REA response to the first draft of the BREF
The JRC published the first draft of the revised Best Available Techniques (BAT) Reference Document for Waste Treatment (WT BREF) just before Christmas 2015. This covers both composting and anaerobic digestion along with other waste treatments. (As a reminder the BREF is a European Commission document and when it is published it will be the BAT conclusions that all AD and Composting sites (operating as installations or with PPC permits, i.e. over 100t/day for AD or over 75t/day for composting) have to comply with).
We circulated the draft BREF to our members for comments, thanks very much to all those who provided feedback. We also sit on the biological treatment sub group set up by the JRC and attended a meeting in January to discuss the draft (info here). Comments from members were incorporated with feedback from the sub-group and comments from the UK regulators and a draft ORG response was circulated to members.
Following a few further comments, the final REA ORG comments were uploaded directly as a technical working group member by the deadline of 18th March 2016.
The comments mainly focused on Chapter 4 - Biological Treatment and Chapter 6 - BAT conclusions. Some of the issued raised were:
- Clarity needed on definitions of some terms used throughout the document.
- Some of the associated emission levels for emissions were questioned as they seem to be derived from limited data, particularly for emissions to air with AELs for NH3 and H2S.
- Emission monitoring frequency, parameters and methodology not appropriate for all facilities.
- Clarity needed regarding requirements for waste water as some confusion around direct emissions and emissions to further treatments.
- A risk based approach was recommended for requirements for odour monitoring and management and for containment requirements.
We expect the Commission will release a further (possibly final) draft towards the end of the year and we will provide further updates when available. If you would like any further information, please contact Jenny Grant.
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