EU PRACTICE IN SETTING WASTEWATER EMISSION LIMIT VALUES

R.C.Frost March 2009

1 Introduction and scope

The processes of setting emission limit values (ELVs) for wastewater and treated effluent discharged to surface water have evolved over time in EU member states and are now to a large extent similar. But it wasnt always the case. In the 1970s and 1980s the practice in a number of continental member states was to set standard technology-based ELVs to be achieved by all dischargers (within a sector) whilst the UK, for example, tended to set long-term ELVs based on an assessment of the assimilative capacity of the receiving water with shorter-term ELVs based on the achievable performance of existing facilities. The usual approach nowadays is to set minimum technology-based ELVs except where considerations of objective surface water quality (SWQ) require further reduction in pollutant loads provided this is technologically feasible and the costs are considered not disproportionate. In practice, the concepts of proportionate and disproportionate cost are usually impossible to apply with confidence; hence the concepts of reasonable or unreasonable cost usually substitute for them, tacitly at least, i.e. decisions on whether to adopt stricter standards are the subject of qualitative judgement rather than quantitative determination. With regard to technology-based standards for wastewater discharge to surface water, two EU Directives are of prime significance: the Urban Wastewater Treatment Directive (UWTD) and the Integrated Pollution Prevention and Control (IPPC) Directive. Both are referenced in the Water Framework Directive (WFD). UWTD sets minimum treatment standards to be met by urban wastewater treatment plants and industrial activities that generate similar effluents. The minimum degree of treatment to be given and the ELVs to be achieved, depend on the nature of the surface water that a facility discharges to. IPPC provides a framework for a comprehensive and integrated regulation of those industrial sectors whose activities are potentially the most polluting. This includes waste treatment. Industrial sectors that are subject to IPPC are prescribed in the Directive. Production capacity criteria apply to enterprises in some sectors; so that installations whose capacities fall below the sector criterion are excluded from IPPC control. IPPC embodies the fundamental concepts of Best Available Techniques (BAT) - which includes technology, equipment and operational practices - and BAT associated emission levels (BATAEL). BAT and BATAEL are described in a series of BAT reference documents known as BREFs. Following from and technical discussions with an industrial operator, regulatory officials set site-specific ELVs which may be derived from BATAEL. The ELVs are included in the installations IPPC authorisation (permit). Subject to safeguards, many industrial activities generate wastewater that can be discharged to urban sewers for combined treatment with wastewater from domestic and other sources. For much small-scale industry, some larger scale industries after wastewater pre-treatment, and many trades this disposal route offers the best option for cost-effective management of their wastewater. But safeguards in the form of trade effluent control (TEC) must be in place to protect the workers, physical

infrastructure, treatment processes, effluent discharge arrangements and sludge disposal routes employed by the water and sewerage operator. The WFD identifies of group of 33 substances for which, subject to disproportionate costs and technical infeasibility constraints, control may be required: Priority Substances (PS) form the largest sub-set within the group. Their concentrations in surface water should be controlled so as to achieve specific SWQ standards defined in EU legislation. Member states should also ensure there is no deterioration in surface water quality from the current position. Priority Hazardous Substances (PHS) form a smaller sub-set Their concentrations in surface water should be controlled so as to achieve specific SWQ standards defined in EU legislation. Member states must then (i) ensure no deterioration from the current position and (ii) to eliminate all emissions and discharges to water.

Practice in EU member states on the above issues is summarised and illustrated in the following sections, using selected published information as far as possible.

2 Urban Wastewater Treatment Directive 91/271/EEC

2.1 Scope
Adopted in 1991, the UWTD requires that urban and similar wastewaters be treated to minimum levels prior to discharge to surface water. This applied throughout the EU member states though, where needed, existing and new member states were allowed periods of several years to catch up with the minimum requirements. The application of the UWTD to a specific urban wastewater discharge depended (and depends) on the population equivalent (p.e.) of the urban catchment and the nature of the receiving water - see Section 2.2. The Directive also requires the regulation of biodegradable wastewater discharged to surface water from industrial plants in specific sectors - see Section 2.3 - where the wastewater from a plant represents a p.e. of 4 000 or more. Relevant definitions of terms are: 'urban waste water' means domestic waste water or the mixture of domestic waste water with industrial waste water and/or run-off rain water; 'domestic waste water' means waste water from residential settlements and services which originates predominantly from the human metabolism and from household activities; 'industrial waste water' means any waste water which is discharged from premises used for carrying on any trade or industry, other than domestic waste water and run-off rain water; 'collecting system' means a system of conduits which collects and conducts urban waste water; '1 p.e. (population equivalent)' means the organic biodegradable load having a five-day biochemical oxygen demand (BOD5) of 60 g of oxygen per day. Loads expressed in p.e. shall be calculated on the basis of the maximum average weekly load entering a (collecting system and) treatment plant during the year, excluding unusual situations such as those due to heavy rain; 'primary treatment' means treatment of urban waste water by a physical and/or chemical process involving settlement of suspended solids, or other processes in which the BOD5 of the incoming waste water is reduced by at

least 20 % before discharge and the total suspended solids of the incoming waste water are reduced by at least 50 %; 'secondary treatment' means treatment of urban waste water by a process generally involving biological treatment with a secondary settlement or other process in which the requirements established in Table B.2 are respected; 'eutrophication' means the enrichment of water by nutrients, especially compounds of nitrogen and/or phosphorus, causing an accelerated growth of algae and higher forms of plant life to produce an undesirable disturbance to the balance of organisms present in the water and to the quality of the water concerned; sensitive area means a water body that falls into one of the following groups: (a) natural freshwater lakes, other freshwater bodies, estuaries and coastal waters which are found to be eutrophic or which in the near future may become eutrophic if protective action is not taken Annex II of the Directive gives factors to take into account; (b) surface freshwaters intended for the abstraction of drinking water which could contain more than the concentration of nitrate laid down under the relevant provisions of Council Directive 75/440/EEC of 16 June 1975 if action is not taken; (c) areas where further treatment than that prescribed in Article 4 of this Directive is necessary to fulfil Council Directives.

2.2 Application of UWTD to Urban WWTPs

The UWTD applies to wastewater discharges to all surface waters. Table B.1 gives the minimum specified levels of treatment for wastewater discharges to freshwater, which depend on (i) whether or not the freshwater body is a sensitive area and (ii) the wastewater p.e. For simplicity and relevance, the time periods that member states were allowed for meeting UWTD requirements are omitted. Table B.1 Minimum Urban Wastewater Treatment Required Under UWTD
Surface Water Designation Freshwater Secondary treatment see Table B.2 Secondary treatment see Table B.2 Freshwater in Sensitive Area Secondary treatment see Table B.2 Secondary treatment see Table B.3 (1)

Wastewater p.e. 2 000 to 10 000 10 000

(1)

Alternatively, requirements for individual plants need not apply in sensitive areas where it can be shown that the minimum percentage of reduction of the overall load entering all urban waste water treatment plants in that area is at least 75 % for total phosphorus and at least 75 % for total nitrogen.

UWTD also requires particular attention is paid to the sampling and analysis of wastewater discharges to assess their compliance with the ELVs in Tables B.1 and B.2. Specifically: WWTPs shall be designed or modified so that representative samples of the incoming wastewater and of treated effluent can be obtained before discharge to receiving waters Flow-proportional or time-based 24-hour samples shall be collected at the same well-defined point in the outlet and if necessary in the inlet of the treatment plant in order to monitor compliance

Good international laboratory practices aiming at minimizing the degradation of samples between collection and analysis shall be applied Compliance with the ELV is assessed at the 95 percentile confidence level the UWTD provides look-up tables specifying the maximum permissible number of failures consistent with 95 percentile compliance. The number of permissible failures varies non-linearly with the number of samples analysed during the year. The annual number of samples noted in these look-up tables ranges from 4-7 to 351-365. Minimum UWTD Secondary Treatment Performance

Table B.2

Values for limiting concentration or the percentage of reduction shall apply

Parameter BOD5 at 20 C Biochemical oxygen demand without nitrification (3,6) COD (Chemical oxygen demand) (4) Total suspended solids
(1) (2) (5, 6)

Limiting Concentration 25 mg/l O2

Minimum % Load Reduction (1) 70 - 90

125 mg/l O2 35 mg/l

75 90 (2)

Reduction in relation to the influent load This requirement is optional (3) Reference Method of Measurement: Homogenized, unfiltered, undecanted sample: determination of dissolved oxygen before and after five-day incubation at 20 C 1 C, in complete darkness. Addition of a nitrification inhibitor (4) Reference Method of Measurement: Homogenized, unfiltered, undecanted sample: potassium dichromate (5) Reference Method of Measurement: Filtering of a representative sample through a 0.45 m filter membrane. Drying at 105 C and weighing Or Centrifuging of a representative sample (for at least five minutes with mean acceleration of 2 800 to 3 200 g), drying at 105 C and weighing (6) Urban waste water discharges to waters situated in high mountain regions (over 1 500 m above sea level) where it is difficult to apply an effective biological treatment due to low temperatures may be subjected to treatment less stringent than that prescribed above provided that detailed studies indicate that such discharges do not adversely affect the environment. Table 1 of Annex 1 of the UWTD defines the relaxed limits

Table B.3

Additional Minimum UWTD Discharge to a Sensitive Area

Treatment

Performance

for

One or both parameters may be applied depending on the local situation. The values for concentration or for the percentage of reduction shall apply.
Wastewater p.e. 10 000 to 100 000 100 000 10 000 to 100 000 100 000
(1) (2)

Parameter Total Phosphorus (3) Total Nitrogen (2,3)

Limiting Concentration 2 mg/l P 1 mg/l P 15 mg/l N (4) 10 mg/l N

(4)

Minimum % Load Reduction (1) 80 80 70 - 80 70 - 80

Reduction in relation to the influent load This requirement is optional (3) Reference Method of Measurement: Molecular absorption spectrophotometry

(4)

Alternatively, the daily average must not exceed 20 mg/l N. This requirement refers to a water temperature of 12 C or more during the operation of the biological reactor of the waste water treatment plant.

Taken from the EUs 1998 UWTD implementation review report, Figure B.1 below shows the planned capacity growth for collecting systems and treatment plants over a thirteen-year period. This covered all 14 member states at that time. Collecting systems capacity was planned to increase by 22 % and treatment capacity by 69 % over this period. Figure B.1 Planned Development of Collecting Systems and Treatment Plants (1 000 p.e.)

It may be noted that in Germany, the implementation of the UWTD necessitated a major upgrading and expansion of the wastewater infrastructure and triggered very large investments. The problems connected with implementation in the new Lnder of eastern Germany were particular severe and of relevance. Similar to the situation in the EECCA, the wastewater infrastructure in the new Lnder was in such a desolate condition immediately after German reunification that some of the existing sewage disposal systems could not even be rehabilitated. Cost-effective solutions were therefore sought in order to contain the immense costs required for redevelopment. The efficient upgrading of wastewater collection and treatment systems in compliance with UWTD meant targeting financial resources carefully and more economically in the water protection sector and avoiding local planning mistakes and measures that were regionally uncoordinated.

2.3 Application of UWTD to Industry

Article 11 of UWTD requires that discharges of industrial waste water into collecting systems and urban waste water treatment plants is subject to prior regulations and/or specific authorizations by the competent authority or appropriate body, i.e. it requires that industrial discharges to sewer be subjected to trade effluent control (TEC). The TEC approaches adopted by selected authorising bodies in the United Kingdom is summarised in Section 5. Article 11 also states that the (TEC) regulations and/or specific authorization shall satisfy the following requirements: protect the health of staff working in collecting systems and treatment plants ensure that collecting systems, waste water treatment plants and associated equipment are not damaged ensure that the operation of the waste water treatment plant and the treatment of sludge are not impeded ensure that discharges from the treatment plants do not adversely affect the environment, or prevent receiving water from complying with other
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Community Directives ensure that sludge can be disposed of safety in an environmentally acceptable manner.

Article 13 of UWTD refers to biodegradable industrial wastewater from plants that (i) belong to the industrial sectors listed below and (ii) (each) represent a wastewater load of 4 000 p.e. or more. It requires that such wastewater, unless discharged to urban WWTPs, when it would be subject to TEC (see above), shall before discharge respect conditions established in regulations and/or specific authorization by the competent authority or appropriate body. Unlike for urban wastewater discharges, no specific minimum ELVs are laid down but it would be reasonable to apply the same or similar ELVs as given in Tables B.2 and B.3. The sectors to which Article 13 applies are: Milk-processing Manufacture of fruit and vegetable products Manufacture and bottling of soft drinks Potato-processing Meat industry Breweries Production of alcohol and alcoholic beverages Manufacture of animal feed from plant products Manufacture of gelatine and of glue from hides, skin and bones Malt-houses Fish-processing industry only a few Member States had taken into consideration the threshold of 4 000 p.e. Most stipulate in their laws that all discharges of industrial waste water must, whatever their size, be subject to prior regulations and/or specific authorisations regarding the stipulation in paragraph 2 of Article 13 that requirements should be appropriate to the nature of the industry concerned: Austria, Germany, France and Flanders in Belgium incorporate emission standards into their laws which vary according to the nature of the industry; the United Kingdom, Finland, Ireland, the Netherlands, Denmark, Sweden and Luxembourg opted to determine emission standards on a case-by-case basis for each industrial site, taking account of the principle of the best available technologies (BAT) when issuing discharge authorisations. In Greece, Italy and Portugal, national legislation did not define emission standards in relation to the industry concerned and the authorisations issued were not based on the principle of BAT. Spain had not completed the process of transposing the provisions of Article 13.

In a 1998 implementation review (7 years after adoption), the EU reported that:

In conclusion, the Commission considered that nine Member States had adopted provisions in accordance with Article 13 of the directive. Austrian legislation was deemed to be not in conformity in that it did not cover all the industrial sectors specified in the directive. Italy had not transposed the directive. Checks were in progress regarding Greece, Portugal, Belgium and Spain.

3 Industry IPPC and Principles of BAT

3.1 Integrated Pollution Prevention and Control Directive (IPPC) 96/61/EC
Adopted in 1996, the IPPC Directive is concerned with industrial installations whose potential for causing pollution is significant. Table B.4 lists the industrial activities and, where they apply, the threshold capacities or throughputs of installations subject to IPPC. IPPC applies an integrated approach to pollution prevention, control and permitting of installations. Releases to water, air and land are considered together in the authorisation; all appropriate preventive measures are required to be taken against pollution, in particular through application of best available techniques (BAT); and IPPC requires that no significant pollution is caused. Relevant definitions include: 'substance` means any chemical element and its compounds, with the exception of radioactive substances within the meaning of Directive 80/836/Euratom (1) and genetically modified organisms within the meaning of Directive 90/219/EEC (2) and Directive 90/220/EEC (3); 'pollution` means the direct or indirect introduction as a result of human activity, of substances, vibrations, heat or noise into the air, water or land which may be harmful to human health or the quality of the environment, result in damage to material property, or impair or interfere with amenities and other legitimate uses of the environment; 'installation` means a stationary technical unit where one or more Annex-1 activities listed below are carried out, and any other directly associated activities which have a technical connection with the activities carried out on that site and which could have an effect on emissions and pollution; emission` means the direct or indirect release of substances, vibrations, heat or noise from individual or diffuse sources in the installation into the air, water or land; 'emission limit values` means the mass, expressed in terms of certain specific parameters, concentration and/or level of an emission, which may not be exceeded during one or more periods of time. Emission limit values may also be laid down for certain groups, families or categories of substances, in particular for those listed in Annex III. The emission limit values for substances shall normally apply at the point where the emissions leave the installation, any dilution being disregarded when determining them. With regard to indirect releases into water, the effect of a water treatment plant may be taken into account when determining the emission limit values of the installation involved, provided that an equivalent level is guaranteed for the protection of the environment as a whole and provided this does not lead to higher levels of pollution in the environment, without prejudice to Directive 76/464/EEC or the Directives implementing it; 'environmental quality standard` means the set of requirements which must be fulfilled at a given time by a given environment or particular part thereof, as set out in Community legislation;

'competent authority` means the authority or authorities or bodies responsible under the legal provisions of the Member States for carrying out the obligations arising from this Directive; 'permit` means that part or the whole of a written decision (or several such decisions) granting authorisation to operate all or part of an installation, subject to certain conditions which guarantee that the installation complies with the requirements of this Directive. A permit may cover one or more installations or parts of installations on the same site operated by the same operator; (a) 'change in operation` means a change in the nature or functioning, or an extension, of the installation which may have consequences for the environment; (b) 'substantial change` means a change in operation which, in the opinion of the competent authority, may have significant negative effects on human beings or the environment;

'best available techniques` means the most effective and advanced stage in the development of activities and their methods of operation which indicate the practical suitability of particular techniques for providing in principle the basis for emission limit values designed to prevent and, where that is not practicable, generally to reduce emissions and the impact on the environment as a whole: 'techniques` shall include both the technology used and the way in which the installation is designed, built, maintained, operated and decommissioned 'available` techniques means those developed on a scale which allows implementation in the relevant industrial sector, under economically and technically viable conditions, taking into consideration the costs and advantages, whether or not the techniques are used or produced inside the Member State in question, as long as they are reasonably accessible to the operator 'best` means most effective in achieving a high general level of protection of the environment as a whole

'operator` means any natural or legal person who operates or controls the installation or, where provided for in national legislation, to whom decisive economic power over the technical functioning of the installation has been delegated

As indicated in Table B.4, the range of industrial activities coming under the IPPC regime in EU member states is considerable. The application of BAT lies at the heart of IPPC and descriptive guidance on BAT in each industrial sector and sub-sector is provided in a series of BAT Reference documents normally referred to as BREFs. All BREFs are freely available in English language (only) on the website of the European IPPC Bureau (http://eippcb.jrc.es). The first BREFs became available a few years after the Directive was adopted. The final BREF of this, the first round, appeared in 2006. A process of revision and update to reflect technological advances is currently in place. Industry was not required to change overnight. Existing installations had several years to adapt to the new requirements: new installations were expected to apply BAT in their applications. Provision was also made for the application of BAT when an existing installation was modified significantly.

Table B.4

Industrial Installations Subject to IPPC Directive 96/61/EC

The threshold values given below generally refer to production capacities or outputs. Where an operator carries out several activities falling under the same subheading in the same installation or on the same site, the capacities of such activities are added together. Category 1. Energy industries Sector 1.1 Combustion installations 1.2. Mineral oil and gas refineries 1.3. Coke ovens 1.4. Coal gasification and liquefaction plants 2. Production and processing of metals 2.1. Metal ore (including sulphide ore) roasting or sintering installations 2.2. Production of pig iron or steel (primary or secondary fusion) including continuous casting 2.3. Processing of ferrous metals a) Hot-rolling mills (b) Smitheries using hammers (c) Application of protective fused metal coats 2.4. Ferrous metal foundries 2.5. Installations (a) production of non-ferrous crude metals from ore, concentrates or secondary raw materials by metallurgical, chemical or electrolytic processes (b) smelting, including the alloyage of non-ferrous metals, including recovered products, (refining, foundry casting, etc.) 2.6. Surface treatment of metals and plastic materials using an electrolytic or chemical process Capacity 2.5 tonnes/hour Crude steel capacity 20 tonnes/hour Calorific power used 20 MW Hammer energy 50 kJ/hammer Crude steel input 2 tonnes/hour Production capacity 20 tonnes/day Sub-Sector Threshold Values Rated thermal input 50 MW -

Melting capacity: 4 tonnes/day for Pb and Cd 2- tonnes/day for other metals Volume of the treatment vats 30 m3

Category 3. Mineral industry

Sector 3.1 production of cement clinker and lime

Sub-Sector Production of cement clinker in rotary kilns Production of lime in rotary kilns or other furnace

Threshold Values Kiln capacity 500 tonnes/day Furnace capacity 50 tonnes/day Melting capacity 20 tonnes/day Melting capacity 20 tonnes/day production capacity 75 tonnes/day and/or kiln capacity 4 m3 and with a setting density per kiln exceeding 300 kg/m3 -

3.2. Production of asbestos and the manufacture of asbestos-based products 3.3. Manufacture of glass including glass fibre 3.4. Melting mineral substances including the production of mineral fibres 3.5. Manufacture of ceramic products by firing: in particular roofing tiles, bricks, refractory bricks, tiles, stoneware or porcelain 4.1. Basic organic chemicals, such as:

4. Chemical industry industrial scale

production by processing substances or groups of substances listed in 4.1 to 4.6

(a) simple hydrocarbons (linear or cyclic, saturated or unsaturated, aliphatic or aromatic) (b) oxygen-containing hydrocarbons such as alcohols, aldehydes, ketones, carboxylic acids, esters, acetates, ethers, peroxides, epoxy resins (c) sulphurous hydrocarbons (d) nitrogenous hydrocarbons such as amines, amides, nitrous compounds, nitro compounds or nitrate compounds, nitriles, cyanates and isocyanates (e) phosphorus-containing hydrocarbons (f) halogenic hydrocarbons (g) organometallic compounds (h) basic plastic materials (polymers synthet-ic fibres and cellulose-based

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Category 4. Chemical industry continued

Sector

Sub-Sector fibres) (i) synthetic rubbers (j) dyes and pigments (k) surface-active agents and surfactants

Threshold Values -

4.2 Basic inorganic chemicals, such as:

(a) gases, such as ammonia, chlorine or hydrogen chloride, fluorine or hydrogen fluoride, carbon oxides, sulphur compounds, nitrogen oxides, hydrogen, sulphur dioxide, carbonyl chloride (b) acids, such as chromic acid, hydrofluoric acid, phosphoric acid, nitric acid, hydrochloric acid, sulphuric acid, oleum, sulphurous acids (c) bases, such as ammonium hydroxide, potassium hydroxide, sodium hydroxide (d) salts, such as ammonium chloride, potassium chlorate, potassium carbonate, sodium carbonate, perborate, silver nitrate (e) non-metals, metal oxides or other inorganic compounds such as calcium carbide, silicon, silicon carbide

4.3. Production of phosphorous-, nitrogen- or potassium-based fertilisers (simple or compound fertilisers) 4.4. Production of basic plant health products and of biocides 4.5. Installations using a chemical or biological process for the production of basic pharmaceutical products 4.6. Chemical installations for the production of

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Category 5. Waste management

- see Directive text for cross-references to other Directives

Sector explosives 5.1. Installations for the disposal or recovery of hazardous waste and the disposal of waste oils see Directive text for further guidance 5.2. Installations for the incineration of municipal waste 5.3. Installations for the disposal of nonhazardous waste - see Directive text for further guidance 5.4. Landfills excluding landfills of inert waste -

Sub-Sector

Threshold Values Capacity 10 tonnes/day

Capacity 3 tonnes/hour Capacity 50 tonnes/day

Receiving 10 tonnes/day Or Total capacity 25 000 tonnes Production capacity 20 tonnes/day Treatment capacity 10 tonnes/day

6. Other activities

6.1 Industrial plants for the production of:

(a) pulp from timber or other fibrous materials (b) paper and board -

6.2. Plants for the pre-treatment (operations such as washing, bleaching, mercerisation) or dyeing of fibres or textiles 6.3. Plants for the tanning of hides and skins 6.4 (Food processing)

(a) Slaughterhouses (b) Treatment and processing intended for the production of food products from: - animal raw materials (other than milk) - vegetable raw materials

Treatment capacity 12 tonnes/day of finished products Carcase production capacity 50 tonnes/day Animal raw materials: finished products production capacity 75 tonnes/day Vegetable raw materials: finished products production capacity (average value on a quarterly basis) 300 tonnes/day Quantity of milk received: (average value on an annual basis) 200 tonnes/day
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(c) Treatment and processing of milk

Category 6. Other activities - continued

Sector 6.5. Installations for the disposal or recycling of animal carcases and animal waste 6.6. Installations for the intensive rearing of poultry or pigs

Sub-Sector

Threshold Values Treatment capacity 10 tonnes/day

(a) places for poultry (b) production pigs (over 30 kg) (c) 750 places for sows -

40 000 places 2 000 places 750 places Organic solvent consumption capacity 150 kg per hour or 200 tonnes/year

6.7. Installations for the surface treatment of substances, objects or products using organic solvents, in particular for dressing, printing, coating, degreasing, waterproofing, sizing, painting, cleaning or impregnating 6.8. Installations for the production of carbon (hard-burnt coal) or electrographite by means of incineration or graphitization

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3.2 IPPC Permitting and ELVs

3.2.1 Principles
Articles 9, 10 and 18 of the Directive refer to the conditions of an IPPC permit and setting ELVs. Paragraphs 3, 4 and 5 of Article 9 state in part that: Para. 3: The permit shall include ELVs for pollutants, in particular, those listed in Annex III likely to be emitted from the installation concerned in significant quantities, (i.e. ELVs do not have to set for all the parameters listed below, only if the substances are likely to be emitted in significant quantities) having regard to their nature and their potential to transfer pollution from one environmental medium to another. Where appropriate, limit values may be supplemented or replaced by equivalent parameters or technical measures. The Annex III indicative list of main polluting substances to be taken into account if relevant for fixing emission limit values for releases to water are: Organohalogen compounds and substances which may form such compounds in the aquatic environment Organophosphorus compounds Organotin compounds Substances and preparations which have been proved to possess carcinogenic or mutagenic properties or properties which may affect reproduction in or via the aquatic environment Persistent hydrocarbons and persistent and bioaccumulable organic toxic substances Cyanides Metals and their compounds Arsenic and its compounds Biocides and plant health products Materials in suspension Substances which contribute to eutrophication (in particular, nitrates and phosphates) Substances which have an unfavourable influence on the oxygen balance (and can be measured using parameters such as BOD, COD, etc.).

Para. 4. Without prejudice to Article 10, the ELVs and the equivalent parameters and technical measures referred to in paragraph 3 shall be based on the best available techniques, without prescribing the use of any technique or specific technology, but taking into account the technical characteristics of the installation concerned, its geographical location and the local environmental conditions. In all circumstances, the conditions of the permit shall contain provisions on the minimisation of long-distance or transboundary pollution and ensure a high level of protection for the environment as a whole. Para. 5: The permit shall contain suitable release monitoring requirements, specifying measurement methodology and frequency, evaluation procedure and an obligation to supply the competent authority with data required for checking compliance with the permit. Article 10 refers to BAT and environmental quality standards, stating that: Where an environmental quality standard requires stricter conditions than those achievable by
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the use of BAT, additional measures shall in particular be required in the permit, without prejudice to other measures which might be taken to comply with environmental quality standards. This is the so-called combined approach. Paragraph 1 of Article 18 provides the basis for the setting of ELVs at the Community level, though this has procedure not been invoked. Paragraph 2 states in part that, In the absence of Community emission limit values defined pursuant to para. 1), the relevant ELVs contained in (15) Directives referred to in Annex II shall be applied as minimum ELVs for the installations listed in the IPPC Directive (Table B.4). The Directives referred to include: Directive 82/176/EEC on limit values and quality objectives for mercury discharges by the chlor-alkali electrolysis industry Directive 83/513/EEC on limit values and quality objectives for cadmium discharges Directive 84/156/EEC on limit values and quality objectives for mercury discharges by sectors other than the chlor-alkali electrolysis industry Directive 84/491/EEC on limit values and quality objectives for discharges of hexachlorocyclohexane Directive 86/280/EEC on limit values and quality objectives for discharges of certain dangerous substances included in List 1 of the Annex to Directive 76/464/EEC, subsequently amended by Directives 88/347/EEC and 90/415/EEC amending Annex II to Directive 86/280/EEC Directive 76/464/EEC on pollution caused by certain dangerous substances discharged into the aquatic environment of the Community Directive 75/442/EEC on waste, as amended by Directive 91/156/EEC Directive 91/689/EEC on hazardous waste

3.2.2

Summary

In summary, therefore, the Directive envisaged that ELVs for wastewater discharges to surface water from installations subject to IPPC would be set as follows: According to the current state of technology BAT subject to default maximum values where defined in other EU Directives Stricter than BAT where surface water quality would otherwise be compromised

In practice, BAT is interpreted as taking into account the relation of costs and benefits, hence measures going beyond BAT are usually regarded as breaching the proportionality principle. Certainly this is the view of the Federation of German Industries (BDI), representing 35 industrial sector federations and 100 000 industrial enterprises that employ more than 8 million people. Commenting on a draft proposal to recast the IPPC Directive (and others) to form a unified Industrial Emissions Directive, the BDI has sought specific assurance that quality standards and national emission ceilings will not lead to measures going beyond BAT (Reference: BDI (2007), Position Paper: Proposal of the Commission for a Directive on Industrial Emissions (IPPC), Document No. D 0163, 24 October 2007. Available at: www.bdionline.de). By implication, it is normal practice in Germany that ELVs which are set for IPPC installations are not stricter than those achievable by BAT. The same approach applies in the United Kingdom.

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3.3 BAT an Introduction

3.3.1 Considerations when Determining BAT
Considerations to be taken into account generally or in specific cases when determining best available techniques, as defined in Article 2 (11) of the Directive, bearing in mind the likely costs and benefits of a measure and the principles of precaution and prevention, 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 their 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. the information published by the Commission pursuant to Article 16 (2) or by international organisations. The BREF documents and IPPC regulators therefore place great emphasis on the use of at-source prevention of pollutant generation or where, that is not feasible, at minimising pollutant generation at-source. So a major focus is on the practices and techniques employed within the industrial production facility this is in distinct contrast to the older approach of simply regulating the emission to water (or to air or land). The introduction of IPPC and BAT thus requires a significant expansion in professional capacity of the regulatory staff that inspect installations, set and enforce permits. IPPC regards the treatment of wastewater (and other streams) prior to discharge as subsidiary to or supportive of the primary role played by applying preventive and minimisation techniques. But wastewater treatment is not ignored and BREFs give guidance on good practice in this area also. Potential techniques cover a wide range including the monitoring and management of material, water and energy use; operational good practice; retrofitting equipment to improve the efficient use of materials, water and energy; investment in less polluting production technologies; recycling of waste streams; replacement where possible of hazardous substances with those that are more benign; and choosing effective methods for the treatment and disposal of the wastewater generated. BAT therefore comprises a combination of at-source and end-of-pipe techniques. The later BREFs, in particular, indicate the average level of emissions that an installation should be able to achieve through the application of BAT. This average value of emissions

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level is termed BATAEL (BAT associated emissions level). BATAEL is not the same therefore as a binding ELV, though it may form a basis for determining the ELV for an installation.

3.4 BATAEL vs. ELV

The effluent from any system of industrial production and wastewater treatment will be influenced by changes in raw material characteristics, fluctuations in production level and efficiency and changes in the performance of the WWTP facility. Effluent quality is bound to be variable to some extent therefore. Actual effluent quality will vary around an average value. And if effluent quality is normally distributed, we may expect effluent quality to be worse than average for 50% of the time - the rest of the time, we may expect effluent quality to be better than average. (The actual distribution may be skewed to some extent, in which case we should refer to the median rather than the average.) We shall assume a normal distribution for present purposes. BATAEL represents average effluent quality and is determined empirically, i.e. from the actual results measured at industrial installations. This being the case, it is irrational and incorrect to set an ELV as a maximum allowable concentration (PDK) equal to BATAEL. Instead, the ELV that is appropriate and consistent with BATAEL is that level at which we can say that: If sampling and analysis indicates that the ELV is satisfied for 95% of the time then we can be reasonably confident (a) that average effluent quality is consistent with the BATAEL and (b) that BAT is being applied. Figure B.2 illustrates the concept, showing a distribution of effluent quality around an average value - BATAEL and showing the value of effluent quality which is met for 95% of the time the ELV. In practice, ELVs are set by regulators following serious technical negotiations with the operator of an existing or proposed installation. Figure B.2 Concept of BATAEL vs. ELV
95 percentile

Effluent mg/l

BATAEL

ELV

Since the value of BATAEL is determined empirically, its value depends on the specific characteristics of an installation in a given sector. And since each installation may be regarded as a unique situation, the reality is that a single BATAEL value is not necessarily applicable to all installations in a sector. Nor by extension, is it

17

necessarily valid to apply a single ELV to all installations within a given sector or subsector. Hence BREF documents commonly contain a range of BATAEL values. It should also be noted that as IPPC seeks to prevent or minimise pollutant load releases, BATAEL values are commonly given as specific pollutant loads (e.g. kg pollutant per tonne of product, m3 wastewater per tonne product etc). If indicative BATAEL concentration values are not given they may be calculated from the load values. Commenting on a draft proposal to recast the IPPC Directive (and others) to form a unified Industrial Emissions Directive, the IPPC Alliance of (12) energy intensive industries whose constituent fims employed over 7.2 million people provided an example to illustrate the issue (full submission available at: www.eurofer.org). Figure B.3 illustrates the case where two installations apply the same techniques but, due to other factors such as raw materials, new vs existing installation etc - average emissions differ. Different ELVs apply, therefore. Figure B.3 Environmental Performances and ELVs of Two Installations Applying the Same Technique

Setting technology-based ELVs for industrial installations is clearly not an easy task, therefore. It requires that both the industrial operator and the regulator or permit issuing/enforcement authority have (a) access to meaningful monitoring and performance data (b) an in-depth understanding of technical issues and (c) can come to a reasonably common accord on setting an ELV that may be technically challenging this may appear especially demanding initially as major change might be needed to achieve the desired improvement in environmental performance - but is achievable. Though not an easy procedure, this is the basis on which ELVs are set

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for IPPC installations in EU member states. It requires that permit issuers/enforcers apply judgement and may involve incremental change, potentially including the tightening of ELVs over time as experience and knowledge accumulates.

4 Specific Industrial Sectors BATAEL and Selected ELVs

4.1 Scope
The specific ELVs set for an IPPC installation are or should be made available for public information. In the UK, for example, public registers of discharge consents are made available as public records, open for inspection on appointment at a local office of the Environment Agency for England and Wales. BREFs dont contain the ELVs as such, which are set locally, but may contain the BATAEL values agreed by the EIPPCB through the Seville process. BATAEL represents the typical output from an installation, i.e. after BAT is applied which may include wastewater pre-treatment of treatment. The Seville process entails dialogue between representatives of the national regulators, industry and other IPPC stakeholders; the preparation of draft BREFs; and further consultation and dialogue before the BREFs are finalised and adopted. Though all the BREFs offer a high level of description of the techniques involved in BAT, not all are forthcoming regarding BATAEL values: the later BREFs tend to provide more detail than did the earlier ones. In due course it may be expected that the revised BREFs will provide more comprehensive performance data. Abstracted from the adopted BREF documents; Tables B.5 to B.11 give BATAEL values for four selected industrial sectors, the date of BREF adoption is given in parenthesis. They serve as an illustration: some BATAEL values are given as concentrations, other as loads; some are given as single values, some as range and some as upper limit values. Potential provision is made for the ELVs for specific installations in the sector to be inserted from public registers at a later date. The sectors covered here are: Food and drink manufacture Paper making including pulping of recycled paper Iron and steel coke production Intensive rearing of pigs.

4.2 Food and Drink Sector Including Milk Processing (2006)

Table B.5 BATAEL and Selected ELVs: Food and Drink Sector
ELVs for Selected Installations Discharge Parameter BOD5 mg/l COD mg/l TSS mg/l pH value Oil and grease mg/l Total nitrogen Total phosphorus BATAEL 25 125 50 6-9 10 10 0.4 to 0.5 Plant A UK Plant B Germany Plant C Netherlands

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Note: Better levels of BOD5 and COD can be obtained. It is not always possible or cost effective to achieve the total nitrogen and phosphorus levels shown, in view of local conditions.

Additional BAT for dairies and specific BAT for producing market milk, powdered milk, butter, cheese and ice-cream address water consumption, energy consumption and waste prevention. Table B.6 gives the range of consumption and emission levels indicative of levels that can be achieved by applying in-process BAT they are based on reported achieved levels. The ranges reflect a variety of operating conditions. Water consumption and waste water emission levels may vary due to, e.g. different product portfolios, batch sizes and cleaning systems. The waste water emission level may be lower compared to the water consumption level because many dairies measure the intake of cooling water, but discharge it unmeasured. In warm climates, more water may be lost due to evaporation. Table B.6 Additional Consumption and Discharge Levels Typical for Milk Processing
Energy Consumption 0.07 - 0.2 kWh/l 0.3 0.4 kWh/l 0.6 2.8 kWh/kg Water Consumption 0.6 1.8 l/l 0.8 1.7 l/l 4.0 5.0 l/kg Wastewater Discharge 0.8 1.7 l/l 0.8 1.5 l/l 2.7 4.0 l/kg

Milk Processes Production of market milk from 1 litre of received milk Production of milk powder from 1 litre of received milk Production of 1 kg of ice-cream

4.3 Paper and Board Manufacturing (2001)

Table B.7 gives the BATAEL load values for integrated recovered paper mills, i.e. recovered paper (and cardboard) processing and papermaking are carried out at the same site. The BATAEL values refer to yearly averages and are presented separately for processes with and without deinking. Wastewater flow is based on the assumption that cooling water and other clean water are discharged separately, i.e. the values given are for process wastewater only, excluding cooling water discharges. Table B.8 gives the equivalent concentration values for (a) integrated RCF paper mills without deinking, assuming the achievable specific wastewater discharge volume. Table B.7 BATAEL Load Values for Integrated Recovered Paper mills
Integrated RCF Paper Mill Load Parameter Flow m3/t (dry) BOD5 kg/t (dry) COD kg/t (dry) TSS kg/t (dry) Total N kg/t (dry) Total P kg/t (dry) AOX
(1)

(a) Without de-inking e.g. carton-board etc 7 0.05 0.15 0.5 1.5 0.05 0.15 0.02 0.05 0.002 0.005 0.005

(b) With de-inking e.g. newsprint, printing and writing paper 8 - 15 0.05 0.2 2-4 0.1 0.3 0.05 0.1 0.005 0.01 0.005

(c) Tissue mills 8 - 25 0.05 0.5 2-4 0.1 0.4 0.05 0.25 0.005 0.015 0.005

kg/t (dry)

(1) Adsorbable organic halogenated compounds

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Table B.8

BATAEL and Selected ELVs: Integrated Recovered Paper Mills

(a) Integrated recovered fibre (RCF) paper mills without deinking

ELVs for Selected Installations Discharge Parameter BOD5 mg/l COD mg/l TSS mg/l Total N mg/l Total P mg/l AOX
(1) (1)

BATAEL 7 - 21 70 - 210 7 - 21 3-7 0.3 0.7 0.7

Plant A UK

Plant B Germany

Plant C Netherlands

mg/l

Adsorbable organic halogenated compounds

Table B.9 gives the BATAEL load values for non-integrated paper mills. They are presented for three types of paper product though the differences between the paper grades are not distinct. The BATAEL values refer to yearly averages. Again, wastewater flow is based on the assumption that cooling water and other clean water are discharged separately, i.e. the values given are for process wastewater only, excluding cooling water discharges. Table B.9 BATAEL Load Values for Non-Integrated Paper mills
Products of Non-Integrated RCF Paper Mills Load Parameter Flow m3/t (paper) BOD5 kg/t (paper) COD kg/t (paper) TSS kg/t (paper) Total N kg/t (paper) Total P kg/t (paper) AOX
(1) (1)

(a) Uncoated fine paper 10 - 15 0.15 0.25 0.5 2 0.2 0.4 0.05 0.2 0.003 0.01 0.005

(b) Coated fine paper 10 - 15 0.15 0.25 0.5 1.5 0.2 0.4 0.05 0.2 0.003 0.01 0.005

(c) Tissue 10 25 0.15 0.4 0.4 1.5 0.2 0.4 0.05 0.25 0.003 0.015 0.001

kg/t (paper)

Adsorbable organic halogenated compounds

4.4 Coke Production (2001)

Table B.10 gives BATAEL concentrations for wastewater from coking plants after biological wastewater treatment with integrated nitrification and denitrification. The concentration values are based on a specific wastewater flow of 0.4 m3 per tonne of coke.

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Table B.10

BATAEL and Selected ELVs: Coke Production

ELVs for Selected Installations BATAEL 90% 0.1 0.05 0.1 0.5
-

Discharge Parameter COD removal Sulphide mg/l PAH mg/l CN mg/l Phenols mg/l Sum of NH4 , NO2 and NO3 nitrogen Suspended solids
(1) the 6 Borneff substances:
+ (1)

Plant A UK

Plant B Germany

Plant C Netherlands

30 40

Fluoranthene (CAS number 206-44-0), benzo(a)pyrene (CAS number 50-32-8), benzo(b)fluoranthene (CAS number 205-99-2), benzo(k)fluoranthene (CAS number 207-08-9), benzo(g,h,i)perylene (CAS number 191-24-2) and indeno(1,2,3-cd)pyrene (CAS number 193-39-5). See Section 6 also.

4.5 Intensive Rearing of Poultry and Pigs (2003)

Table B.11 gives BATAEL values for effluent following the biological treatment of pig manure at large farms. Table B.11 BATAEL and Selected ELVs: Biological Treatment of Pig Manure
ELVs for Selected Installations Discharge Parameter BOD5 mg/l COD mg/l P mg/l
(1)

BATAEL 90 1 800 260 80

Plant A UK

Plant B Germany

Plant C Netherlands

N Kj mg/l

5 Industrial Wastewater Discharges to Sewer UK Practice of Trade Effluent Control

5.1 Objectives
Section 2.2 notes the requirement under the UWTD for EU member states to exert regulatory control over the discharge of industrial wastewaters to sewer. The trade effluent control (TEC) practice of water and sewerage companies in England and Wales is used here to illustrate TEC. These companies are mandated under legislation (Water Act 1991) to regulate trade effluent discharges to their sewerage systems. Companies such as Welsh Water and United Utilities publish guidance and application forms see, respectively, http://www.dwrcymru.com/English and http://www.unitedutilities.co.uk for the use of proposed dischargers. In addition to meeting the objectives outlined in Section 2.2, setting trade effluent consents has two other purposes. In total they are to protect the health of staff working in collecting systems and treatment plants ensure that collecting systems, waste water treatment plants and associated equipment are not damaged
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ensure that the operation of the waste water treatment plant and the treatment of sludge are not impeded ensure that discharges from the treatment plants do not adversely affect the environment, or prevent receiving water from complying with other Community Directives ensure that sludge can be disposed of safety in an environmentally acceptable manner. prevent an unacceptable frequency of storm sewage discharges to watercourses ensure that the discharger pays an appropriate charge for the reception, conveyance, treatment and disposal of his effluent.

5.2 Procedures
Each water and sewerage company operates its own procedures but essentially they comprise the steps indicated in Figure B.4. Figure B.4 Trade Effluent Control - Application to Discharge to Sewer

An industrial operator or trader is required to complete a number of forms and submit a site drainage plan to the sewerage operator in the Stage 1 pre-application. These forms are designed to help inform the sewerage operator as to the exact location of
Applicant: Stage2 Complete& SubmitTEC Notice

Applicant: Stage1 Forms

Sewerage Co: Assessmentand DraftingofTEC Notice

Sewerage Co: Grantor DeclineTE Consent

the proposed discharge, the nature of the activities undertaken relevant to effluent volume and composition, and the substances likely to be present in the effluent above background concentrations in the water supply. A sewerage company making an assessment of a Stage 1 pre-application will take into account: The nature and concentration of the likely constituents of the trade effluent and their potential negative effects on the sewerage system. If considered acceptable, limits will be set in the consent for each constituent. Additional analytical information may be requested at this stage. If any of the constituents declared are prescribed substances under IPPC legislation and are likely to be present in significant quantities then the application will be referred to the national competent authority (Environment Agency in England and Wales), who may impose conditions to be included in the consent Rationalisation and/or treatment of trade effluent may be required before the sewerage company is able to grant permission to discharge to the public sewers. For example: o Drainage amendments may be required to combine a number of trade effluent sources into a single waste stream (for monitoring and control purposes), or an Effluent pre-treatment plant may have to be installed and maintained in order to remove or reduce certain constituents in the trade effluent
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If satisfied with the proposed discharge, the sewerage company will prepare a trade effluent notice for the applicant to sign and return with an application fee. The trade efflunet notice is a formal request to discharge to the sewer and will stipulate: Sampling point - the Consent requires that a designated trade effluent sampling point be provided through which only trade effluent may pass, that is, no domestic sewage must be present. This point must be safe and easily accessible at all times. Sampling equipment - in order to obtain accurate representation of the nature and composition of the trade effluent, there may be a requirement for the discharger to supply and maintain equipment capable of sampling and / or monitoring the trade effluent discharge. Wastewater flow recording - it is necessary to be able to accurately determine the volume and rate of flow of trade effluent passing into the public sewer. This may require the installation of an appropriate measuring device, capable of recording flow rate and totalised volumes of effluent entering the foul water system. Self-monitoring - there may be a requirement for the discharger to carry out some self-monitoring and keep such records to an auditable standard and made available for inspection upon request. Maximum flow rates and, where applicable, wastewater concentration limits.

After Consent is granted, the sewerage company will take compliance samples as appropriate to monitor for the relevant constituents of the effluent. The number of monitoring visits by the sewerage companys Trade Effluent Inspectors will be determined by the nature and volume of the trade effluent. If required, they will take additional samples in order to obtain more representative results for trade effluent billing purposes. Samples may be analysed by an independent laboratory. The sewerage companys Trade Effluent Officers will check each completed Sample Analysis Report for compliance with the Consent conditions before forwarding to the discharger with comments. If necessary, a letter of Breach of Consent will accompany the report, requesting information on the nature of the incident and what remedial action is to be taken in future to prevent a recurrence. Any queries about the detail of a Consent to Discharge may be raised with the sewerage companys Area Trade Effluent Officer. The consent granted will remain unchanged for a period of at least 2 years (under the terms of the Water Industry Act 1991).

Breach of any conditions of a Trade Effluent Consent is a criminal offence and may render the discharger liable for prosecution by the water and sewerage company.

5.3 Commonly Imposed Restrictions on the Discharge of Industrial Effluent to Sewer

The following non-exhaustive list indicates the number of physical and chemical parameters that a water and sewerage company may limit in a Trade Effluent Consent this list is taken from a publication of United Utilities, a company that provides water and wastewater services in the industrial north west of England. Dependent on the nature of the industrial activity, the water and sewerage company

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might seek to set limits on other parameters not mentioned below. Any limit values given below are indicative and not prescriptive: Ammonia Ammonia can cause unsafe sewer atmospheres and toxicity problems in watercourses. Flammable Substances Flammable substances or substances which can produce flammable or explosive atmospheres will be prohibited or controlled to safe levels. Hydrogen Cyanide The limit is not greater than 1 mg/l. Hydrogen cyanide is toxic and can inhibit treatment processes. Hydrogen Sulphide The limit for substances that can produce hydrogen sulphide upon acidification is normally 1 mg/l. Hydrogen sulphide is a toxic gas that can build up in the sewer atmosphere, leading to hazardous working conditions. Hydrogen sulphide also has a very pungent odour which can cause smell nuisance. Organic Load Chemical oxygen demand and biological oxygen demand may be limited to prevent overloading of the wastewater treatment processes. pH The normal range of pH allowed is 6 to 10. Extremes of pH can lead to an unsafe working environment, affect biological treatment systems and damage equipment. Low and high pH can result in damage to the materials of construction of the sewer network. Red List Substances These substances are controlled under international conventions. A list of these substances is included in the preliminary document (Stage 1) and includes the metals cadmium and mercury, chlorinated solvents and a range of pesticides. These substances are persistent within the environment and can accumulate through the food chain. They can also inhibit biological treatment processes. Separable Oil and Grease Separable oil and grease can build up within the sewer which can lead to smell problems, blockages and subsequent foul flooding. Oil and grease can also build up on equipment such as pumps and cause operational difficulties at pumping stations and treatment works. Sulphate Sulphate is normally limited to 1 000 mg/l because it can cause damage to concrete structures. Suspended Solids Suspended solids can cause siltation and blockages in the sewerage system. Temperature This is limited by statute to a maximum of 43.3 oC

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Toxic Metals This group includes the metals; antimony, beryllium, chromium, copper, lead, nickel, selenium, silver, tin, vanadium and zinc. Metals can cause a range of problems. The presence of toxic metals can inhibit biological treatment processes and they may accumulate in the environment. Volume This parameter is normally limited to a number of cubic metres per 24 hour period and a rate of discharge in litres per second.

5.4 Charging for Industrial Effluent Discharges to Sewer

Industry discharging effluent to public sewer pays the sewerage company according to a widely used formula (known for historical reasons as the Mogden formula). This formula has a number of cost-recovery elements: A charge for the reception and conveyance of the effluent into and by the sewerage system A charge for the preliminary (screening, grit removal) and primary treatment (sedimentation) A charge for pumping and settlement of effluent during secondary (biological) treatment A charge for secondary (biological) treatment excluding pumping and settlement mainly this is for the aeration tanks, aeration and secondary sludge treatment and disposal A charge for primary sludge treatment and disposal Other charge elements may be added if the trade effluent constituents contribute to the sewerage company incurring significant additional costs e.g. a industrial operator releasing wastewater containing significant quantities of nitrogenous and phosphorus compounds to a WWTP discharging effluent to designated sensitive area. The sewerage company would be required to provide nutrient (N and P) removal prior to discharge and would include Nand P-related components in its charging structure.

The third and fourth charge elements above would be excluded if only preliminary and primary sewage treatment were provided. The formula takes the general form:

C = R + V + B1 + B2 (Ot/Os) + S (St/Ss)
Where: R= V= B1 = B2 = S= Os = Ss = Ot = St = Charge per cubic metre for reception and conveyance Charge per cubic metre for preliminary and primary sewage treatment Charge per cubic metre for pumping and settlement during biological treatment Charge per cubic metre for biological treatment (minus pumping and settlement) and the treatment and disposal of biological sludge Charge per cubic metre for primary sludge treatment and disposal One-hour settled COD of crude sewage (mg/l) Average Suspended Solids of crude sewage (mg/l) Average one-hour settled COD of trade effluent at pH 7 (mg/l) Average Suspended Solids of trade effluent at pH 7 (mg/l)
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The values of the charge components R, V, B1, B2 and S and of the standard strength terms Os, Ot, Ss and St - vary from company to company according to their particular situation. Values for one of the sewerage companies in 2004/05 are given below for illustration:
R V B1 B2 S Os Ss /m3 /m
3 3 3 3

0.131 0.100 0.015 0.093 0.079 312 230

/m /m /m

mg/l mg/l

Two examples are given in Table B.12 to indicate (i) the influence that wastewater discharge strength has on the costs incurred and (ii) that upper limits on the content of oxidisable components may be quite relaxed or not imposed at all dependent on the capability of the urban WWTP to handle the discharge. Table B.12 Illustrative Trade Effluent Charges
Assuming full treatment and taking the formula values given above Parameter Volume in charging period (m3) Ot Chemical oxygen demand (mg/l) St Suspended solids (mg/l) Charge for the period () Plant 1 5 000 500 150 2 260 Plant 2 5 000 3 000 900 7 275

6 WFD Priority and Priority Hazardous Substances

For substances considered to be particularly hazardous the WFD requires Member States to meet (surface water) Environmental Quality Standards (EQSs) set by the European Commission (in COM(2006)397 and most recently covered in a Common Position adopted by the Council). EQSs are set for the priority (PS) and priority hazardous substances (PHS) identified in Table B.13: i. ii. Priority Substances: referred to as Annex X in the WFD. A water body will fail Good Chemical Status if any of these EQSs are not complied with; Priority Hazardous Substances: these are a subset of PS. They are substances which are considered extremely harmful and, as well as achieving the EQS, discharges, emissions and losses must cease or be phased out.

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Summary of WFD requirements for Priority Substances

Requirement Meet the proposed EQS by 2015 Progressive reduction of discharges, emissions and losses (until EQS is achieved) Cessation or phasing out of discharges, emissions and losses (20 years from adoption of a proposal) Priority substances Priority hazardous substances

X

However, the WFD allows less stringent, or alternative, objectives to be met where it would be technically infeasible or disproportionately expensive to achieve the objectives (by 2015). For example, exemptions may also apply to the objective of aiming to cease emissions, discharges and losses of PHS and progressive reduction of discharges emissions and losses of Priority Substances on the grounds of infeasibility and disproportionate cost. As noted earlier, applying these concepts is more a matter of judgement and interpretation than mechanistic quantification. The competent authority in each member state is charged with implementing the WFD by developing River Basin Management Plans (RBMPs) and Programmes of Measures to set out the actions needed to meet EQSs and other WFD objectives. In England and Wales, the Environment Agency is charged with this responsibility and, in part fulfilment of this, has prepared a series of documents that supplement RBMPs by setting out national pollution reduction plans (PRPs) to meet WFD objectives for PSs and PHSs. Each PRP outlines what is known about the production, uses and sources; summarises monitoring information on releases and presence in controlled waters; evaluates measures to reduce and where appropriate, to cease discharges, emissions and releases; and identifies an action plan which may be merely to maintain the status quo if the EQS for a PS is complied with. Where surface waters are considered to fail the EQS at the 95 percentile level or to be at risk of failure or, in the case of PHS, where there is a WFD requirement to cease or phase out discharges, emissions and losses, action plans should be more substantial. However, the current PRPs largely identify the need for action rather than specific measures and, based on the available evidence, the likely targets for investigative work. Measures to reduce PS or PHS release beyond current achievements will be the subject of site-specific investigations and policy decisions.

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Table B.13
Alachlor Atrazine Benzene

WFD Priority and Priority Hazardous Substances

Priority Substance Priority Hazardous Substance Anthracene Brominated diphenylether (pentabromodiphenylether) Cadmium and compounds Chloroalkanes c10-13 (sccps) Endosulfan Hexachlorobenzene Hexachlorobutadiene Hexachlorocyclohexane Mercury and its compounds Nonyl phenol Pentachlorobenzene Polyaromatic hydrocarbons (pahs six berhoff substances excluding fluoranthene) Tributyltin compounds

Chlorfenvinphos Chlorpyrifos 1,2-dichloroethane Dichloromethane Di(2-ethylhexyl) phthalate (dehp) Diuron Fluoranthene Isoproturon Lead and compounds Naphthalene Nickel and compounds Octylphenol Pentachlorophenol Simazine Trichlorobenzenes (1,2,4-tcb) Trichloromethane Trifluralin

It should be noted that some PS and PHS are naturally occurring substances - eg Cd, Pb and Ni - or are present in diffuse releases from essentially uncontrolled sources such as old spoil heaps, old dump sites, the land, surface water run-off and precipitation.

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