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What is the FDM BREF and how should your approach your BAT assessment?

Frank Wayman

17 Jul 18

This is the third blog post by Dr Frank Wayman PHD taken from his recent e-book, How will the EU Industrial Emissions Directive impact the Brewing and Drinks? (Read the first and second posts here). In this post Frank examines the case for using BREF guidance and how you should approach your BAT assessment.

 

Why use the BREF?

Using the BREF guidance document is in every business’ best interests. Site operators should use this to assess whether their operations are BAT (Best Available Technique) and whether they can meet the BAT-AELs (emissions limits).

Operators who are in any doubt that they can raise the necessary funds to achieve compliance should start sooner rather than later; the UK’s environmental regulators generally respond better to early warnings of non-compliance rather than last-minute attempts to avoid legal action.

If they are not BAT, or cannot meet the BAT-AELs with their current techniques, operators will need to either invest in new techniques or apply for a derogation.

Operators can expect regulators to be more interested in the manufacturing process, rather than just the output. For example, in the graph below, data shows how regulators across the EU have compared the specific water use per hectolitre of soft drinks product for 10 different production sites. The installation represented by the column on the right-hand side discharges nearly ten times the volume of its product as effluent and is not considered to be compliant with this legislation.

 

Specific wastewater discharge

How should BAT processes be determined?

The Directive includes a description of how BAT processes are to be determined. These are:

1. The use of low-waste technology;

2. The use of less hazardous substances;

3. The furthering of recovery and recycling of substances generated and used in the process and of waste, where appropriate;

4. Comparable processes, facilities or methods of operation which have been tried with success on an industrial scale;

5. Technological advances and changes in scientific knowledge and understanding;

6. The nature, effects and volume of the emissions concerned;

7. The commissioning dates for new or existing installations;

8. The length of time needed to introduce the best available technique;

9. The consumption and nature of raw materials (including water) used in the process and energy efficiency;

10. The need to prevent or reduce to a minimum the overall impact of the emissions on the environment and the risks to it;

11. The need to prevent accidents and to minimise the consequences for the environment;

12. Information published by public international organisations.

BAT Assessment

Who can help?

Specialists such as Alpheus have been working with other industry sectors on these issues and can assist with preparing BAT assessments and delivering solutions.

In the case of a BAT assessment, it will be necessary to carry out a site survey that can gather representative data from all processes. This will involve the installation of data logging and sampling equipment throughout the site if these are not already in place. The data will then be assessed alongside design information and production rates where applicable.

Using our experience with effluent treatment we will be able to determine not just whether a process is compliant, but whether it can be brought into compliance, and how that can be achieved in the most cost-effective way. Based on this assessment, decisions will no doubt have to be made about the best method of compliance for the organisation. This may mean the relocation of certain processes between sites and the installation or upgrade of treatment equipment.

BAT Assessment

Opportunities to save money

Some of these ideas are not just environmental measures but could offer the opportunity to reduce costs. FD&M producers will have to seriously look at these options if they want to maintain their compliance with regulations while remaining competitive.

Once decisions are made, these proposals will need to be agreed with the environmental regulator, who will then need to write and sign a new operating permit (this must happen within four years of publication of the BREF). For the food and drinks industry, publication is expected in the autumn of 2019. Realistically, all FD&M installations should have a new permit to operate from their environmental regulator by the autumn of 2023 at the latest.

Alpheus has years of experience on environmental permitting regulations. Not only can we advise on the type of technology that will bring a site to compliance, but we can also support producers to liaise with the regulator and complete all of the necessary steps required to apply for a new permit or variation of the existing permit conditions. Contact us for an informal discussion about your requirements.

You can read more about the IED and its impact on the brewing and drinks sector by downloading the complete e-book.

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