For our Environment

Legal Framework for Best Available Techniques (BAT) Reference Documents

Refresher course 17.06.2019, Delhi

Brigitte ZietlowAlmut ReichartFederal Environment Agency

Content

1. Basic approaches to conserve and to improve environmental

quality

2. Legal Framework: Industrial emission directive

3. The concept of best available techniques

4. How to implement the BAT Conclusions

5. Permitting – supervision – enforcement

6. Conclusions

Basic approaches to conserve and

to improve environmental

quality

3

The three columns to air pollution control in the EU

4

Water management = Managing conflicting interests

5

Habitat for flora and fauna,

Biodiversity

Source of drinking water

Receiving waterbody

for discharges

Economic growth

Politics

Regulation and standards

Economic incentives

Water quality norms

Water Framework

Directive

Sector specific emission limits

for waste water discharges

based on BAT

Legal Framework:

Industrial emission directive

6

Industrial Emissions Directive 2010/75/EU (IED)

Common framework and key instrument for the regulation of

industrial emissions throughout the 27 EU Member states

Objectives:

• to prevent, to reduce and as far as possible to eliminate pollution arising

from industrial activities

• based on the ‘polluter pays’ and the precautionary principle

• to achieve a high level of protection for the environment as a whole in the EU

by aligning the environmental standards for industrial installations

Main provisions of the IED (I):

• All relevant industrial installations in the EU as listed in Annex 1 IED

need an integrated environmental permit

e.g. power plants, metal production, cement and lime production, chemical

industry, waste incineration, waste treatment, paper production, intensive

livestock rearing, textile industry (in total: 55.000 installations in the EU)

• The permits shall include:

• Emission limit values (ELVs) or equivalent parameters or technical

measures ensuring an equivalent level of environmental protection

• Requirements for emission monitoring, for regular maintenance as well

as for other than normal operating conditions

• conditions for assessing compliance with the emission limit values

Main provisions of the IED (II):

• ELVs shall ensure that emissions under normal operating conditions do not

exceed the emission levels associated with the best available techniques as

laid down in the decisions on BAT conclusions

• The permit shall not prescribe the use of particular techniques, but the level of

environmental protection that can be achieved by application of BAT

Best = most effective with respect to the prevention of emissions

and the impact on the environment as a whole

Available = developed on a scale which allows implementation in the

relevant industrial sector, under economically and

technically viable conditions

Technique = includes both the technology used and the way in which the

installation is designed, built, maintained, operated and

decommissioned

• Permit requirements shall be based on the Best Available Techniques (BAT)

Main provisions of the IED (III):

• Public participation in the permitting of installations

• New plants or substantial changes

• Update of permits

• Derogations

• Closure of plants

• Public access to information

• Publication of permits, site inspection reports, monitoring results

• Reporting obligations for the Member States

• on how they implemented the Directive

• includes representative data on permit requirements such as ELVs

Public participation increases transparency and contributes

to public awareness

11

The concept of best available

techniques

12

Information Exchange on BAT

• The IED requires an information exchange on best

Available Techniques (BAT) addressing:

− the performance of installations and techniques in

terms of emissions and consumptions, etc.

− the techniques used, associated monitoring,

economic and technical viability, etc.

− best available techniques identified after considering

all the issues concerned (like economic and technical

viability, solution for key environmental issues..)

− Outcome of the process is a comprehensive

technical document, the BAT reference Document

(BREF)

− Chapter 5 ‘BAT conclusions’ is the core part of the

BREF, specifying what is generally considered as

BAT for installations within the sector

13

EU Member

States

Industry

EU

Commission

Environmental

NGOs

BAT Reference Documents for

the sector (BREF)

BAT conclusions

Data on installations

(technical

descriptions,

Emission data…)

The content of BREFs and BAT conclusions (I)

General outline of the BREFs:

Preface, Scope

1. General information about the sector concerned

2. Applied processes and techniques

3. Current emission and consumption levels

4. Techniques to consider in the determination of BAT

5. Best available techniques (BAT) conclusions

6. Emerging techniques

7. Concluding remarks and recommendations for future work

References, Glossary of terms and abbreviations

Annexes (dependent upon relevance and availability of information)

14

The content of BREFs and BAT Conclusions (II)

Chapter 4 provides a lot of information on each Technique:

• Technical description

• Achieved environmental benefits

• Environmental performance and operational data

• Cross-media effects

• Technical considerations relevant to applicability

• Economics

• Driving force for implementation

• Example plants

• Reference literature

15

The content of BREFs and BAT Conclusions (III)

Chapter 5 “BAT conclusions” is the core part of BREF

containing:

•the choice of techniques identified as BATs, including emission

levels associated with BAT, associated monitoring, associated

consumption levels, and, where appropriate, relevant site

remediation,

•concise description of techniques,

• information to assess their applicability,

→ formal adoption of “BAT conclusions” as secondary

legislation by Commission

→ Commission Implementing Decision

16

BAT is about real plant performance

Example: Waste water treatment in the chemical sector

17

0811

8

34 113

01 86

62 85 75

0790

40 87 54 33 11 41 64 19 91 60

53

89 111 51 70 82

100

29 74 8348 37

101 4757

114

18

25

61 03

98

63 67

02 84 93 96 21

49 92 10 45

041

27 50

17

80

042

117

105

73

95

32 94 79 115

120 11

6

119

121

Ultr

afU

ltraf Sed SF

Filtr

NI

Filtr SF

Sed S

FN

IS

ed Sed Sed N

IN

IS

ed Flot

Sed Sed NI

Sed Sed Sed N

IN

IS

edS

ed Flot Flot

SF

Flot

Sed Sed Flot

Sed

Sed Sed Flot SF

Sed N

IFl

ot SF

Sed SF

Sed N

IS

ed Flot

Sed N

I Sed Flot

.S

edS

edN

IS

edFl

ot NT N

I NI

Sed Sed

NI

Sed S

edN

IS

edN

I Sed

Bio

Bio

PC

Bio

PC

PC Bio Bio Bio

Bio

Bio P

C Bio Bio

PC

PC

PC Bio

Bio

Bio B

ioP

CB

io PC Bio PC

Bio

Bio

Bio

Bio

PC Bio

Bio PC

Bio Bio

PC Bio

Bio P

CB

ioB

io Bio

Bio P

CP

C Bio

PC

PC Bio

Bio P

C Bio Bio Bio

Bio P

CB

ioB

io PC

Bio B

io Bio Bio

Bio Bio

Bio

PC

Bio

PC B

io

0

50

100

150

200

250

300

0 5 10 15 20 25 30 35 40 45 50 55 60 65 70

TSS

(mg/

l)

Number of WWTP

Effluent values not shown in the graph:

< LOD: #69 (Bio)

< 5 mg/l: #36 (Bio)

BAT-AEL: 5 – 35 mg/l (yearly average)

Abbreviation Meaning

Bio Biological treatment

Filt Filtration (includes MBR and sand filtration)

Flot Flotation

NI No information provided

PC Physico-chemical treatment only

Sed Sedimentation

SF Sand filtration

Ultraf Ultrafiltration

BAT is about 10-20 % best performersExpert judgement of the technical working group to conclude on BAT

How to read the BREF documents?

• If you look for general information on the sector

→ Start right from the beginning and benefit from the valuable

information provided in whole BREF

• If you look for technical solutions for a special issue

→ Start in the corresponding section of Chapter 4, where the

‘Techniques to consider‘ are presented

• If you are interested in environmental standards in the EU

→ Start with the corresponding BAT conclusions in Chapter 5

If you want more information on the techniques mentioned in

Chapter 5, look for the corresponding information in Chapter 4

18

Deriving BAT conclusions is acomplex consensus

building process but it is worth it:

• Information exchange with stakeholders

and focus on applicability will lead to higher

acceptance and overall implementation of

environmental standards

• Improvement of performance of a specific sector as a

whole → level playing field

• Reduction of environmental impact of the sector

• Gives solutions for different scales of industry

• Integrated solutions improve the efficiency of

installations and also of product quality → therefore

better competetiveness of Industry

19

How to implement the BAT

Conclusions

20

How to implement the BAT Conclusions?

• In general, the BAT Conclusions have to be transposed to permit

conditions by the Competent Authorities

• In order to facilitate the granting of permits, Member States may set

requirements for certain categories of installations in general binding

rules (Art. 6 + 17 IED)

−General binding rules shall also be based on the best available

techniques, without prescribing the use of any technique or specific

technology

−General binding rules have to be updated to take into account

developments in best available techniques

21

How BAT Conclusions are implemented in Germany

• Germany implements BAT via general binding rules, e.g.

» the Federal Pollution Control Act and its subordinated Ordinances

as well as the ‘Technical Instructions for Air Quality Control’ (“TA

Luft”)

» The ‘Waste Water Ordinance’

• The competent authorities will then transpose the requirements from

the general binding rules into the permits, as far as they are relevant

for the installation in question.

• For existing plants, permit requirements can be changed by

subsequent order.

• Germany established standard procedures to update its general

binding rules when new BAT conclusions are published.

22

23

▪ Within one year the Federal Environment Ministry together with UBA

and Federal States Experts carry out a comparison with existing

legislation

→ New legally binding regulations for concerned media

✓ Water water ordinances and its annexes for industrial sectors

✓ 13th, 17th ordinances and TA Luft

✓ Other affected permits for all installations of the sector

▪ Local competent authorities check the existing permits for all

installations of the sector

→ Issue of new permits (if necessary) by local authorities

→ Technical adaptation to new permit conditions (by Owner or

operator)4 Years

Transposition of IED and BAT conclusions into national legislation

How to implement the BAT Conclusions?

24

BAT conclusions whitout BAT AELs

General requirements Annex 25 waste water ordinance

The use of clean hides or skins; Processing fresh hides or skins

Storing the hides and pelts at low temperature

- Using non-denaturised salt

Shaking off loose salt from hides by mechanical means

Retaining brine from skin curing via suitable techniques such as dry disposal or returning to production

The use of short floats

Hair-save unhairing

Reduced ammonium use during deliming

…

Parameter BAT-AELs in mg/l (monthly average values based on

the average of the 24-hour representative composite

samples taken over a month)

Emission limit value Annex 25 waste water

ordinance in mgl/l (qualified random sample

or 2-hour composite sample)

COD 200-500 ( 1 ) 250

BOD 5 15 - 25 25

Suspended solids < 35

Ammoniacal nitrogen NH 4 -N (as N)

< 10 10

Total chromium(as Cr)

< 0,3-1 (in the combinedwaste water stream)

1 (in waste water streamfrom soaking, liming and

deliming)

Sulphide (as S) < 1 (in the combined wastewater stream)

2 (in waste water streamfrom tanning and from wet

finishing)

Total phosphorous 2

Adsorbableorganic halogens(AOX)

0,5

Toxicity to fish eggs (Tegg)

2

( 1 ) The upper level is associated with COD inlet concentrations of ≥ 8 000 mg/l.

Example: updating of the German waste water ordinance annex 25

(leather industry)

The Waste Water Ordinance

Appendix 38 Textile manufacturing and finishing

▪ Section A – Scope of application

▪ Section B – General requirements

▪ Section C – Requirements for waste water at the point of discharge

▪ Section D – Requirements for waste water prior blending

▪ Section E– Requirements for waste water for the site of occurrence

▪ Section F – Requirements for existing discharges

The Waste Water Ordinance

Appendix 38 Textile manufacturing and finishing

Textile

mill

Waste water partial streams

Indirect discharge via

municipal waste water

treatment plantDirect discharge after

treatment in the plant

Textile substrate

Textile product

Input substances(Dyes, basic chemicals,

textile auxiliaries)

Total waste water stream

Section C: Requirements

for waste water at

the point of discharge

Section D:

Requirements for waste

water prior blending

Requirements for certain highly polluted partial

streams in section B, D and E:

Section B: e.g. Minimisation of amounts, retention

or reuse of left-over finishing padding baths

Section C: e.g. Requirements for waste water

containing petroleum-derived hydrocarbons

Section E: e.g.Waste water may not contain Left-

over printing pastes

Requirements on finishing processes in

Section B: Avoidance of use of chlorinating

pressure-pre-treatment for wool

Requirements for input

substances in section B and E:

Section B: e.g. restrictions for

certain surfactants , APEO

Section E: e.g. waste water

may not contain EDTA

Section B: Requirements

for sizing agents

The Waste Water OrdinanceAppendix 38 Textile manufacturing and finishing

PARAMETERQualified random sample or

2-hour composite sample

COD 160 mg/l

BOD5 25 mg/l

Phosphorous, total 2 mg/l

Ammonium- nitrogen 10 mg/l

Total nitrogen 20 mg/l

Sulfit 1 mg/l

Toxicity to fish eggs 2

Colour

7 m-1 (436 nm, yellow)

5 m-1 (525 nm, red)

3 m-1 (620 nm, blue)

C Requirements for waste water at the point of discharge

D Requirements for waste water prior to blending

PARAMETERQualified random sample or

2-hour composite sample

AOX 0.5 mg/l

Sulphide 1 mg/l

Chromium, total 0.5 mg/l

Copper 0.5 mg/l

Nickel 0,5 mg/l

Zinc 2 mg/l

Tin 2 mg/l

Dilution with fresh

water is not allowed

28

Permitting – supervision

– enforcement

28

29

Legal approach in Germany in order to ensure the integrated permit

▪ permit covers all legal fields and allowances which might effect the

environment (even if only partly, maybe overlapping issues)

▪ permit covers construction and operation, because some aspects of the

construction are connected to environmental issues

▪ Competent authority is obliged to fully coordinate of permit procedure

and permit conditions to be set out

✓ all documents are collected and distributed by one authority

(“concentration”)

✓ all problems are managed by one authority! (“one face to the

customer”)

Licensing Procedure

29 35

30

Integrated permitting

• Gives priority to intervention at source (process-integrated measures) but

also include abatement techniques

• Covers main activities of the installation including directly associated

activities carried out on the same site and which have a technical connection

with the main activity and could have an effect on emissions

• Integrates major issues into one permit

• Site-specific issues are taken into account

31

Competentlocal authority

Immission Control Act

City administration:

Fire and civilprotection agency

Department

Nature protection

NGO’s

City administration:

Building department

City administration:

Local health

agency

Measures for noise

abatement

(approved consultant)

Safety report

(approved consultant)

Department

Occupational health and

safety

City administration:

planning departement

Department

waste management

Department

Water and waste water

Cooperation with responsible authorities, consultants and NGO‘s

(“one face to the customer”)

Licensing Procedure

36

32

Structure of a permit

1. General (including definition of the subject permitted)

2. Construction licence

3. Fire prevention

4. Occupational Safety and Health

5. Air pollution control

• Emission limit values

• Conditions of measurements

• Requirements for malfunctions etc.

6. Environmental technical safety

32

Licensing Procedure

37

33

7. Noise protection

8. Wastewater

• Emission limit values

• Conditions of measurements

• Requirements for malfunctions etc.

9. Protection of soil and groundwater

10. Waste

11. Nature protection

12. Definite cessation

13. Legal reasons for the permit and the conditions

Annex I: Technical rules to be considered

Annex II: The submitted documentation of the installation (application documents)

33

Licensing Procedure

38

34

• In principle discharge of any waste water into a water body is banned

• The ban can be lifted by a permit under water law for a particuliar

purpose and duration

• The permit can be granted by the competant authoities under following

conditions:

1. Compliance with environmental quality requirements

2. Implementation of best available techniques to prevent/reduce

the pollutant load as far as possible (precautionary principle) →

site independent

3. Compliance with requirements for waste water treatment plants

and sewer systems

Permit under water law in Germany

35

Aims and purposes of environmental inspections

• Competent authorities shall control the compliance of permits and shall intervene in case of non-compliance.

• Environmental Inspections are an indispensable means to implement and to enforce environmental law, and hence to achieve a high level of environmental protection.

Purpose of inspections including on-site visits:

• to check if the requirements laid dawn in the permit or in general binding rules (e.g. application of BAT) are met in day-to-day operation

• to monitor the impacts of an installation on the environment and on people, in order to initiate additional measures, if required

‘Environmental inspection’ means all actions, including

→ site visits,

→ monitoring of emissions and checks of internal reports

→ verification of self-monitoring,

→ checking of the techniques used and adequacy of the environment management of the installation

36

Criteria for scheduling periodic environmental inspections

• all installations are covered by an environmental inspection plan

• Potential risks:

− General environmental relevance

− Accident risk from dangerous substances

− Transfer, use or storage of waste

• Actual environmental relevance:

− Emission sources and their actual level

− Quality and sensitivity of the environment

− Incidents and accidents

• Operator-related criteria:

− Compliance with permit requirements

− Operator‘s willingness for cooperation/compliance

− Adherence to an Environment Management System

→ Criteria determine the inspection frequency (1−3 years)

Genehmigungsbescheid

AZ: 53.8851-16- 03513

Bezirksregierung Köln

GenehmigungsbescheidAZ: 53.8851-16- 03513

37

The inspection report

After the on-site visit, relevant results are fixed in the inspection report:

• evaluation of the current installation condition,

• compliance or non-compliance with permit-obligations and/or with national legislation,

• Summary of the tasks resulting from the inspection,

• fixing or modification of obligations for the operator,

• The basic results of the inspectionhave to be published on thewebsite of the competent authority, about 2 months after the on-site visit

Published report

from inspection of sinter plant

38

Consequences of non-compliance

Minor deficiency Substantial

deficiency

Serious deficiency

Written request

Competent authority demands to correct the

deficiencies within a certain time; No fine

Regulatory offence

Competent authority sets the fine (up to

50.000 €); possible objection at civil court

Criminal offence

The competent authority hands over the

issue to the prosecution service; court

hearing; Fine or even prison term

Restoration of complianceInterdiction of plant

operation?

non-observance

non-

observance

39

Conclusions

39

40

Conclusions

• The IED sets up an integrated framework for the regulation of industrial emissions in the EU,

aiming for a high level of protection for the environment as a whole

• BAT is a dynamic concept based on and promoting continuous improvements in environmental

performance, in order to improve the quality of life in the regions concerned

• Well-founded, consistent environmental standards provide reliability for plant operators and

their investments, and help to create a level playing field for the companies

• Various techniques to reduce the environmental impact of industrial installations are available

as they are described in the EU BAT documents

• BAT is more than the application of specific technologies; good housekeeping, maintenance,

input control and a proper monitoring system for the emissions are also relevant as efficient

means to reduce emissions and to improve production efficiency

40

41

Conclusions

• In order to achieve real improvements, permit requirements such as emission limit values need

to be complemented by adequate monitoring, inspections and “incentives” for compliance

• Harmonisation of environmental standards helps to improve the quality of life in the regions

concerned and to create a level playing field for the companies

41

Oct. 2017 Workshop in Lahore 42

Thank you!

Brigitte Zietlow

brigitte.zietlow@uba.de

Almut Reichart

almut.reichart@uba.de

Main provisions of the IED (II):

• Reconsideration and updating of permit conditions within 4 years of

publication of decisions on BAT conclusions

(a)all the permit conditions for the installation concerned shall be

reconsidered and, if necessary, updated to ensure compliance with

the Directive, in particular regarding the emission levels associated

with BAT;

(b) the installation complies with those permit conditions.

• BREFs shall be revised and updated at least every 8 years

The IED provides for a continuous updating of permits and

hence, if neccessary, retrofitting of installations!

43

.

Criteria for determining best available techniques –

(Annex III of the IED)

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;

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 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

44

Permitting – supervision – enforcement

New development in BAT

Substantial change of operating conditions

47

Contents of a permit

Descriptive section

• Installation and its activities (primary or process-related techniques, secondary or end-of-pipe techniques, …) ;

• Raw and auxiliary materials,

• Sources of emissions (e.g. stacks characteristics, …)

• Conditions of the site of the installation

• Comparative analysis of the actual performances of the installation with the relevant BAT and related BAT-AELs

Prescriptive section

• ELVs (or equivalent measures) for all the significant pollutants;

• Conditions for assessing compliance with the ELVs

• Measures relating to other-then-normal conditions (e.g. start up/shut down operations, leaks, malfunctions, …)

• requirements concerning monitoring of soil and groundwater (in relation to relevant hazardous substances)

Monitoring andControl Plan

• Emission monitoring Requirements(e.g. measurement methodology, frequency and evaluation procedure)

• Obligation to supply the competent authority (annually) results of predefined selected monitoring and control data

48

General requirements for emission monitoring

• General requirements for emission monitoring are laid down in the

environmental law

• The requirements have to be substanciated in the environmental

permit(s) and in official monitoring plans

• In general, emission monitoring is mandatory for every pollutant or

parameter for which an emission limit value is specified in the permit

• It has to be specified by whom and how frequent emission monitoring

and supervision has to be carried out :

→ Self-monitoring

→ Supervision by administrative staff or officially mandated measurement

services

49

General requirements for emission monitoring

• To achieve comparability of results reference conditions have to be

specified in monitoring requirement, e.g:

• Parameters and units,

• Sampling and analyzation method,

• Frequencies,

• Averaging periods, e.g. half-hourly or daily average value

• Point of reference

• Reference conditions for the measurement, e.g. temperature, gas pressure, wet

or dry gas, oxygen content in waste gas

50

Emission monitoring regimes in Germany

In Germany regimes for self monitoring of emission differ according torelevance:

• Most relevant air pollutants have to be monitored continuously, iftheir permitted mass flow exceeds certain relevant threshold valuesaccording to the hazardousness of the substance:

→ Dust→ 3 kg/h,

→ SO2 → 30 kg/h,

→ Mercury →2,5 g/h

• ELVs are specified as daily averages.

• Periodic measurements of air pollutants with lower mass flow areonly carried out once per 1 to 3 years,

→ have to be carried out under the worst operational conditions, e.g. fullcapacity operation

→ no measurement value shall exceed the ELV.

51

Preparation of the environmental inspection

The inspection team has the following tasks:

• to collect and evaluate as much information as suitable

about the company, their operating installations, the

environment conditions and the working conditions

• to study the permit including application documents of

the installation as well as former inspection reports,

• to check measurement reports and operator

documentations,

• to prepare appropriate checklists for inspection, which

cover the relevant points

52

On-site visit

• Verification whether the permit and the documents examined for

preparation are consistent with observations in the installation. Key

tools are the checklist and layout plans.

• Collection of relevant data on the current condition of the plant,

including photos. Physical impressions (odour, noise) may also

provide useful information.

• The inspector may take samples, for example of discharged waste

water, waste materials or unknown materials.

53

Occasions for environmental inspections

• Inspection procedures starts as soon as the permit is issued (during

construction of the installation and before starting routine operation)

• Inspection in the light of current events, e.g.

→ complaints by neighbors

→ indications for non-compliance or excessive pollution

→ recent incidents or accidents

• Periodic environmental inspections (all 1 to 3 years)

54

Interdiction of plant operation

• The competent authority (CA) may interdict plant operation for the

time needed to restore compliance with permit requirements.

• The CA has to interdict plant operation if:

→ the deficiencies mean an immediate hazard to human health or a severe

hazard to the environment or

→ measures of the operator to prevent hazardous incidents according to

the relevant regulation are not sufficient

• The CA shall order to decommision and to remove plants that have

been erected, modified or operated without an adequate permit

• The CA may also interdict operation of a plant by certain people

known for their unreliability. The CA may allow the beneficiary of the

permit to hand over the operation to other people considered reliable

to operate the plant in due form

55

Revocation of environmental permits

• Permits according to the German Immission Control Act are revocable

if:

a) the beneficiary does not comply with permit requirements within a

reasonable time

b) given the actual circumstances, the competent authority would have

refused the permit

c) the revocation of the permit is in public interest, in order to avoid

substantial harm for the common welfare

• Revocation may affect part of the permit or the permit in total

• Beneficiary of the permit may claim for compensation for financial

losses caused by trust in the persistence of the permit

56

Waste Water Levy Act

56

▪ Discharger of waste water has to pay a levy to the country.

▪ Levy depends on the emission concentration of (COD, P, N, AOX,

Hg, Cd, Cr, Ni, Pb, Cu and Gei as well as on the amount of yearly

waste water

▪ Calculation of emission units (EU) 1 EU = 35,79 EURO

e.g. 1 EU equals 50 kg CSB

1 EU equals 3 kg P

1 EU equals 2 kg AOX (calculated as Cl)

1 EU equals 100 g Cd

▪ Determination of emission units is based on the permitted values of

the waste water permit.

▪ Investments into waste water treatment with reduction of emissions

by >20% may be set off against this levy of the last three years.

Comparison of BAT- Conclusions with national binding rules in Germany

… not included in national requirements

so far

Additional national requirements have to be definded according to the BAT conclusion

BAT conclusion…

… are more demanding than national requirements

National requirements have to be revised in order to comply with

BAT

… are on equal level or less demanding than

national requirements

National requirements stay as they are

How to implement the BAT Conclusions?

A – Scope of application

B – General requirements

• The contaminated load must be as low as possible by applying the following measures, as revealed

by examination of the relevant individual case:

• Processing and reuse of the wash water from the printing plant that is used for washing printer's

blankets and for cleaning printing equipment…,

• Avoidance of use of hardly biodegradable/bioeliminable synthetic size products and surfactants.

• Avoidance of use of hardly biodegradable organic complexing agents…,

• Avoidance of use of chlorinating pressure-pre-treatment of wool and mixed-wool substrates,

• Avoidance of use of alkylphenol ethoxilates (APEO),

• Minimisation of the amounts, and retention or reuse, of synthetic size products from desizing and

of left-overs from dye liquors, finishing padding baths, …

• …,

• The prove of compliances with the general requirements has to be documented

− in an operational logbook (showed to authorities during inspections)

− in an annual performance report send to the competent authority

58

The Waste Water OrdinanceAppendix 38 Textile manufacturing and finishing

E – Requirements for waste water at the site of occurrence

• The waste water may not contain:

− Organic chlorine carriers (dye accelerators),

− Chlorine-separating bleaches, except for sodium chlorite for bleaching of synthetic fibres,

− Free chlorine from the use of sodium chlorite,

− Arsenic, mercury and their compounds, or organic tin compounds from use as preservatives,

− Alkylphenol ethoxilates (APEO) as washing and cleansing agents,

− Chromium VI compounds from use as oxidants for sulphur dyes and vat dyes,

− EDTA, DTPA and phosphonates from use as water softeners in process water,

− Unused, left-over amounts of chemicals, dyes and textile auxiliaries and

− Left-over printing pastes in printing equipment, from printing.

• The waste water may contain only approved halogenated solvents.

• The concentration of chromium VI in the waste water may not exceed a level of 0.1 mg/l in the

random sample.

• Proof of compliance may be provided by listing the operating and auxiliary substances used in an

operating log book and presenting manufacturers' information showing that these do not contain any

of the substances or substance groups cited above.

59

The Waste Water OrdinanceAppendix 38 Textile manufacturing and finishing