SOURCE TESTING ASSOCIATION I Annual Guide 2021
A contemporary summary of the key outcomes at the time of writing are:
General principles
the top end of the BAT-AEL range is likely to be delivered via an improvement condition in the permit.
Mercury (Hg) monitoring
Following submission of operational data from UK operators, regulators have agreed a protocol for determining whether the mercury content of the waste can be considered to be “low and stable” (based on the mercury content in the emissions) and negate the need for continuous monitoring. A threshold based on periodic monitoring of Hg of 10 µg/Nm3
is to be used as a
trigger level under the protocol. Exceedances of the threshold initiate a process which could require the operator to install a continuous Hg analyser if emissions cannot be returned below this level following investigation.
Dioxins and furans monitoring
A protocol similar to the one for Hg has also been developed for dioxins and furans monitoring (which includes dioxin-like PCBs) to negate the need for continuous sampling if emissions can be demonstrated to be “suffi ciently stable”. The BAT Conclusions allow either an ELV for periodic sampling of dioxins and furans (I-TEQ) at 0.06 ng/Nm3
furans and dioxin-like PCBs (WHO-TEQ) of 0.08 ng/Nm3 in the fi nal stages of development at the time of writing.
for existing plant or and ELV for dioxins, . This is
Approach to OTNOC The new BAT-AELs apply only in normal operating conditions, not OTNOC. The current defi nition of OTNOC used in the UK (usually termed as “abnormal operation” (AO) under permits) is limited to failure of abatement or failure of CEMS only. Regulators are considering how and whether to widen the defi nition of AO to include all types of plant breakdown. A preliminary draft has been prepared and shared with industry and more dialogue is underway to refi ne it.
Monitoring during OTNOC
The BAT Conclusions also have a requirement to undertake monitoring of emissions during OTNOC. CEMS measurements are made throughout OTNOC, unless the OTNOC is triggered by a failure of CEMS. With the widespread use of hot-standby CEMS systems, this is not a commonly experienced situation. There is also a requirement to measure dioxins and furans specifi cally during start-up and shut-down whilst no waste is being burned.
An Individual Perspective
on the Industry Position The UK waste management sector has been generally very content with the way in which the UK regulators have approached the implementation of the BAT Conclusions.
The UK regulators have tried to work together to achieve common interpretations of the conclusions. They have kept industry informed of their intended approaches to implementation and have sought feedback on proposed guidance.
Where necessary, and to aid the translation of policy into practice, the UK regulators have also requested data and information from operators to support decision-making. It has been a very positive model for the interpretation of complex EU-level regulation into the local UK setting.
Unless there are specifi c local circumstances to do otherwise, the upper range of the BAT-AELs will be used as new permit limits for emissions, following existing Defra guidance. (Note Defra guidance on transcription of BAT-AELs into ELVs in permits does not apply in Scotland). The notable exception to this generalisation is oxides of nitrogen (NOx potential for further NOx
) for existing plants. The reductions at existing plants below
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