Following the submission of a response to the first draft of the Waste Treatment BREF (Best available techniques reference document) earlier this year, ORG are continuing to be involved in the review process.
Since the last update, the IPPC Bureau held a series of webinars to discuss the data that was used to derive the Associated Emission Levels (AELs) for the emissions to air and water. The Bureau made the data available but after analysis it was not clear how the AELs were derived and the Bureau did not provide any background detail so we do not know what data has been questioned and subsequently ruled out (i.e. mistakes in the recording, or results not representative of usual operations).
In advance of the webinar ORG met with the EA and other trade bodies to discuss the proposed emission levels for emissions to air and water from biological treatment. We circulated a summary of the proposed requirements to members and invited feedback to help prepare our input into the webinar. ORG joined the webinar on biological treatment. Data, omissions and corrections were the key discussion points during the webinar and one of the repeated comments to the Bureau was the apparent disconnect between the data and the AEL proposals. In addition, it was suggested that the current proposal for NH3 and H2S as AELs for emissions to air but these are operational parameters could be replaced with the requirement to monitor Odour.
The Bureau plan to release revised proposals for the BAT conclusions early January 2017 together with a Background Paper. This will set out how the main comments received on Draft 1 (D1) of the WT BREF have been accounted for and how the draft BAT conclusions could be revised. We will be given the opportunity to provide feedback on both documents (i.e. revised draft BAT conclusions and Background Paper) prior to the Final TWG Meeting.
The revised draft BAT conclusions will then be discussed at the Final TWG Meeting - March 2017 (tentative).
If you would like any further information on any of the above, please contact Jenny Grant (email@example.com).