Annual Guide 2021 I SOURCE TESTING ASSOCIATION


Substance NOx


NH3 N2


CO SO2


HCl HF


Particulates


Metals (As, Co, Cr, Cu, Mn, Ni, Pb, Sb, V)


Cd + Tl Hg Dioxins and furans


Dioxins and furans + dioxin-like PCBs


Standard Generic EN O


Generic EN EN 21258 Generic EN Generic EN Generic EN Generic EN EN 13284-2


EN 14385 EN 14385


Generic EN & EN 14884


EN 1948 1-3 EN 1948 1-3 ** 180 mg/Nm3


IED ELV – Daily or periodic (mg/Nm3


200


- -


50 50 10 2


10 0.5 0.05 0.05 0.1 ng/Nm3 I-TEQ -


)


BAT-AEL new plant (mg/Nm3 50 – 120 2 - 10


10 - 50 5 - 30 <2 - 6 <1


<2 - 5 0.01 – 0.3 0.005 – 0.02


0.005 – 0.02 (periodic / continuous daily) 0.001 – 0.01 (long-term sampling)


<0.01 – 0.04 ng/Nm3 I-TEQ (periodic)


<0.01 – 0.06 ng/Nm3 I-TEQ (long-term sampling)


<0.01 – 0.06 ng/Nm3 WHO-TEQ (periodic) <0.01 – 0.08 ng/Nm3 WHO-TEQ (periodic)


applicable if the plant uses Selective Non-Catalytic Reduction for NOx


) BAT-AEL existing plant (mg/Nm3 50 – 150 (180**) 2 - 10


10 - 50 5 - 40 <2 - 8 <1


<2 - 5 0.01 – 0.3 0.005 – 0.02


0.005 – 0.02 (periodic / continuous daily) 0.001 – 0.01 (long-term sampling)


<0.01 – 0.06 ng/Nm3 I-TEQ (periodic)


<0.01 – 0.08 ng/Nm3 I-TEQ (long-term sampling)


<0.01 – 0.08 ng/Nm3


WHO-TEQ (long-term sampling) <0.01 – 0.1 ng/Nm3


WHO-TEQ (long-term sampling) abatement


)


Under IED, there is very limited scope for operators to claim derogations from having to apply the BATCs. In the UK, it is unlikely that any municipal Energy from Waste facilities will claim whole-scale derogations from applying BAT and the BATCs will be applied in full.


All emissions limit values (ELVs) identifi ed as BAT, the BAT-AELs, relate to normal operating conditions and daily averages only. The IED specifi es the ELVs that apply for shorter averaging periods (i.e. 10 minutes or 30 minutes) and during other than normal operating conditions (OTNOC).


Turning BAT Conclusions


into National Policy. National regulators (referred to in the BREF as “competent authorities”) are responsible for introducing BATCs into operating permits. In the UK, this process has been led by the Environment Agency with the other UK regulators also engaged. The UK industry, through its trade groups, has also been consulted at regular intervals throughout the process of turning BATCs into regulatory policies and guidance.


The implementation phase is well under way. UK regulators are continuing to draft guidance notes with the intention of completing the process ahead of the review and variation of existing permits. These documents will be made publically available upon completion.


The initial plan in England was to issue Reg 61 Notices to sites, requesting information on whether the new BAT Conclusions can be met. Following completion and review of the Reg 61 notices, each site’s permit was to be updated with the new requirements. This process has been impacted by the COVID-19 situation and the backlog of work within the EA’s National Permitting Service. The EA is now considering the possibility of commencing the fi rst batch of permit reviews in April 2021 by issuuing a consolidated permit with improvement conditions to request information in place of the Reg 61 Notices.


The approach is likely to be slightly different in Scotland where the regulator has indicated its intention to assign limits based on historic operational data. It is not entirely clear whether Welsh and Northern Irish regulators will adopt an approach more aligned to that in England or Scotland or somewhere in between.


The development of guidance process has yielded a situation which carefully balances improvements in emissions and environmental outcomes with operational effi ciencies in the use of raw materials and capital investment. There has generally been a high level of agreement on the approaches taken amongst both regulators and operators, facilitated in no small part by an open exchange of operational data as the basis for decision making.


There is no unanimity between regulators and operators (or within regulators and operators) but there has been a willingness to engage and achieve a common goal.


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