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 (jenny@r-e-a.net).