EA Says - Environment Not to be Considered as a Recipient of Pollutants and Waste

The UK Environment Agency's implementation of IPPC Regulations is progressing and the draft Guidance for the Treatment of Landfill Leachate Final DRAFT - Sector Guidance Note IPPC S5.03 is available on their web site here.

This is now (at 187 pages) an even longer document than the orginal draft, but it is now a significant reference document and source of information for all those interested in leachate treatment in the UK, and being freely available for downloading is also likely to be used in many other nations.

The EA does state that:

The BAT approach requires us not to consider the environment as a recipient of pollutants and waste, which can be filled up to a given level, but to do all that is practicable to minimise emissions from industrial activities and their impact.

For those unfamilar with the concept of BAT, BAT stands for Best Available Techniques. What constitutes a best available technique for the treatment of leachate is fully explained in the guidance document. The use of the word technique is broader than would be indicated if the word process had been used instead of technique, and means that a combination of a proven process and optimum implementation of the process is important when establishing that a treatment process is BAT.

Why is BAT important? It is important because the BAT philosophy is central to the UK's implementation of IPPC.

Who does the Guidance apply to? Everyone with leachate to discharge, or tanker away, from an IPPC regulated landfill.

Here is the context for the quotation above, which we have copied from the guidance:-

BAT and Environmental Quality Standards (EQS )

The BAT approach complements, but differs fundamentally from, regulatory approaches based on Environmental Quality Standards (EQS).

Essentially, BAT requires measures to be taken to prevent emissions - and measures that simply reduce emissions are acceptable only where prevention is not practicable. Thus, if it is economically and technically viable to reduce emissions further, or prevent them altogether, then this should be done irrespective of whether or not EQSs are already being met.

The BAT approach requires us not to consider the environment as a recipient of pollutants and waste, which can be filled up to a given level, but to do all that is practicable to minimise emissions from industrial activities and their impact.

The BAT approach first considers what emission prevention can reasonably be achieved (covered by Sections 2 and 3 of this Guidance) and then checks to ensure that the local environmental conditions are secure (see Section 4 of this Guidance and also Guidance Note IPPC Environmental Assessments for BAT).

The BAT approach is therefore the more precautionary one because the release level achieved may be better than that simply required to meet an EQS.

Conversely, if the application of indicative BAT might lead to a situation in which an EQS is still threatened, a more effective technique is required to be BAT for that installation. The Regulations allow for expenditure beyond indicative BAT where necessary, and, ultimately, an installation will only be permitted to operate if it does not cause significant pollution.

Several new leachate treatment technologies have now been included in the guidance. We will post again soon with further information on the technologies within this guidance.

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