Ministero deIl’Arnbiente +396 70362313 +39 6 77257005 Paolo Simonetti ITALY Agenzia Provinciale per Ia Protezione delI’Ambiente 0039 (0)4611497760-497761 0039 (0)461/497759 Claude Peters LUXEMBOURG Administration de lEnvironnement +352 40 56 56 241 +35248 50 78 Ana Mana Martins PORTUGAL Direccao Geral do Ambiente +351 1 472 8242 +351 1 471 9074 Miguel Mendez SPAIN Consetena de Medio Ambiente +34 5448 02 04 +34 5448 02 22 Olle BostrOm SWEDEN Swedish EPA +46-8-698 1612 +46-8-698 1585 Robert Domonkos SWEDEN Stockholm County AdmInistration +46 8 785 5132 +46 8 651 5750 Karl-Erik Isaksson SWEDEN Skellefteâ Local Environment Health Board +46 910 735 477 +46 910 775 415 Cornelis P. Boekel THE NETHERLANDS Regional Environment Inspectorate Overyssel +31 38 469 5300 +31 38 469 5330 Henk C Schippen THE NETHERLANDS Ministry of Transport and Watermanagement +31 26 3688247 +31 26 3620322 Wouter B. Tuijnman THE NETHERLANDS Province of Utrecht +31 302582116 +31 30258 3842 Rob Glaser THE NETHERLANDS Roger Fisher UNITED KINGDOM Environment Agency +44 1222 770088 +44 1222 798555 Graham Tate UNITED KINGDOM Environment Agency +44 1302 859121 +44 1302 856115 Richard Ida UNITED STATES OF AMERICA U S EPA, National Enforcement Investigations Center (303) 236-3636 (303) 236-2395 ------- ‘ Environmental Administratior Finland Finlands Environmental Administration was restructured In 1995.As of March I, I 995 ,the former water and environment districts and the environmental units ofthe Provindal State offices (formerly Provincial Governments) were combined Into 13 RegIonal Environment Centres. The National Board ofWater and the Environment Is now known as the Finnish Environment Institute, a centre for environmental research and development. The Regional Environment Centres and the Finnish Environment Institute are under the supervision of the Ministry of the Environment. They are responsible for the use and management of water resources falling within the remit of the Ministry ofAgr CuIture and Forestry, so that each of the ministries oversees legislation relevant to its own sphere of government. The EnvironmentalAdministration employs atotal of 2200 people, of whom 320 work for the Ministry of the Environment, 380 for the Finnish Environment Agency and 1500 for the Regional Environment Centres. The local authorities also have environmental responsibilities. Functions of the Environmental Administration: O oromote sustainable development to further environmental protection and the sustainable use of natural resources to oromote the diversity and vitality of nature to saIe9uard the beauty and cuftural value of the environment to ennance the human milieu and community structure to attend to the use and management of water resources 1.3. 1997 •.......... . .. S S S S S . The Ministry ofthe ‘ Environment is responsible forensunng that the environmental perspective is given proper consideration t all levels of government. society and international cooperation The Ministry formulates environmental policies.conducts strategic planning and makes decisions within its own sphere of interest It is responsible for environmental legislation. related budgetary matters, resuft management and development of standards S • S S • S S • The Finnish Environment Institute _______ conducts environmental R&D It also promotes sustainable develop- ment through monitoring and assessing proposed plans and projects, exercising initiative where required Addrtionally. it is responsible for national environmental research, monitoring the overall state of the Finnish environment, providing an environmental information service and increasing public awareness of environ- mental issues It ensures a uniform stand- ard of environmental protection through- out the country The Environment Insti- tute serves the Environmental Adminis- tration and other clients with its staff of experts . . . . . . Regional Environmnent Centres attend to environmental pro- tection. land use and building, nature conservation, protection of the cultural environment, and the management of water resources The centres compile regional information on the state and use of the environment.This material is also used to meet the needs of nationwide monitonng, research and planning The centres promote environmental aware- ness in their regions ................... ------- Environmental Administration Attachment 2 Finland Environmental expertise : : Regional Environment Centres • work to prevent am water and ground pollution • promote and supervise waste manage- ment and noise abatement • conduct environmental assessments • have permit authority • guide land use planning • provide recreational areas • protect the cultural heritage • do research and help educate • assist in international cooperation • are partners with local groups The Regional Environment Centres safe- guard the public interest in environmental and water matters The versatility of the centres allows them to carry out multiple tasks The centres must ensure that envi- ronmental managementwatersupply and watercourse works are carried out effi- ciently and at the same time strive to foresia l environmental damage They see to me ourchase of land for conservation purposes and provide recreational amen- rties in outdoor areas They grant environ- mental pernirts and supervise compli- ance with their terms The centres act as experts and coordinators in environmen- tal impact assessment, and in land extrac- tion matters they serve as ratification and appeal authorities The preservation of biological diversity has major significance in all this work Other duties include caring for the cultural environment and preserving the cultural heritage The centres guide build- ing and other land use in their areas, ratify plans, grant special permits and act as appeal authorities They provide support for building conservation and more ad- vanced experimental work in environ- mental protection The Regional Environment Centres conduct research and monitor the state of the environment and pollution in their regions Based on data gathered through research, the centres produce and dis- seminate environmental information thus educating individuals and corporations on the environmentThe centres provide support services to their clients on how to improve the state of the environment The centres also participate in inter- national cooperation in Arctic regions and in areas adjacent to Finland They contribute to the preparation and imple- mentation of regional development schemes To qualify for EU financing, all schemes should include an assessment of environmental impacts The Regional Environment Centres work in partnership with municipal envi- ronmental authorities The centres help the local authorities to manage environ- mental matters at the municipal level The centres also work closely with the region- al administration, and other regional par- ties such as businesses, private citizens, research institutes and government, nev- er losing sight of their commitment to the environment The Finnish Environment Institute • researc i on sustainable development, waste management. the prevention of ar .aTe and ground pollution. exploi- :aton aria management of water re- sources nature conservation, land use. anc tne Dust environment • stuces on changes in the environment anc ceterniirration of the causes • prooucjion of up-to-date information on me state of the environment and on riat.Jra resources • upkeep of nationwide information sys- tems and dissemination of information to trie environmental administration arid otner clients • participation in R & D on environmen- tal technology The Finnish Environment Institute works to promote a healthy environment through research With the information produced. it searches forwaysto prevent and solve environmental problems The models and procedures it develops will allow for rapid and reliable environmental assessment of projects The Environment Institute is involved in the preparation of plans and schemes intended to enhance the quality of life in Finland This can be done by ensuring a consistent standard of environmental pro- tection throughout the country Among its official duties at the na- tional level are supervision of chemical and pesticide legislation. monitonng po- tential sources of oil pollution and other sources of environmental damage, and -r supervising the transboundary move- ments of waste The Institute is also re- sponsible for matters relating to permits for the international trade in endangered animal and plant species The Finnish Environment Institute acts as the national contact of the Euro- pean Environment Agency (EEA) and is an international information centre. ft assists in providing information for the preparation and implementation of inter- national agreements and EU legislation. The Institute arranges training for the entire environmental administration It also cooperates closely with Regional Environment Centres. other government authorities, research institutes and univer- sities, businesses and organizations. C C z A cleaner environment through research ‘C ‘C -C ------- Environmental Administration • Regional Environment Centres [[[ Finland I Lapland Regional Environment Centre 2 North Ostrobothnia Regional Environment Centre 3 Kainuu Regional Environment Centre 4 Central Ostrobothnia Regional Environment Centre S West Finland Regional Environment Centre 6 Central Finland Regional Environment Centre 7 North Savo Regional Environment Centre 8 North Karelia Regional Environment Centre 9 South Savo Regional Environment Centre I 0 Southeast Finland Regional Environment Centre II Hame Regional Environment Centre I 2 Southwest Finland Regional Environment Centre I 3 Uusimaa Regional Environment Centre (b ------- Environmental USEFUL ADDRESSES Administration October V996 [[[ Finland REGIONAL ENVIRONMENT CENTRES . • . S S •SS•S•SS S S S S •S S •S SSS• SS S S • 5•SS•• •......SSSS Se S.... S I Lapland Regional Environment Centre 2 North Ostrobothnia Regional Environment Centre 3 Kainuu Regional Environment Centre 4 Central Ostrobothnia Regional Environment Centre 6 Central Finland Regional Environment Centre 7 North Savo Regional Environment Centre B North Karelia Regional Environment Centre 9 South Savo Regional Environment Centre 10 Southeast Finland Regional Environment Centre • Laopeenranta office II Hame Regional Environment Centre • Tampere office • LaN office Street- and postaladdress Phone Koulukatu 19 P0 Box 262 • 65101 Vaasa Kalevankatu 11-13 • P0 Box 156 • 60101 Seinajoki jt .) . . . . . . Fax Hallituskatu 3 • P0 Box 8060 • 96101 Rovaniemi +358 16 3294111 +358 16 310 340 lsokatu9 • P0 Box 124 • 90101 Oulu +358 8 3158300 +358 8 3158305 Kalliokatu 4 • P0 Box 115 • 87101 Kajaani +358 8 61631 - +358 8 616 3629 Tonkatu 40 • 67100 Kokkola +358 6 8279111 +358 6 827 9237 +358 +358 6 3256511 6 3256511 +358 6 3256596 +358 6 3256791 Ailakinkatu 17 • P0 Box 110 • 40101 Jyvaskylã +358 14 697211 +358 14 614 273 Sepankatu 2 B • P0 Box 1049 • 70101 Kuopio +358 17 164 411 +358 17 262 546-4 Tonkatu36A .POBox69 B Ol OlJoensuu +358 13 1411 +358 13 123622 Jaakannkatu 14 50100 Mikkeli +358 5 1911 +358 15 363 915 Kauppamiehenkatu 4 P0 Box 1023 45101 Kouvola Laserkatu 6 53850 Lappeenranta +358 +358 5 7761 5 624 3290 +358 5 371 0893 +358 5 412 0949 BirgerJaarlin katu 3 P0 Box 31 13101 Hameenlinna Rautatienkatu2l B POBox297 33l0lTampere Kauppakatu II C • P0 Box 29 15141 Lahti +358 +358 +358 3 2420111 3 2420111 3 2420111 +358 3 242 0500 +358 3 2420266 +358 3 2420300 ltsenaisyydenaukio 2 P0 Box 47 • 20801 Turku Vaftakatu6 •28100 Pon +358 +358 2 266 777 2 6300700 +358 2 266 1635 +358 2 6300730 +358 9 148881 +358 9 14888295 S S S S • +358 +358 +359 +358 • • S S •S• 9 403000 9 40300100 9 40300201 9 4030 0770 •IS••S.I I • +358 9 40300190 +358 9 40300190 +358 9 40300290 +358 9 4030 0790 . . P0 Box 399 00121 Helsinki Etelaesplanadi 18 Korkeavuorenkatu2l Etelaesplanadi 18 Ratakatu 3 Ratakatu 3 Ratakatu 3 Etelaesplanadi 18 Etelaesplanadi 18 . +358 9 19911 S S • • S • +358 9 1991 9545 +358 9 1991 932J +358 9 1991 9588 +358 9 1991 9631 +358 9 1991 9453 +358 9 1991 9716 +358 9 1991 9602 +358 9 633 106 +358 9 1991 9416 MINISTRY OF THE ENVIRONMENT . MIN!STPY 0 THE ENVIRONMENT • riio’mat,ori • Lanc Use Department • Housing and Building Department • Environment Policy Department • Environmental Protection Department • Unit for International Affairs t • 55••S..I +358 9 1602450 +358 9 1602450 +358 9 1609166 Unit 5 West Finland Regional Environment Centre Seinaloki office 12 Soutriwest Finland Regional Environment Centre Pori office I 3 Uusimaa Regional Envronrnern Centre Asemapaal likonkatu 14 P0 Box 36 • 00521 Helsinki FINNISH ENVIRON S.. 5S FINNISH ENVIRONMENT INSTITUTE • Customer Services • Liora y • inf nàtion MENT INSTITUTE • • I I 555.. •S S •S SeS• 5SSSS Kesakatu 6 P0 Box l40 00251 Helsinki • Administrative Urit MINISTRY OF AGRICULTURE AND FORESTRY S •SSS S SS S SSSSSSSSS S •S•SSISSS•SSSISSSS 55555555 MINISTRY OF AGRICULTURE AND FORESTRY l isankatu 8 • P0 Box 232 • 00171 Helsinki +358 9 1601 ------- |