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Which FD&M producers will be affected by the Industrial Emissions Directive?

Frank Wayman

05 Jul 18

This is the second 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? (You can read the first here). In this post Frank explains which FD&M producers will be affected by the IED and what emission level targets they will be subject to.
 

Will all FD&M producers be affected by the IED?

No, not all FD&M producers will be affected by the IED, the thresholds for compliance depend on several factors such as the product being made by the installation and the quantities. Some examples can be found on the table below:

Will all FD&M producers be affected by the IED?

These producers will therefore be subject to targets on emission levels (BAT-AELs) obtained under normal operating conditions using a best available technique or a combination of best available techniques.

The table below shows the new BAT-AEL targets for effluent discharges for direct emitters to the environment. Indirect discharges (i.e. to the sewerage network) will have to meet an equivalent standard, and by following the “polluter pays” principle, will have to prove that their treatment downstream (in a municipal sewage treatment works, for example) is effective in reaching the limits given here.

subject to targets on emission levels (BAT-AELs)

These limits will represent some challenging targets for emitters and although they have not been firmly confirmed (BREF document is still a draft version), it indicates that is likely that every producer is going to need to take more control over their processes to achieve these targets.
 

Are there specific emissions limits based on output?

Yes, there will be specific limits based on production output. For example, for a given volume of beer produced and bottled by an installation, there will be a specific limit on effluent volume written into the permit. In the table below, taken from the FDM BREF, data collected from large installations across Europe was analysed and compared.

Are there specific emissions limits based on output?

Overall and as seen on the table, the least efficient breweries use 4 times as much water per hectolitre of beer as the most efficient ones (not counting what goes into the product). Environmental regulators may refuse to grant permits or include improvement conditions in the permits if an installation exceeds the maximum figures for specific uses, because they will be considered to be failing the BAT benchmark.

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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