REA to represent the Biowaste Treatment Sector in the Waste Treatment BREF TWG

The review of the Waste Treatment Best Available Techniques Reference Document (WT BREF) started with the reactivation of the Technical Working Group which resulted, as of today, in an updated provisional list of 124 members.

Kiara Zennaro, Senior Technical Officer at the Organics Recycling Group (REA) sits on the Technical Working Group as a representative of the UK biowaste treatment sector, alongside Tina Benfield (CIWM Biological Special Interest Group). Howard Leberman (EA) is the person appointed to represent the UK Government in the Working Group.

REA will also feed the views of its members through European Compost Network, which has four representatives in the TWG (Adrie Veeken from Attero NL, Frank Schwarz from Veolia Umweltservice West GmbH, Percy Foster from Cré – Composting and Anaerobic Digestion Association of Ireland, and Unico Van Kooten from Dutch Waste Management Association).

What are BREF and BAT?

The Industrial Emissions Directive (formerly the IPPC Directive) requires that all appropriate preventive measures are taken to protect against pollution, in particular Best Available Techniques (BAT) must be used. Thus, use of BAT is required by the regulator when licensing installations under the IED legislative regime. BAT takes into account the balance between the costs and environmental benefits.

BREF is the reference documents for Best Available Technique (BAT), which sets out conclusions on what constitutes BAT for the relevant sector and the emission levels associated with their use.

The revised WT BREF is due to be released in 2016. Once adopted, the industry will have four years to implement its changes. All installations falling under the regime of the IED will need to follow BAT specified in the WT BREF. Departure from the BAT conclusions described in the BREF is possible, if supported by sound evidence showing that the objective of protecting the environment is met.

Timescales for the review of the BREF

The European Commission Joint Research Centre Institute for Prospective Technological Studies (European IPPC Bureau) is leading the review of the Waste Treatment (WT) BREF.

The WT TWG kick-off meeting is likely to take place in November 2013 (e.g. in the week 25-29 November 2013, indicative date).

The deadline for the members of the Technical Working Group to express their initial positions on the WT BREF review is 20 September 2013. The guidelines on how to express initial positions and the role of the TWG can be found HERE.

The timescales for the WT BREF review process are shown below.

Timescales WT BREF Review

Expression of TWG members positions (deadline: 20 September 2013)
Kick-off meeting of the TWG (indicative date: end of November 2013)
Submission of information (deadline will be set)
Elaboration of the first formal draft of the reviewed WT BREF
TWG comments on the first draft
(optional) Elaboration of the second formal draft
(optional) TWG comments on the second draft
Final TWG meeting
Final draft
Presentation at an IED Article 13 forum meeting
BAT conclusions voted at the IED Article 75 committee meeting
Publication of the BAT conclusions in the Official Journal of the European Union
Publication of the BREF on the EIPPCB website (this should be in 2016).

Question – How do I know if my facility falls within the scope of the Industrial Emission Directive and thus, whether the BREF will apply to me?

Answer – You will need to meet the requirements of the IED if your facility falls under the categories below (for non-hazardous wastes):

Biological treatment aimed at disposal of non-hazardous waste with a capacity exceeding 50 tonnes per day (or 100 tonnes/day if only waste treatment is AD) e.g. MBT plants
Biological treatment aimed at recovery or mix of recovery and disposal of non-hazardous wastes with a capacity exceeding 75 tonnes/day (or 100 tonnes/day if only waste treatment is AD) – e.g. composting, AD and MBT.

For hazardous wastes, IED will apply to:

Biological treatment aimed at disposal or recovery of hazardous waste with a capacity exceeding 10 tonnes per day involving one or more of the
following activities.
You can find the meaning of capacity in the EA Guidance RGN.2 Appendix 1.

EA’s Sector Guidance Documents on composting, AD and MBT

Prior to the publication of the WT BREF, any new installation which starts operation will need to comply with IED and the applications will be assessed against the current Best Available Techniques (BAT). The EA is to publish interim industry guidance notes for AD, composting and MBT processes. These will be considered as BATs and reviewed annually and after publication of European BREFs/BATs.

The EA’s sector guidance notes consist of indicative environmental standards of operation and performance. They go into great detail to about how the site should be run to the specified standards and it’s worth emphasising that it is quite prescriptive in places. On top of that, it is very important to note that the sector guidance notes will also apply to all non-IED biowaste treatment operations as they are considered to describe the indicative ‘appropriate measures’ required by environmental permits.

The DRAFT EA GUIDANCE is out for consultation now and deadline for providing comments is 16th September 2013. You can access ths guidance on the Organic Recycling Group website.

Please note that the regulator is planning to feed these guidance documents back into the WT BREF review process.

If you wish to receive a copy of the guidance and want to provide feedback on the content, please contact Kiara ((07717 294793, Kiara@r-e-a.net).

Your feedback is needed

REA will keep its members involved throughout the whole process. Please provide any feedback or comments on the WT BREF to Kiara Zennaro (Kiara@r-e-a.net) or Justyna Franuszkiewicz (Justyna@r-e-a.net).

As mentioned above, as a member of the Technical Working Group responsible for the review of the Waste Treatment BREF, REA will need to express its position on the current WT BREF by 20th September 2013. In order to do that, REA will need your views on the current BREF.

We would be grateful if, by 30th August, you can read the WT DRAFT BAT CONCLUSIONS ~ GUIDELINE DRAFT FOR THE EXPRESSION OF INITIAL POSITIONS and let us know:

- if any relevant information is missing;
- if you can see any showstoppers;
- if you can provide evidence in relation to any of the green text;
- if you know of any emerging or established techniques that have been missed out (in the event you do, please provide associated detail);
- if you disagree with any of the BAT conclusions;
- if you wish to propose any amendment to the text.

Please note that in the document the text in black represents items derived from the BAT conclusions in the currently adopted WT BFEF and the green text describes additional proposals made by the JRC-IPTS. Please find it on the ORG website

BAT Conclusions for biological treatments are stated in part 1.3 on pages 34-41. BAT conclusions specific to aerobic treatment are described at pages 34 – 37; those specific to anaerobic digestion are described at pages 38-41.

These include:

General environmental performance;
Emission to air & emission levels;
Odour;
Water consumption and emission to water; and
Energy efficiency.

Please note that the BAT conclusions under these sections refer to BATs in previous sections of the document.

Source: Biogas

For more information on: Biogas