APPENDIX 22
EXTRACTS FROM BATNEEC NOTES
LIST OF BATNEEC NOTES AVAILABLE ........................................................................ 3
EXTRACT FROM EPA BATNEEC GUIDANCE NOTE FOR THE EXTRACTION OF
ALUMINA ............................................................................................................................... 6
4.
5.
CONTROL TECHNOLOGIES .................................................................................... 6
EMISSION LIMIT VALUES....................................................................................... 9
EXTRACT FROM EPA BATNEEC GUIDANCE NOTE FOR BOARD
MANUFACTURE ................................................................................................................. 13
4.
5.
CONTROL TECHNOLOGIES .................................................................................. 13
EMISSION LIMIT VALUES............................................................................................ 17
EXTRACT FROM EPA BATNEEC GUIDANCE NOTE FOR THE CHEMICAL
SECTOR................................................................................................................................. 21
4.
5.
CONTROL TECHNOLOGIES .................................................................................. 21
EMISSION LIMIT VALUES..................................................................................... 25
EXTRACT FROM EPA BATNEEC GUIDANCE NOTE FOR ELECTROPLATING
OPERATIONS....................................................................................................................... 35
4.
5.
CONTROL TECHNOLOGIES .................................................................................. 35
EMISSION LIMIT VALUES............................................................................................ 39
EXTRACT FROM EPA BATNEEC GUIDANCE NOTE FOR THE EXTRACTION OF
MINERALS ........................................................................................................................... 45
4.
5.
CONTROL TECHNOLOGIES .................................................................................. 45
EMISSION LIMIT VALUES ............................................................................................. 49
EXTRACT FROM EPA BATNEEC GUIDANCE NOTE FOR THE PIG
PRODUCTION SECTOR .................................................................................................... 53
4. CONTROL TECHNOLOGIES ....................................................................................... 53
5. COMPLIANCE MONITORING .................................................................................... 60
EXTRACT FROM EPA BATNEEC GUIDANCE NOTE FOR THE RENDERING OF
ANIMAL BY-PRODUCTS................................................................................................... 62
4.
5.
CONTROL TECHNOLOGIES .................................................................................. 62
EMISSION LIMIT VALUES .................................................................................... 66
EXTRACT FROM EPA BATNEEC GUIDANCE NOTE FOR THE SLAUGHTER OF
ANIMALS .............................................................................................................................. 69
4.
5.
CONTROL TECHNOLOGIES .................................................................................. 69
EMISSION LIMIT VALUES............................................................................................ 72
EXTRACT FROM EPA BATNEEC GUIDANCE NOTE FOR THE MANUFACTURE
OF SUGAR ............................................................................................................................ 74
4.
CONTROL TECHNOLOGIES .................................................................................. 74
Page 1 of 132
5.
EMISSION LIMIT VALUES............................................................................................ 77
EXTRACT FROM EPA BATNEEC GUIDANCE NOTE FOR THE MANUFACTURE
OR USE OF COATING MATERIALS .............................................................................. 81
4.
5.
CONTROL TECHNOLOGIES .................................................................................. 81
EMISSION LIMIT VALUES............................................................................................ 85
EXTRACT FROM EPA BATNEEC GUIDANCE NOTE FOR TEXTILE FINISHING
................................................................................................................................................. 94
4.
5.
CONTROL TECHNOLOGIES .................................................................................. 94
EMISSION LIMIT VALUES............................................................................................ 98
EXTRACT FROM EPA BATNEEC GUIDANCE NOTE FOR WASTE ..................... 103
4.
5.
CONTROL TECHNOLOGIES ................................................................................ 103
EMISSION LIMIT VALUES................................................................................... 107
EXTRACT FROM EPA BATNEEC GUIDANCE NOTE FOR THE PRODUCTION OF
CEMENT ............................................................................................................................. 116
4.
CONTROL TECHNOLOGIES............................................................................ 116
5. EMISSION LIMIT VALUES .............................................................................................. 119
EXTRACT FROM EPA BATNEEC GUIDANCE NOTE FOR THE POULTRY
PRODUCTION SECTOR .................................................................................................. 123
4 CONTROL TECHNOLOGIES ...................................................................................... 123
5 COMPLIANCE MONITORING ............................................................................. 131
Page 2 of 132
LIST OF BATNEEC NOTES AVAILABLE
Published BATNEEC Notes are available from the EPA website at www.epa.ie and
EPA Publications, Dublin Regional Inspectorate, McCumiskey House, Richview,
Clonskeagh Road, Dublin 14. Tel. 00353 (0)1-26801000
IPPC
Directive
Annex 1
Category
Equivalent
EPA Act
1992, First
Schedule
Category
1. Energy Industries
1.1
2.2
1.2
1.3
9.3
9.4
Description of Activity per EPA Act 1992, First
Schedule
The burning of fuel in a boiler > 50 MW
The refining of petroleum or gas
Carbonisation, gasification etc. of coal, lignite,
oil, bituminous shale
1.4
9.4
Carbonisation, gasification etc. of coal, lignite,
oil, bituminous shale
2. Production and Processing of Metals
BATNEEC NOTE
Draft note covers all
activities 2.1 & 2.2 (V8)
in this sector
Draft (V3)
Draft (V3)
Draft (V3)
Draft (V3)
2.1
2.2
3.6
3.2
Roasting, sintering or calcining of metallic ores
The processing of iron & steel in forges
Draft (V3)
2.3(a)
2.3(b)
2.3(c)
3.2
?
3.4
The processing of iron & steel in forges
Draft (V3)
Draft (V3)
2.4
3.3
2.5(a)
2.5(b)
1.2
3.4
The production. recovery, processing, use of nonferrous metals
The production. recovery, processing, use of
ferrous metals
The extraction of aluminium oxide from ore
The production. recovery, processing, use of nonferrous metals
Electroplating operations
2.6
12.3
3. Mineral Industry
3.1
10.1
Production of cement
Draft (V3)
Published
Draft (V3)
Published
Published
3.2
13.3
1.1
3.3
3.4
4.3
4.2
Lime production
The extraction, production & processing of raw
asbestos
The production of glass
Manfu. of glass fibre or mineral products fibre
3.5
13.4
Coarse ceramics
Draft (V3)
Awaiting draft
Draft (V1)
Draft (V1)
Draft(V3)
Page 3 of 132
IPPC
Directive
Annex 1
Category
Equivalent
Description of Activity per EPA Act 1992, First
BATNEEC NOTE
EPA Act
Schedule
1992, First
Schedule
Category
4. Chemical Industry - Published Chemical Note covers all activities 4.1 – 4.6
5.2
The manufacture of olefins and their derivatives or of monomers and polymers,
4.1(a)
including syrene and vinyl chloride
5.3
The manufacture, by way of chemical reaction processes, of organo or organometallic chemical products other than those specified at 5.2
5.4
5.3
The manufacture of inorganic chemicals
The manufacture, by way of chemical reaction processes, of organo or organometallic chemical products other than those specified at 5.2
5.9
The chemical manufacture of glues, bonding agents and adhesives
4.1(c)
5.4
5.3
The manufacture of inorganic chemicals
The manufacture, by way of chemical reaction processes, of organo or organometallic chemical products other than those specified at 5.2
4.1(d)
5.4
5.3
The manufacture of inorganic chemicals
The manufacture, by way of chemical reaction processes, of organo or organometallic chemical products other than those specified at 5.2
5.4
The manufacture of inorganic chemicals
5.9
5.3
The chemical manufacture of glues, bonding agents and adhesives
The manufacture, by way of chemical reaction processes, of organo or organometallic chemical products other than those specified at 5.2
5.4
The manufacture of inorganic chemicals
4.1(f)
5.3
4.1(g)
5.3
4.1(h)
5.2
4.1(i)
5.3
4.1(j)
5.7
4.1(k)
5.3
The manufacture, by way of chemical reaction processes, of organo or organometallic chemical products other than those specified at 5.2
The manufacture, by way of chemical reaction processes, of organo or organometallic chemical products other than those specified at 5.2
The manufacture of olefins and their derivatives or of monomers and polymers,
including syrene and vinyl chloride
The manufacture, by way of chemical reaction processes, of organo or organometallic chemical products other than those specified at 5.2
The manufacture of paints, varnishes, resins, inks, dyes, pigments or elastomers
where the production capacity exceeds 1,000 litres per week
The manufacture, by way of chemical reaction processes, of organo or organometallic chemical products other than those specified at 5.2
4.2(a)
4.2(b)
4.2(c)
4.2(d)
4.2(e)
4.3
4.4
5.4
5.4
5.4
5.4
5.4
5.4
5.5
5.6
4.5
5.6
4.1(b)
4.1(e)
5.3
4.6
5.4
The manufacture of inorganic chemicals
The manufacture of inorganic chemicals
The manufacture of inorganic chemicals
The manufacture of inorganic chemicals
The manufacture of inorganic chemicals
The manufacture of inorganic chemicals
The manufacture of artificial fertilizers
The manufacture of pesticides, pharmaceutical or vetinary products and their
intermediates
The manufacture of pesticides, pharmaceutical or vetinary products and their
intermediates
The manufacture, by way of chemical reaction processes, of organo or organometallic chemical products other than those specified at 5.2
The manufacture of inorganic chemicals
Page 4 of 132
IPPC
Directive
Annex 1
Category
Equivalent
WM Act
1996, Third
& Fourth
Schedule
Category
5. Waste Management
5.1
Sched. 4,
classes
1,3,5,6,7,&
9
5.2
Sched. 3,
Class 8
5.3
5.4
Sched. 3,
Classes
1&5
IPPC
Equivalent
Directive
EPA Act
Annex 1
1992, First
Category
Schedule
Category
6. Other Activities
6.1(a)
8.2
Description of Activity per EPA Act 1992, First
Schedule
BATNEEC NOTE
Disposal or recovery of hazardous waste
Published
Incineration of municipal waste
Disposal of non-hazardous waste
Landfills
Description of Activity per EPA Act 1992, First
Schedule
Pulp & Paper manufacture
BATNEEC NOTE
Note covers 8.1 manfu. of
paper pulp & paper &
8.2(V3) manfu. of
bleached pulp.
Published
Published
6.1(b)
6.2
8.1
8.5
6.3
6.4(a)
6.4(b)
8.6
7.4
7.1
Board manufacture
Dyeing, treatment or finishing of fibres or textiles
including carpet
Fell-mongering & tanning
The slaughter of animals
Manufacture of vegetable & animal oils & fats
7.5
Manufacture of fish-meal and fish-oil Draft (V3)
Draft (V3)
7.6
Manufacture of sugar
Published
6.4(c)
6.5
6.6(a)
6.6(b)
7.7
7.2
7.7
6.1
6.2
Rendering of animals by-products.
Manufacture of dairy products
Rendering of animals by-products.
The rearing of poultry
The rearing of pigs
Published
Draft (V3)
Published
Published
Published
6.6(c)
6.7
6.2
12.2
Published
Published
6.8
9.4
The rearing of pigs
Manufacture or use of coating materials using
organic solvents
Carbonisation, gasification etc. of coal, lignite,
oil, bituminous shale
Page 5 of 132
Draft (V4)
Published
Draft (V3)
Draft (V3)
Extract from EPA Batneec Guidance Note For The Extraction of
Alumina
4.
4.1
CONTROL TECHNOLOGIES
Introduction
As explained in Section 2, this Guidance Note identifies BATNEEC but
obviously does so in the absence of site-specific information. Accordingly, it
represents the requirements expected of any new activity covered by the Note,
but does not exclude additional requirements which may form part of the
granting of a licence for a specific site.
The approach to be used in selecting BATNEEC is based on the following
hierarchy:

Process design / redesign changes to eliminate emissions and wastes that
might pose environmental problems.

Substitution of materials (e.g. low sulphur fuel) by environmentally less
harmful ones.

Demonstration of waste minimisation by means of process control,
inventory control and end-of-pipe technologies etc.

Use of energy efficient technologies, such as combined heat and power
generation, when appropriate.
The existing or possible measures for reducing and controlling emissions are
described in this section. These range from relatively simple containment
measures to sophisticated recovery and end-of-pipe technologies and include:
(i)
(ii)
(iii)
(iv)
(v)
Load minimisation
Containment
Recovery/recycle
Emission reduction
Waste treatment and disposal.
The technical feasibility of the measures listed below has been demonstrated by
various sources. Used singly or in combination, the measures represent
BATNEEC solutions when implemented in the appropriate circumstances. The
circumstances depend on plant scale, materials used, grade of product made, etc.
A summary of the treatments for various emissions is given at the end of the
section.
4.2
Technologies for load minimisation
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
Page 6 of 132









4.3
Containment of emissions
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).











4.4
Save for bulk tanks, enclosure of materials, storage, handling, processing and
transfer within a suitable building.
Closed transfer systems for raw and process materials.
Bunding of tanks.
Management of mud-stack to minimise dust blow-off (e.g. use of crusting
agents, cover material etc.).
Overground pipelines and transfer lines.
Only totally enclosed conveyors to be used.
Overfilling protection on bulk storage tanks.
Prevention of rain ingress, wind entrainment etc. for stored materials.
Heat recovery to be used where practicable.
Local extract systems as appropriate.
Condensers on all appropriate process equipment.
Technologies for recovery and recycle
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).




4.5
Use of high aluminium content Bauxite.
Optimisation of energy recovery and usage.
Inventory control.
Optimisation of water and condensate usage.
Separation of cooling water, storm water and process effluents of
different origin in order to permit appropriate treatment options.
Use of low sulphur fuels when economically feasible.
Optimised design and engineering of mud-stack to minimise surface and
ground water contamination.
Selection of process/plant design to maximise alumina yield.
Design of receiving hoppers and of finished product loading systems to
minimise fugitive dust releases (especially at jetties).
Countercurrent washing of wastes for alumina and caustic recovery.
Recovery of condensate for reuse.
Reuse of collected dusts.
Recycle of effluent/ storm water run-off streams where appropriate.
Technologies for treating air emissions
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
(Symbols refer to Table 4.1).

Electrostatic precipitors (T1).
Page 7 of 132



4.6
Technologies for treating water emissions
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
(Symbols refer to Table 4.2)




4.7
Bag Filters (T2).
Cyclones (T3).
Wet Scrubbers (T4).
pH Correction/neutralisation (F1).
Coagulation/flocculation/precipitation (F2).
Sedimentation/filtration/floatation (F3).
Centrifugation (F4).
Technologies for the treatment and disposal of wastes
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
4.7.1 Sludge Treatment




Gravity thickening.
Dissolved air flotation.
Filtration.
Centrifugation.
4.7.2 Disposal


Engineered landfill of wastes.
Reuse in another industry.
Table 4.1 - Summary of Technologies for Treating Air Emissions
(Symbols refer to section 4.5)
Emission Type
Technology
Dust
T1, T2, T3
Off Gases (Sodium salt treatment)
T4
Page 8 of 132
Table 4.2 - Summary of Technologies for Treating Water Emissions
(Symbols refer to section 4.6)
5.
5.1
Emission Type
Technology
Suspended Solids
F2, F3, F4
Alkali/ Acid
F1
EMISSION LIMIT VALUES
Reference Conditions
The reference conditions for concentrations of substances in emissions to air from
contained sources are:
For combustion sources (including calciner)
Temperature 273 K; Pressure 101.3 kPa; 11% oxygen, no correction for water
vapour content.
For non-combustion sources
Temperature 273 K; Pressure 101.3 kPa; no correction for water vapour content
These units and reference conditions may not be suitable for continuous
monitoring methods and may, by agreement with the Agency, be converted, for
day-to-day control purposes, into values more suitable for the available
instrumentation.
Page 9 of 132
5.2
Interpretation of Compliance
Unless otherwise detailed in the licence, the following interpretation of
compliance with limit values should apply.
(Achievement of ELV concentration by the introduction of dilution air is not
permitted)
5.2.1 Emissions to Air
For continuously monitored emissions, the following will be required for
compliance with measurements based on 30 minute mean values (unless
otherwise stated):
(i)
97% of all 30 minute mean measurements shall be below 1.2 times the
emission limit.
(ii)
No 30 minute mean measurement shall exceed 2.0 times the emission
limit.
(iii)
All daily mean values shall be less than the emission limit.
Where periodic monitoring is used to check compliance, all samples should
meet the consent conditions.
5.2.2 Emissions to Waters
The limit values for discharges to water are based on 24 hour flow proportional
composite samples unless otherwise specified.
5.3
Emissions to Air
Emission Limit Values representing BATNEEC are given in Table 5.1 below.
Table 5.1 - Emission Limit Values for Emissions to Air
Emission
Total Particulate Matter (Calciner)
Limit Value
50 mg/m3
Note 1: Achievement of ELV concentrations by the introduction of dilution air is not
permitted
Page 10 of 132
5.4
Emissions to Water
Effluent should be minimised by recovery of materials wherever practicable. The
use of lower quality water may be possible for some parts of the process rather
than fresh water.
All releases to waters are subject to a licence from the Agency. However, any
discharge to a sewer will require the consent of the sanitary authority.
BATNEEC to minimise the release of substances will generally include
minimisation at source and either specific treatment of contaminated waste
streams to remove particular substances or co-treatment of combined effluent
streams or both. The Emission Limit Values for effluent discharges to waters are
set out in Table 5.2.
Table 5.2 - Emission Limit Values for Emissions to Water*
Constituent Group
or Parameter
pH
BOD (mg/l)
Toxic Units
Total Nitrogen (as N)**
Total Phosphorus (as P)**
Oils, Fats and Grease (mg/l)
Fish Tainting
Mineral Oil (Interceptor) (mg/l)
Limit Value
Notes
6-9
3
As per Licence
(based on presence in raw materials)
5
1,3
>80% Removal
3,4
or 15 mg/l
>80% Removal
3,4
or 2 mg/l
15
3
No Tainting
2,3
20
3
Metals
*
As per Licence
(based on presence in raw materials)
All values refer to daily averages, except where otherwise stated to the contrary,
and except for pH which refers to continuous values. Limits apply to effluent
prior to dilution by uncontaminated waters, e.g. cooling waters or storm waters.
** Only applicable to waters subject to eutrophication. One or both limits may apply
depending on the sensitivity of the receiving waters.
Notes for Table 5.2:
Page 11 of 132
1.
Toxicity Unit (TU) = 100/x hour E(L)C 50 in percentage vol/vol, where x
is defined by the test procedure. The toxicity of the process effluent to at
least two appropriate aquatic species shall be determined. Higher TU
values reflect greater levels of toxicity.
2.
No substances shall be discharged in a manner which, or at a concentration
which, following initial dilution, causes tainting of fish or shellfish,
interferes with normal patterns of fish migration or which accumulates in
sediments or biological tissues to the detriment of fish, wildlife or their
predators.
3.
Consent conditions for these parameters for discharge to municipal
treatment plants can be established with the Licensing Authority, and
different values may apply.
4.
Reduction in relation to influent load. Total nitrogen means the sum total of
Kjeldahl-Nitrogen plus nitrate-nitrogen plus nitrite-nitrogen.
Page 12 of 132
Extract from EPA Batneec Guidance Note For Board Manufacture
4.
CONTROL TECHNOLOGIES
4.1
Introduction
As explained in Section 2, this Guidance Note identifies BATNEEC but obviously
does so in the absence of site-specific information. Accordingly, it represents the
requirements expected of any new activity covered by the Note, but does not
exclude additional requirements which may form part of the granting of a licence
for a specific site.
The approach to be used in selecting BATNEEC is based on the following
hierarchy:

Process design / redesign changes to prevent emissions and eliminate
wastes that might pose environmental problems.

Substitution of materials / resins etc. by environmentally less harmful ones.

Demonstration of waste minimisation by means of process control,
inventory
control and end-of-pipe technologies etc.
The existing or possible measures for reducing and controlling emissions are
described in this section. These range from relatively simple containment
measures to sophisticated recovery and end-of-pipe technologies and include:
(i)
(ii)
(iii)
(iv)
(v)
Load minimisation
Containment
Recovery/Recycle
Emission reduction
Waste treatment and disposal.
The technical feasibility of the measures listed below has been demonstrated by
various sources. Used singly or in combination, the measures listed below
represent BATNEEC solutions when implemented in the appropriate
circumstances. The circumstances depend on plant scale, chemicals used, nature of
the products made, number of different products produced, etc. A summary of the
treatments for various emissions is given at the end of the section.
Note that where flammable/explosive vapours or dusts are handled, safety
procedures (acceptable to HSA) should be adopted and nothing in this note should
be construed as advice to the contrary.
4.2 Technologies for load minimisation
Page 13 of 132
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and site constraints).










4.3
Inventory control.
Optimisation of water usage.
Dry equipment cleaning and dry vacuum systems, where feasible.
Minimum number of controlled emission points for all large dedicated plants.
Separation of cooling water, storm water and process effluents of different origin
in order to permit appropriate treatment options.
Use of low NOx burner technology.
Maximum use of covered storage for wood chips, sawdust etc.
Avoidance of excessive drier temperatures.
Selection of most environmentally favourable resins and adhesives.
Optimisation of heat recovery (including abatement systems).
Containment of emissions
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).








4.4
Enclosure of material storage (other than logs and bulk liquids), handling,
processing and transfer within a suitable building.
Bunding of tanks.
Overground pipelines and transfer lines.
Check system to avoid mixing incompatible materials.
Bunding of all stored materials with separate bunding for incompatibles.
Prevention of rain ingress, wind entrainment etc. for stored materials.
Local extraction systems as appropriate e.g. sanders, surface coating, trimming
etc.
Overfilling protection on bulk storage tanks.
Technologies for recovery and recycle
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).



Recycle of waferised/fiberised material.
Reuse of trimmings, collected dusts, bark and sludges (as appropriate) as fuel.
Chemically treated wood (e.g. sander dust and off cuts) should only be burned
where suitable combustion conditions are assured).
 Ducting of burner exhausts to drier inlets.
 Reuse in another industry (e.g. bark, chippings etc.).
4.5
Technologies for treating air emissions
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
(Symbols refer to Table 4.1)



Cyclones (T1).
Bag filters (T2).
Wet electrostatic precipitators (T3).
Page 14 of 132



4.6
Vapour incineration (T4).
Wet scrubbers (T5).
Biofilters as final air treatment (T6).
Technologies for treating water emissions
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
(Symbols refer to Table 4.2)
4.6.1 Primary Treatment
 Coagulation/flocculation/precipitation (F1).
 Sedimentation/filtration/floatation (F2).
4.6.2 Secondary Treatment
 Biofilters (F3).
 Activated sludge/aeration lagoons (F4).
 Extended aeration (F5).
 Nitrification/denitrification (F6).
4.6.3 Tertiary Treatment
 Filtration/coagulation/precipitation (F7).
4.7
Specific technologies for the treatment and disposal of wastes
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
4.7.1 Sludge Treatment
 Gravity thickening.
 Dissolved air floatation.
 Filtration.
 Centrifugation.
 Sludge digestion.
 Drying.
4.7.2 Disposal
 Engineered landfill of wastes.
 Landspreading of wastes (as fertiliser).
 Recycle of process wastes to other industries.
Page 15 of 132
Table 4.1 - Summary of Technologies for Treating Air Emissions
Emission Type
Large Particulates
Technology
(Symbols refer to section 4.5)
T1
Small Particulates
T2, T3
Organics (VOCs, adhesives, phenols,
aldehydes etc.
Ammonia
T3, T4, T5, T6
Carbon Monoxide
T4
NOx
-
T5
Table 4.2 - Summary of Technologies for Treating Water Emissions
Emission Type
Organics (incl. phenols)
Technology
(Symbols refer to section 4.6)
F1, F2, F3, F4, F5
Ammonia/Nitrate
F6
Trace Organics
F7
Page 16 of 132
5.
Emission Limit Values
5.1
Reference Conditions
The reference conditions for concentrations of substances in emissions to air from
contained sources are:
All sources except Direct Fired Wood Driers :
Temperature 273K; Pressure 101.3 kPa; no correction for water vapour content.
Direct Fired Wood Driers :
Temperature 273K; Pressure 101.3 kPa; no correction for water vapour content,
oxygen 17% v/v.
These units and reference conditions may not be suitable for continuous
monitoring methods and may, by agreement with the Agency, be converted, for
day-to-day control purposes, into values more suitable for the available
instrumentation.
5.2
Interpretation of Compliance
Unless otherwise detailed in the licence, the following interpretation of
compliance with limit values should apply:
5.2.1 Air emissions
For continuously monitored emissions, the following will be required for
compliance with measurements based on 30 minute mean values (unless
otherwise stated):
(i)
97% of all 30 minute mean measurements shall be below 1.2 times the
emission limit.
(ii)
No 30 minute mean measurement shall exceed 2.0 times the emission
limit.
(iii)
All daily mean values shall be less than the emission limit.
Where periodic monitoring is used to check compliance, all samples should
meet the consent conditions.
5.2.2 Emissions to waters
The limit values for discharges to water are based on 24 hour flow proportional
composite samples unless otherwise specified.
Page 17 of 132
5.3
Releases to Air
All emissions to air should be free from persistent mist, fume and droplets and,
other than steam or water vapour, should be colourless.
Emission Limit Values representing BATNEEC are given in Table 5.1 below.
Table 5.1 - Emission Limit Values for Emissions to Air
Parameter
Emission Limit
Particulates (wood driers and MDF plants)
Particulates (other than above)
Condensible VOCs (as C)
(excluding particulate matter)
CO
Formaldehyde (excluding Wood Driers)
Formaldehyde (Wood Driers)
Total Aldehydes (Wood Driers) (as C)
Total Ammonia
MDI (as NCO group)
NOx
Pulverised Fuel fired plant
(>20 MW) or Grate Fired plant
(not burning coated residues)
All other plant
Phenol
Odour
20 mg/m3
50 mg/m3
130 mg/m3
*
5 mg/m3
20 mg/m3
20 mg/m3
70 mg/m3
0.1 mg/m3 (2 hr. mean)
400 mg/m3
500 mg/m3
20 mg/m3
No detectable odour nuisance beyond site
boundary
Note 1: Achievement of ELV concentrations by the introduction of dilution air is not permitted
* To be determined at time of licensing
5.4 Releases to Water
Effluent should be minimised by recovery of materials wherever practicable. The use
of lower quality water may be possible for some parts of the process rather than fresh
water.
All releases to waters are subject to a licence from the Agency. However, for any
discharge to a sewer, the Agency are also required to obtain the consent of the sanitary
authority. BATNEEC to minimise the release of substances will generally include
minimisation at source and either specific treatment of contaminated waste streams to
remove particular substances or co-treatment of combined effluent streams or both.
The Emission Limit Values for effluent discharges to waters are set out in Table 5.2.
Page 18 of 132
Table 5.2 - Emission Limit Values for Discharge to Water*
Constituent Group
or Parameter
pH
BOD
Total Ammonia (mg/l as N)
Total Nitrogen (as N)**
Total Phosphorus (as P)**
Oils, fats and grease (mg/l)
Fish Tainting
Mineral Oil (Interceptor) (mg/l)
Toxic units
Phenols (mg/l)
Limit Value
Notes
6-9
> 90% removal
or 50 mg/l
10
>80% Removal
or 15 mg/l
>80% Removal
or 2 mg/l
10
No Tainting
20
5
1
4
1,4
4
4,5
4,5
4
3,4
4
2,4
4
*All values refer to daily averages, except where otherwise stated to the contrary,
and except for pH which refers to continuous values. Limits apply to effluent
prior to dilution by any uncontaminated streams, e.g. cooling waters, storm water,
etc.
** Only applicable to waters subject to eutrophication. One or both limits may apply
depending on the sensitivity of the receiving water.
Notes for Table 5.2:
1.
The daily raw waste load for BOD is defined as the average daily mass
arising for treatment over any three month period.
Calculations of the removal rates for BOD should be based on the
differences between the waste loads arising for disposal and those
discharges to the receiving waters. The amounts removed by treatment
(chemical, physical, biological) may be included in the calculation.
2.
Toxicity Unit (TU) = 100/x hour E(L)C 50 in percentage vol/vol, where x
is defined by the test procedure. The toxicity of the process effluent to at
least two appropriate aquatic species shall be determined. Higher TU
values reflect greater levels of toxicity.
3.
No substances shall be discharged in a manner which, or at a concentration
which, following initial dilution, causes tainting of fish or shellfish,
interferes with normal patterns of fish migration or which accumulates in
sediments or biological tissues to the detriment of fish, wildlife or their
predators.
Page 19 of 132
4.
Consent conditions for these parameters for discharge to municipal
treatment plants can be established with the Licensing Authority, and
different values may apply.
5.
Reduction in relation to influent load. Total nitrogen means the sum total of
Kjeldahl-Nitrogen plus nitrate-nitrogen plus nitrite-nitrogen.
Page 20 of 132
Extract from EPA Batneec Guidance Note For The Chemical Sector
4.
4.1
CONTROL TECHNOLOGIES
Introduction
As explained in Section 2, this Guidance Note identifies BATNEEC, but
obviously does so in the absence of site-specific information. Accordingly, it
represents the requirements expected of any new activity covered by the Note,
but does not exclude additional requirements which may form part of the
granting of a licence for a specific site.
The approach to be used in selecting BATNEEC is based on the following
hierarchy:
Process design / redesign changes to eliminate emissions and wastes that
might pose environmental problems.

Substitution of materials / solvents etc. by environmentally less harmful ones.

Demonstration of waste minimisation by means of process control, inventory
control and end-of-pipe technologies etc.
The existing, or possible measures for reduction and control of emissions are
described in this section. These range from relatively simple containment
measures to sophisticated recovery and end-of-pipe technologies and include:
(i)
Load Minimisation
(ii)
Containment
(iii) Recovery/recycle
(iv) Emission reduction
(v)
Waste treatment & disposal.
The technical feasibility of the measures listed below has been demonstrated
by various sources. Used singly or in combination, these measures represent
BATNEEC solutions when implemented in the appropriate circumstances. The
circumstances depend on plant scale, chemicals used, nature of the products made,
number of different products produced, degree of plant integration etc. A summary of
the treatments for various emissions is given at the end of this section. Note that,
where flammable / explosive dusts or vapours are handled, safety procedures
(acceptable to HSA) should be adopted and nothing in this note should be construed
as advice to the contrary.
4.2 Technologies for load minimisation :
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints)
Page 21 of 132










Improved phase separation in the process.
Optimisation of vacuum condensation efficiency.
Additions of reagents to reactors via sluice valves.
Optimised separation of product and solvent in the filtration or
centrifugation step prior to final drying.
Inventory control.
Optimisation of water usage.
Countercurrent product rinsing.
Mother liquor treatment (recuperation, oxidation).
Dry equipment cleaning and dry vacuum systems, where feasible.
Separation of cooling water, storm water and process effluents of different
origin in order to permit appropriate treatment options.
4.3 Containment of Emissions :
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints)



































Enclosure of materials (excluding bulk liquids), storage, handling,
processing and transfer within a suitable building.
Minimisation of tank filling losses by, e.g., vapour return systems.
Secondary containment of relief valve or bursting disk discharges from
reactors.
Low loss vacuum pumps, e.g., dry vacuum pumps, once-through oil
pumps, cryogenic solvent as pump seal liquid.
Covered basins in WWTP to contain VOC losses.
Vent collection and ducting from tank farms to central abatement
systems.
Vent collection and ducting from reactors to central abatement systems.
Closed transfer systems from reactors to centrifuges to filters to dryers.
Bunding of tanks.
Single controlled emission point for all large dedicated plants.
Minimisation of tank breathing losses by pressure vacuum valves,
isolation and/or tanks painted white.
Overground pipelines and transfer lines.
Floating roofs on bulk storage tanks.
Storage of delivered materials pending detailed analysis.
Check system to avoid mixing incompatible materials.
Bunding of all stored materials with separate bunding for incompatibles
Overfilling protection on bulk storage tanks.
Prevention of rain ingress, wind entrainment etc. for stored materials.
4.4 Technologies for recovery and recycling:
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints)
 Waste air streams with relatively high solvent loads, especially those after
drying, distillation/condensation or vacuum filtration should be subjected to an
effective treatment, primarily aimed at recovery.
Page 22 of 132












Separate organic and aqueous phase drains from process buildings .
Interceptor tanks at each process building.
On-site solvent recovery plants.
Off-site solvent recovery.
Water condensers on reactor overheads.
Refrigerated condensers on reactor overheads.
Cryogenic condensation on reactor overheads.
Carbon adsorption/desorption on vapour streams containing organics.
Organic liquid absorption/desorption on vapour streams containing organics.
Polymer adsorption/desorption on vapour streams containing organics.
Aqueous scrubbing with solvent recovery.
Optimisation of condensation capacity after distillation resulting in at least
95% efficiency for all solvents in multi-purpose plants and at least 99% for
dedicated plants.
 Reuse in another industry.
4.5 Technologies for treating air emissions:
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints)
References in brackets are explained in Table 4.5.1
 Biofilters as final air treatment.(T1)
 Selective chemical reaction scrubbers, e.g., hypochlorite scrubbers for odour
control of mercaptans, NaOH scrubbers for acid removal.(T2)
 Aqueous scrubbing of soluble VOCs for liquid phase biodegradation in
WWTP.(T3)
 Cyclones for removal of fermenter aerosol.(T4)
 Steam sterilisation of fermenter exhausts.(T5)
 HEPA and bag filters.(T6)
 Wet electrostatic precipitators.(T7)
 Vapour incineration - thermal.(T8)
 Vapour incineration - catalytic and regenerative (for non-chlorinated solvent
streams).(T9)
 Flares. (T10)
Table 4.5.1. Summary of Technologies for Treating Air Emissions.
Emission Type
Technologies
VOCs/Organics
Odours
Organisms
Halogens & compounds
Sulphur & compounds
Phosphorus & compounds
Nitrogen & compounds
Carbon oxides
Particulates, metals, metalloids and
compounds
T2, T3, T8, T9, T10.
T1, T2, T8, T9.
T5, T6.
T2
T2
T2
T2, T10
-T4, T6, T7
Page 23 of 132
Acid gases
T2
4.6 Technologies for treating water emissions:
(No priority ranking is intended, and appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints.)
4.6.1
Pre-Treatment:
 Air stripping of effluents for recovery or treatment.(VOCs)
 Steam stripping of effluents for recovery or treatment.(Organics)
 Steam or air stripping for removal of organohalogens and aromatic
hydrocarbons prior to WWTP. (These streams should be treated as close to
the source as possible and should not be transported in open sewer systems on
site. The air or steam used should be subject to recovery)
 Precipitation. (Heavy metals)
 Oxidation .(Cyanides)
4.6.2
Primary Treatment:
 pH Correction / neutralisation. (acids and alkalis)
 Coagulation / flocculation / precipitation. (dissolved and colloidal solids)
 Sedimentation / filtration / floatation. (solids removal)
4.6.3






Secondary Treatment:
Biofilters. (organic treatment for BOD removal)
Anaerobic treatment. (organic treatment for BOD removal)
Wet air oxidation. (organic treatment for BOD removal)
Activated sludge / aeration lagoons. (organic treatment for BOD removal)
Extended aeration. (organic treatment for BOD removal)
Nitrification / denitrification. (treatment of nitrogen compounds)
4.6.4 Tertiary Treatment:




Filtration, coagulation, precipitation. (solids and phosphate removal)
Ozonation/Oxidation. (trace organics)
Activated Carbon polishing.(trace organics)
Resin beds. (dissolved solids)
4.6.5 Sludge Treatment:






Gravity thickening.
Dissolved air floatation.
Filtration.
Centrifugation.
Sludge digestion.
Drying.
Page 24 of 132
4.7 Technologies for the treatment and disposal of wastes:
(No priority ranking is intended, and appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints.).




5.
5.1
Incineration. (Incinerator emissions are the subject of a separate note)
Waste encapsulation.
Vitrification of waste.
Engineered landfill of wastes.
EMISSION LIMIT VALUES
Reference Conditions
The reference conditions for concentrations of substances in emissions to air
from contained sources are:
For non-combustion gases :
Temperature 273 K; Pressure 101.3 kPa; no correction for water vapour
content.
For combustion gases:
Temperature 273 K; Pressure 101.3 kPa; dry gas.
Oxygen content 3% (dry) for liquid and gaseous fuels, 6% (dry) for solid
fuels.
These units and reference conditions may not be suitable for continuous
monitoring methods and may, by agreement with the Agency, be converted for
day-to-day control purposes into values more suitable for the available
instrumentation.
5.2
Interpretation of Compliance
Unless otherwise detailed in the license, the following interpretation of
compliance with limit values should apply.
(Achievement of ELV concentrations by the introduction of dilution air is not
permitted.).
Page 25 of 132
5.2.1 Air emissions
For continuously monitored emissions, the following will be required for
compliance with measurements based on 30 minute mean values (unless
otherwise stated):
(i)
97% of all 30 minute mean measurements shall be below 1.2 times
the emission limit.
(ii)
No 30 minute mean measurement shall exceed 2.0 times the emission
limit.
(iii)
All daily mean values shall be less than the emission limit.
Where periodic monitoring is used to check compliance, all samples should
meet the consent conditions.
5.2.2 Emissions to waters
The limit values for discharges to water are based on 24 hour flow proportional
composite samples, unless otherwise specified.
5.3
Releases to Air
Emission Limit Values representing BATNEEC are given in Tables 5.1.-5.7
below. Where a substance appears in more than one table, the values in Tables
5.1 - 5.3 take precedence over the specific material values in Table 5.4. Table
5.5 applies only for substances not listed in the earlier table.
Page 26 of 132
Table 5.1 - Emission Limit Values for Fertiliser Production
Process
Ammonium nitrate
production
Source
Emission
Limit Value
(mg/m3)
Prill towers
Particulate
15
10
Ammonia
Ammonium nitrate
production
Neutralisers/reactors/coolers/
driers
Particulate
Ammonia
Ammonium nitrate
production
Evaporators
Particulate
30
50
15
50
Ammonia
Ammonium phosphate
production
Particulate
15
10
Ammonia
Other fertiliser production
- Particulate
- Sulphur oxides (as
50
200
- Nitrogen oxides (as
200
50
10
SO2)
NO2)
- Ammonia
- Fluorides (as HF)
Note : Achievement of ELV concentration by the introduction of dilution air is not
permitted
Page 27 of 132
Table 5.2 - Emission Limit Values for Sulphuric Acid Production
Process
New process
Minimum Conversion Rate
(SO2 to SO3)
Steady state:
99.7%
Start up (hourly ave. for first 5 hours):
98%
Note : Achievement of ELV concentration by the introduction of dilution air is not
permitted
Table 5.3 - Emission Limit Values for Ammonia Production
Source
Steam Reforming Plants
Emission
Emission Limit
Value (mg/m3)
Nitrogen oxides (as NO2 at 3% O2)
Sulphur dioxide( Natural Gas fuelled)
2
Carbon monoxide
10
Diffuse emissions
Nitrogen oxides (Non-continuous
emissions
as NO2 )
1 t/a
Partial Oxidation Plants steam superheater flue gas
20 kg/h
40 g NH3/t NH3
Purge Gas Scrubber
Partial Oxidation Plants auxiliary boiler flue gas
450
produced
1700
Sulphur dioxide
Nitrogen oxides (as NO2)
Carbon monoxide (Hourly maximum)
(Daily average)
Particulates
(Hourly maximum)
(active ingredient) (Daily average)
Nitrogen oxides (as NO2)
700
175
10
50
10
450
Sulphur dioxide (Natural Gas fuelled)
2
Carbon monoxide
30
Hydrogen sulphide
0.3
Methanol
100
Note : Achievement of ELV concentration by the introduction of dilution air is not
permitted
Page 28 of 132
Table 5.4 - Emission Limit Values for Specific Materials
(Not already covered by Tables 5.1-5.3)
mg/m3
PARAMETER
Mass Flow
Threshold for
ELVs
(Note 1)
Cadmium
0.1
>1 g/hr
Chlorides (as HCl)
10
>0.3 kg/hr
Iodides (as HI)
5
>50 g/hr
Carbon disulphide
5
>0.1 kg/hr
Hydrogen cyanide
2
>50 g/hr
Mercaptans
2
>0.1 kg/hr
Amines (total)
10
>0.1 kg/hr
Trimethylamine
2
>0.1 kg/hr
Phenols & cresols & xylols
10
>0.1 kg/hr
5
>0.1 kg/hr
0.15
>1 g/hr
0.15
>1 g/hr
Bromine
10
>50 g/hr
Chlorine
10
>50 g/hr
Iodine
10
>50 g/hr
Mercury
0.1
>1 g/hr
Total Heavy Metals
1.5
>5 g/hr
Nitrogen oxides (as NO2)
300
>3 kg/hr
Sulphur oxides (as SO2)
300
>3 kg/hr
Particulates - general
Ethylene dichloride
(1,1,dichloroethylene)
20
>0.5 kg/hr
5
>0.1 kg/hr
Acrylonitrile
20
>0.1 kg/hr
Toluene di-isocyanate
1
>0.1 kg/hr
Ethyl acrylate
1
Note 2
Isobutyl acrylate
1
Note 2
Methyl acrylate
5
Note 2
n-Butyl acrylate
5
Note 2
t-Butyl and higher acrylate esters
Dust - as active ingredient.
20
Note 2
1,2 - Dichloroethane
Dust - pesticide contaminated
1
Dust - pharmaceutical1
1
Page 29 of 132
Note 1: Achievement of ELV concentration by the introduction of dilution air is not
permitted
Note 2: Only applicable to vents from bulk storage ( > 20 tonnes )
Table 5.5- Emission Limit Values for General Emissions to Air (excluding
incinerator
emissions) for materials not already covered by Tables 5.1-5.4
(Note: The emission limit values contained in Tables 5.1 - 5.4 take precedence over those below.)
Constituent Group *
or Parameter
Carcinogenic Substances
Inorganic Dust Particles
Vaporous or Gaseous
Inorganic Substances
Organic Substances with
Photochemical Ozone
Potential - POCP
Organic Substances
(Note 2)
General Dusts
Pharmaceutical and
Pesticide Dust - as active
Class
T.A. Luft I
T.A. Luft II
T.A. Luft III
Substances (other
than those above)
with R45 designation
T.A. Luft I
T.A. Luft II
T.A. Luft III
T.A. Luft I
T.A. Luft II
T.A. Luft III
T.A. Luft IV
U.K. AEA 1
U.K. AEA 2
T.A. Luft I
T.A. Luft II
T.A. Luft III
Mass Flow
Threshold for ELV
(Note 1)
> 0.5 g/hr
>5.0 g/hr
>25.0 g/hr
>0.5 kg/hr
Emission Limit
Value (mg/m3)
>1 g/hr
>5 g/hr
>25 g/hr
>10 g/hr
>50 g/hr
>0.3 kg/hr
>5.0 kg/hr
>0.5 kg/hr
>2.0 kg/hr
0.2
1.0
5.0
1
5
30
500
20
50
>0.1 kg/hr
>2.0 kg/hr
>3.0 kg/hr
<0.5 kg/hr
>0.5 kg/hr
>1g/hr
20
100
150
150
20
0.15
0.1
1.0
5.0
5.0
ingredient
Fugitive Emissions
(Note 3)
* Where a substance falls into more than one category in Table 5.5, the lower emission limit
value applies.
Note : Achievement of ELV concentration by the introduction of dilution air is not
permitted
Page 30 of 132
Notes for Tables 5.4 and 5.5:
1. The Mass Flow is calculated in kg/hr for the raw gas and is determined at
the point before any gas cleaning or abatement plant, but after any devices
inherent in the process (e.g. after reactor overhead condensers; after
product cyclones etc.). Mass Flow is the maximum emission which can
occur over any one hour period of plant operation, from the entire site.
Where the Mass Flow exceeds the mass threshold given in the Guidance
Note, then abatement will be required down to the appropriate emission
limit value (ELV), unless the concentration of the raw gas is already
below the ELV, in which case no further abatement is required.
(In other words, if the raw gas concentration is below the ELV, the mass
flow is not relevant)
5.4
2.
Where organic substances of several classes are present, in addition to the
above limit, the sum of Classes 1 & 2 shall not exceed the Class 2 limit
and the sum of Classes 1, 2 & 3 shall not exceed the Class 3 limit etc.
3.
Fugtive solvent emissions should comply with the requirements of
proposed E.C. Solvent Directive or licence as appropriate.
4.
It should be noted that emissions which fall below the Mass Emission
threshold may still be considered at the time of licensing in order to
minimise these as much as possible.
Releases to water
Effluent load should be minimised by recovery of materials wherever
practicable. The use of lower quality water may be possible for some parts of
the process rather than fresh water.
Excluding uncontaminated stormwaters, all releases to waters are subject to a
licence from the Agency. However, any discharge to a sewer will require the
consent of the local authority or sewerage undertaker. BATNEEC to minimise
the release of substances will generally include minimisation at source and
either specific treatment of contaminated waste streams to remove particular
substances or co-treatment of combined effluent streams or both. The Emission
Limit Values for effluent discharges to waters are set out in Table 5.6.
Page 31 of 132
Table 5.6 - Emission Limit Values for Discharges to Water*
All values shown apply prior to dilution of effluent by uncontaminated streams, e.g.
stormwaters, cooling waters, etc.
Constituent Group
or Parameter
pH
Number of Toxicity Units
Total Nitrogen (mg/1 as N)
Total Phosphorus (mg/1 as P)
Total Ammonia (mg/1 as N)
Oils, Fats & Grease (mg/1)
Organohalogens (mg/l)
Phenols (mg/l)
Cyanide (mg/l as CN)
Mercury (mg/1)1
Tin (mg/l)
Lead (mg/l)3
Chromium (mg/l as Cr VI)
Chromium (mg/l as total Cr)3
Cadmium (mg/l)2
Limit Value
Zinc (mg/l)3
Copper (mg/l)3
Mineral Oil (mg/l) Interceptors
Mineral Oil (mg/l) Biological
treatment
EC. List 1
Benzene & Toluene & Xylene
(mg/l combined)
Genetically Modified
Organisms
Notes
6-9
10
See Table 5.7.
See Table 5.7.
10
10
0.1 (monthly mean)
1.0
0.2
0.05
2.0
0.5
0.1
0.5
0.05
5
2,5
5
5
5
5
4,5
5
5
5 ,7
5 ,7
5 ,7
5 ,7
5 ,7
5 ,7
0.5
0.5
20
1.0
5 ,7
5 ,7
5
5
As per 76/464/EC
& amendments
0.1
(monthly mean)
As per 90/219/EEC
and S.I. No. 345 of
1994
* All values refer to daily averages, except where otherwise stated to the contrary, and
except for pH which refers to continuous values.
Parameter
BOD
COD
Minimum %
Total Removal
91
75
Notes
Page 32 of 132
1
1,6
Parameter
Fish Tainting
Limit value
No Tainting
Notes
3
1
Also compliance with Dir 82/176/EEC & 84/156/EEC ,amendments and S.I. No. 55
of 1986.
2
Also compliance with Dir 83/513/EEC , amendments and S.I. No. 294 of 1985.
3
Where the sum of the loads of these metals is <200 g/day prior to treatment, the
respective emissions limit value may be increased four fold - in justified cases.
Notes for Table 5.6:
1.
The daily raw waste load for BOD/COD is defined as the average daily
mass arising for treatment over any three month period.
Calculation of the removal rates for BOD/COD should be based on the
differences between the waste loads arising for disposal and those
discharges to the receiving waters. The amounts removed by treatment
(physical, chemical, biological) may be included in the calculation.
Calculation of the raw waste loads of BOD/COD shall exclude any waste
load associated with microbial cell biomass removal and solvent recovery.
However, residual amounts remaining after these practices may be
included in the raw waste load calculation.
For certain specific effluents where the % BOD/COD removal rates are
unattainable, a concentration limit may be more appropriate. This will be
a matter for inclusion in a licence.
2.
Toxicity unit (TU) = 100/x hour E(L)C 50 in percentage vol/vol, where x
is defined by the test procedure. The toxicity of the process effluent to at
least two appropriate aquatic species shall be determined.
3.
No substance shall be discharged in a manner, or at a concentration which,
following initial dilution, causes tainting of fish or shellfish, interferes
with normal patterns of fish migration or accumulates in sediments or
biological tissues to the detriment of fish, wildlife or their predators.
4.
Within 6 months of the commencement of production (or as may be
relevent on a campaign basis), the effluent should be screened for a
priority pollutant list (such as CLP 40, US EPA volatile and/or semivolatile).
5.
Consent conditions for these parameters for discharge to municipal
treatment plants can be established with the Licencing Authority, and
different values may apply.
6.
This limit applies only to:
Page 33 of 132
7.
5.1
The manufacture of chemicals in an integrated chemical
installation .
5.2
The manufacture of olefins and their derivatives or of
monomers and polymers, including styrene and vinyl chloride.
5.3
The manufacture, by way of chemical reaction processes, of
organic or organo-metallic chemical products other than those
specified at 5.2.
5.6
The manufacture of pesticides, pharmaceutical or veterinary
products and their intermediates.
Where the metallic content of the effluent arises as an unavoidable
contaminant of raw materials, then these limits may not apply.
Table 5.7.
Discharges to waters subject to eutrophication
(One or both of the limits below may apply,depending on the sensitivity of
the receiving waterbody.)
Parameter
Limit value mg/l
1
Total Nitrogen
>80% removal2, or 15 mg/l
Total Phosphorus
>80% removal2, or 2 mg/l
1
2
Total nitrogen means the sum of Kjeldahl Nitrogen, Nitrate N and Nitrite N.
Reduction in relation to influent load.
Page 34 of 132
Extract from EPA Batneec Guidance Note For Electroplating
Operations
4.
4.1
CONTROL TECHNOLOGIES
INTRODUCTION
As explained in Section 2, this Guidance Note identifies BATNEEC for a new
activity, but obviously does so in the absence of site-specific information.
Accordingly, it represents the minimum requirements expected of any new activity
covered by the Note, but does not exclude additional requirements which may form
part of the granting of a licence for a specific site.
The approach to be used in selecting BATNEEC is based on the following
hierarchy:

Process design / redesign changes to eliminate emissions and wastes that
might pose environmental problems.

Substitution of materials / solvents etc. by environmentally less harmful
ones.

Demonstration of waste minimisation by means of process control,
inventory control and end-of-pipe technologies etc.
The existing or possible measures for preventing, reducing and controlling
emissions are described in this section. These range from relatively simple
containment measures to sophisticated recovery and end-of-pipe technologies and
include:
(i)
(ii)
(iii)
(iv)
(v)
Load minimisation
Containment
Recovery/recycle
Emission reduction
Waste treatment and disposal.
The technical feasibility of the measures listed below has been demonstrated by
various sources. Used singly or in combination, these measures represent
BATNEEC solutions when implemented in the appropriate circumstances. The
circumstances depend on plant scale, chemicals used, type of plating, number of
different products produced, etc. A summary of the treatments for various
emissions is given at the end of the section.
Note that where hazardous (including asphyxiant) dusts or vapours occur, safety
procedures (acceptable to HSA) should be adopted. In these and any other matters
concerning safety, appropriate safe working practices should be adopted and
nothing in this note should be construed as advice to the contrary.
Page 35 of 132
4.2
TECHNOLOGIES FOR LOAD MINIMISATION
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).













Inventory control.
Optimisation of water usage.
Water based cleaning systems to be selected instead of solvent based
systems.
Separation of cooling water, storm water and process effluents of different
origin in order to permit appropriate treatment options.
Except where unavoidable, the following shall not be used:
(i) Halogenated substances.
(ii) White spirits, aromatic solvents and solvent dying.
(iii) Carcinogens (R45 risk phrase under EC Directive 67/548/EEC).
(iv) Chlorine based oxidising substances e.g. hypochlorite.
Raw materials shall be investigated for their potential contribution of EC List
1 substances to aquatic discharges. Alternatives shall be sought for those
with such potential.
In-plant measures to extend the service life of plating baths e.g. filtration,
activated carbon treatment, crystallisation, selective electrolysis, ionexchange etc.
Degreasing bath-life to be extended by e.g. mechanical filtration, oilskimming devices and ultra-filtration.
Pickling bath maintenance to include e.g. liquid-liquid extraction,
electrodialysis, ion exchange and retardation processes.
If technically possible, substitution of hazardous substances (e.g. cyanide,
cadmium, ammonia, mercury, EDTA and similar sequestering and chelating
agents, nonylphenolethoxylates, chlorinated organics) by substances which
are readily biodegradable, non-bioaccumulating, non-mutagenic and have a
low toxicity.
EDTA should be substituted in degreasing baths, stripping baths and
chemical nickel-plating baths. Possible substitutes include e.g. citric acid,
tartaric acid and gluconic acid; where substitution proves impracticable,
recovery of EDTA should be carried out from chemical copper plating baths
(e.g. by precipitation as H4EDTA) and their rinse baths (e.g. by precipitation
after a concentration step, e.g. by anion exchange).
Substitution of processes generating hazardous substances wherever possible
(e.g. cyanide oxidation with hypochlorite).
Multiple use of counter-current rinse waters, at least three rinsing steps
should be applied. Suitable techniques to keep more than 90% of the drag-out
in a small volume for recovery/recycling are e.g.
(i) 3-stage cascade rinsing;
(ii) 2-stage cascade rinsing plus closed cycle rinsing with ion exchange;
(iii) Combined dip/spray/mist rinsing techniques.
If possible these rinsing concentrates should be returned into the process
baths, if necessary after specific treatment/concentration. By applying these
rinsing techniques process baths can often be operated as closed water/low
waste systems.
Page 36 of 132





4.3
PREVENTION OF EMISSIONS
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).







4.4
Enclosure of all process materials, storage and handling within a suitable
building.
Bunding of tanks.
Single controlled emission point for all large dedicated plants.
Overground pipelines and transfer lines.
Check system to avoid mixing incompatible materials.
Bunding of all stored materials with separate bunding for incompatibles.
Overfilling protection on bulk storage tanks.
TECHNOLOGIES FOR RECOVERY AND RECYCLE
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).




4.5
Drag-out minimisation by e.g.
- adequate drip-off time.
- air jetting and brushing.
- suction (bulk articles).
- shaking (rack articles).
- Rack maintenance.
- Correct design of parts and their suspension on the racks to ensure liquid
entrapment is minimised.
- Use of splash guards.
Spray applications to be selected instead of bath immersion where
appropriate.
Ultrasonic cleaning and electro-cleaning.
Shot blasting is preferred to sand blasting.
Iron phosphating is preferred to zinc phosphating.
Recycle of process liquors e.g. separation of suitable non-ferrous metal waste
water streams to carry out internal recycling (e.g. by electrolysis) or external
recovery (e.g. by non-ferrous metal industry).
Reuse in another industry.
Onsite materials recovery.
Material recovery to be optimised by such means as ultrafiltration; reverse
osmosis; electrodialysis; electrolysis; ion-exchange; crystallisation and
evaporation.
TECHNOLOGIES FOR TREATING EMISSIONS TO AIR
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).





Cyclones (T1).
Bag filters (T2).
Vapour incineration (thermal, catalytic and regenerative) (T3).
Wet chemical scrubbers (T4).
Carbon adsorption (T5).
Page 37 of 132
4.6
TECHNOLOGIES FOR TREATING WATER EMISSIONS
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
4.6.1 Pre-Treatment









Precipitation (F1).
Oxidation (F2).
Reduction (F3).
Reverse osmosis (F4).
Electrodialysis (F5).
Electrolysis (F6).
Ion exchange (F7).
Evaporation (F8).
Ultrafiltration (F9).
4.6.2 Treatment



pH Correction/neutralisation (F10).
Coagulation/flocculation/precipitation (F11).
Sedimentation/filtration/flotation (F12).
4.6.3 Polishing


4.7
Resin beds (F13).
Reverse osmosis (F14).
TECHNOLOGIES FOR THE TREATMENT AND DISPOSAL OF WASTES
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
4.7.1 Sludge Treatment


Gravity thickening
Filtration
4.7.2 Disposal



Engineered landfill.
Recovery and reuse in downstream processing or another industry.
Waste encapsulation.
Page 38 of 132
Table 4.1 - Summary of Technologies for Treating Emissions to Air
(Symbols refer to Section 4.5)
Emission Type
Technology
Particulates
Acids, Alkalis, Cyanides
VOCs
T1, T2
T4
T3, T5
Table 4.2 - Summary of Technologies for Treating Water Emissions
(Symbols refer to Section 4.6)
Emission Type
Technology
Acids, Alkali
Metals
F10
F1, F3, F4, F5, F6, F7, F8, F9, F11, F12,
F13, F14
F11, F12
F2
F11
Suspended Solids
Cyanides
Ammonia
Phosphates
5.
Emission Limit Values
5.1
REFERENCE CONDITIONS
The reference conditions for concentrations of substances in emissions to air from
contained sources are:
For non-combustion gases:
Temperature 273 K; Pressure 101.3 kPa; no correction for water vapour content.
These units and reference conditions may not be suitable for continuous
monitoring methods and may, by agreement with the Agency, be converted, for
day to day control purposes, into values more suitable for the available
instrumentation.
5.2
INTERPRETATION OF COMPLIANCE
Page 39 of 132
Unless otherwise detailed in the licence, the following interpretation of
compliance with limit values should apply:
(Achievement of ELV concentrations by the introduction of dilution air is not
permitted.)
5.2.1
Emissions to Air
For continuously monitored emissions, the following will be required for
compliance with measurements based on 30 minute mean values (unless
otherwise stated):
(i)
97% of all 30 minute mean measurements shall be below 1.2 times the
emission limit.
(ii)
No 30 minute mean measurement shall exceed 2.0 times the emission limit.
(iii) All daily mean values shall be less than the emission limit.
Where periodic monitoring is used to check compliance, all samples should
meet the consent conditions.
5.2.2
Emissions to waters
The limit values for discharges to water are based on 24 hour flow proportional
composite samples unless otherwise specified.
5.3
EMISSIONS TO AIR
Emission Limit Values representing BATNEEC are given in Table 5.1.
Page 40 of 132
Table 5.1 - Emission Limit Values for Emissions to Air
Constituent Group
Class
Mass Flow
Emission Limit
or Parameter*
Threshold for ELV Value (mg/m3)**
Carcinogenic Substances
T.A. Luft 1
T.A. Luft 2
T.A. Luft 3
Substances (other
than those above)
with R45 designation)
T.A. Luft 1
T.A. Luft 2
T.A. Luft 3
> 0.5 g/hr
>5.0 g/hr
>25.0 g/hr
>0.5 kg/hr
0.1
1.0
5.0
5.0
>1 g/hr
>5 g/hr
>25 g/hr
0.2
1.0
5.0
Vaporous or Gaseous
Inorganic Substances
T.A. Luft 1
T.A. Luft 2
T.A. Luft 3
T.A. Luft 4
>10 g/hr
>50 g/hr
>0.3 kg/hr
>5.0 kg/hr
1
5
30
500
Organic Substances with
Photochemical Ozone
Creation Potential
- POCP
Organic Substances
(Note 2)
U.K. AEA 1
U.K. AEA 2
>0.5 kg/hr
>2.0 kg/hr
20
50
T.A. Luft 1
T.A. Luft 2
T.A. Luft 3
>0.1 kg/hr
>2.0 kg/hr
>3.0 kg/hr
20
100
150
<0.5 kg/hr
>0.5 kg/hr
150
50
Inorganic Dust Particles
General Dusts
*Where a substance falls into more than one category in Table 5.1, the lower emission
limit value applies.
**Achievement of ELV concentrations by the introduction of dilution air is not
permitted.
Notes for Tables 5.1
1.
The Mass Flow is calculated in kg/hr for the raw gas and is determined at
the point before any gas cleaning or abatement plant, but after any devices
inherent in the process (e.g. after reactor overhead condensers; after
product cyclones etc.) . Mass Flow is the maximum emission which can
occur over any one hour period of plant operation, from the entire site.
Where the mass flow exceeds the mass threshold given in the Guidance
Note, then abatement will be required down to the appropriate emission
Page 41 of 132
limit value (ELV), unless the concentration of the raw gas is already
below the ELV, in which case no further abatement is required.
(In other words, if the raw gas concentration is below the ELV, the mass
flow is not relevant)
Stack Height will be based on :
a)
Mass Flows as emitted from the stack
in those cases where,
(i)
or
(ii)
or
(iii)
b)
Mass Flow of the Raw Gas prior to gas cleaning
and abatement system in those cases where :
(i)
and
5.4
Failure of the abatement system results in
process shutdown.
Failure of the abatement system will not
result in significant risk to health or
environmental damage.
No abatement system exists.
(ii)
Failure of the abatement systems results
in continuing discharges,
Such discharges pose significant risk to
health or the environment.
2.
Where substances of several classes are present, in addition to the above
limit, the sum of Classes 1 & 2 shall not exceed the Class 2 limit and the
sum of Classes 1, 2 & 3 shall not exceed the Class 3 limit etc.
3.
Fugitive solvent emissions should comply with the requirements of
proposed E.C. Solvent Directive or licence as appropriate.
4.
It should be noted that, at the time of licensing, emissions which fall
below the Mass Emission threshold may still be considered in order to
minimise these as much as possible.
Releases to Water
Effluent should be minimised by recovery of materials wherever practicable.
The use of lower quality water may be possible for some parts of the process
rather than fresh water.
All releases to waters are subject to a licence from the Agency. However, any
discharge to a sewer, will also require the consent of the sanitary authority.
BATNEEC to minimise the release of substances will generally include
minimisation at source and either specific treatment of contaminated waste
streams to remove particular substances or co-treatment of combined effluent
streams or both. The Emission Limit Values for effluent discharges to waters
are set out in Table 5.2.
Page 42 of 132
Table 5.2 - Emission Limit Values for Discharges to Water*
Constituent Group
or Parameter
pH
BOD(mg/l)
Number of Toxicity Units
Total Nitrogen (as N)**
Total Phosphorus (as P)**
Total Ammonia (mg/1 as N)
Oils, Fats & Grease (mg/1)
Organohalogens (mg/l as Cl)
Phenols (mg/l)
Mercury (mg/1)
Nickel (mg/l)***
Silver (mg/l)
Lead (mg/l)***
Chromium (mg/l as Cr VI)
Chromium (mg/l as total Cr) ***
Cadmium (mg/l)
Tin
Zinc (mg/l)***
Copper (mg/l)***
Mineral Oil (mg/l) (Interceptors)
EC. List 1
Mineral oils (mg/l)
(Effluent Treatment)
Cyanide
Limit Value
Notes
6-9
25
2
2
5
1,2
> 80% Removal
or 15 mg/l
> 80% Removal
or 2 mg/l
10
10
0.1
1.0
0.05
0.5
0.1
0.5
0.1
0.5
0.05
2,3
2
0.5
0.5
20
As per 76/464/EC and
amendments
1.0
2
2
2
2
-
0.2
2
2,3
2
2
2
2
2
2
2
2
2
2
2
2
*
All values refer to daily averages, except where otherwise stated to the contrary,
and except for pH which refers to continuous values. Limits apply to effluent
prior to dilution by any uncontaminated streams, e.g. storm-water, cooling
water etc.
**
Only applicable to waters subject to eutrophication. One or both limits may
apply, depending on the sensitivity of the receiving water.
*** Where the sum of the metals combined is less than 200 g/d prior to treatment,
the emission limit values above may be increased fourfold.
Notes for Table 5.2:
Page 43 of 132
1.
The toxicity of the effluent shall be determined on an appropriate aquatic
species. The number of Toxicity Units (TU) = 100/96 hr LC50 in
percentage vol/vol. so that higher TU values reflect greater levels of
toxicity.
2.
Consent conditions for these parameters for discharge to municipal
treatment plants can be established with the Licensing Authority, and
different values may apply.
3.
Reduction in relation to influent load. Total nitrogen means the sum total of
Kjeldahl-nitrogen plus nitrate-nitrogen plus nitrite-nitrogen.
Page 44 of 132
Extract from EPA Batneec Guidance Note For The Extraction Of
Minerals
4.
4.1
CONTROL TECHNOLOGIES
INTRODUCTION
As explained in Section 2, this Guidance Note identifies BATNEEC but obviously
does so in the absence of site-specific information. Accordingly it represents the
requirements expected of any new activity covered by the Note, but does not
exclude additional requirements which may form part of the granting of a licence
for a specific site.
The approach to be used in selecting BATNEEC is based on the following
hierarchy:

Process design / redesign changes to eliminate emissions and wastes that
might pose environmental problems (e.g. use of powder coating instead of
solvent based).

Substitution of materials (e.g. water based coatings instead of solvent based)
by environmentally less harmful ones.

Demonstration of waste minimisation, as appropriate, by means of process
control, inventory control and end-of-pipe technologies, etc.
The existing or possible measures for preventing, reducing and controlling
emissions are described in this section. These range from relatively simple
containment measures to sophisticated recovery and "end-of-pipe" technologies
and include:
(i)
(ii)
(iii)
(iv)
(v)
Load minimisation
Containment
Recovery/recycle
Emission reduction
Waste treatment and disposal
The technical feasibility of the measures listed below has been demonstrated by
various sources. Used singly or in combination, the measures represent BATNEEC
solutions when implemented in the appropriate circumstances. The circumstances
depend on plant scale, materials used, nature of the products made, number of
different products produced, etc. A summary of the treatments for various
emissions is given at the end of the section.
Note that where hazardous (including asphyxiant) dusts or vapours occur, safety
procedures (acceptable to the Health and Safety Authority) should be adopted. In
these and any other matters concerning safety, appropriate safe working practices
Page 45 of 132
4.2
should be adopted and nothing in this note should be construed as advice to the
contrary.
TECHNOLOGIES FOR LOAD MINIMISATION
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).



















4.3
PREVENTION OF EMISSIONS
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).










4.4
Tailings system selection to minimise dust emissions (e.g. flooded tailings,
crusting agents).
Minimisation of dust from stockpiles. e.g. enclosure, minimizing the size of
stockpiles, wet suppression, temporary seeding, etc.
Consideration of acid generation potential from all sources.
Wet dust suppression for haul roads, yard surfaces, borrow pits, etc.
Optimisation of water usage.
Separation of storm water and process effluents of different origin in order to
permit appropriate treatment options.
Enclosed delivery and offloading points for dusty materials with extraction to
bag filter.
Wheel and body washing for vehicles (both site and off-site vehicles).
Modelling (validated) of ground water systems.
Selection of frequency and size of blast-charges.
Wet processing where appropriate (BPEO) to minimise dust emissions.
Use of grouting to minimise infiltration.
Appropriate backfill technology.
Pyrite removal/isolation.
Press rather than drier technology.
Determination and provision of appropriate closure options at design stage.
Consideration of underground siting of noise emitting plant.
Engineered containment of waste storage areas.
Optimised recovery of metals.
Enclosure of all handling, processing and product storage within a suitable
building or underground.
Closed transfer systems for milled material, raw materials, etc.
Bunding of tanks.
Overground pipelines and transfer lines.
Overfilling protection on bulk storage tanks.
Local extract systems as appropriate.
Minimisation of tank filling losses.
Cemented backfill to be used as appropriate.
Suitable locations for vent raise discharges.
Covered transport where appropriate
TECHNOLOGIES FOR RECOVERY AND RECYCLE
Page 46 of 132
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).





4.5
TECHNOLOGIES FOR TREATING EMISSIONS TO AIR
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
(Symbols refer to Table 4.1)


4.6
Reuse of production wastes in another facility e.g. as cover material.
Reuse of collected dusts.
Reuse of recovery filtrate.
Reusable containers for process chemicals.
Reuse of tailing return water and mine water in mill operations.
Filtration (T1).
Wet scrubbers (T2).
TECHNOLOGIES FOR TREATING WATER EMISSIONS
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
(Symbols refer to Table 4.2)
4.6.1 Primary Treatment




pH Correction/neutralisation (F1).
Coagulation/flocculation/precipitation/oxidation(F2).
Sedimentation/filtration/flotation (F3).
Centrifugation (F4).
4.6.2 Secondary Treatment


Biofilters/activated sludge (F5).
Aeration lagoons (F6).
4.6.3 Tertiary Treatment




4.7
Post-lagooning (F7).
Wet lands (F8).
Sand-Filtration (F9).
Ion exchange (F10)
TECHNOLOGIES FOR THE TREATMENT AND DISPOSAL OF WASTES
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
4.7.1 Sludge Treatment
 Gravity thickening.
 Centrifugation.
 Belt-pressing.
Page 47 of 132
4.7.2 Disposal




Site development.
Engineered containment of waste with appropriate aftercare provisions.
Reuse in downstream processing.
Backfill (underground mines).
Table 4.1 - Summary of Technologies for Treating Air Emissions
(Symbols refer to Section 4.5)
Technology
Emission
T1
Dust
Fumes
(Drill rigs, size reduction and classification,
physio-chemical extraction dryers,)
conveyors, indoor stockpiles)
T2
Dust (Dryers)
Table 4.2 - Summary of Technologies for Treating Water Emissions
(Symbols refer to Section 4.6)
Technology
Emissions
F1
Acids/Alkalis
F2
Organics/BOD
Oils/Fats/Greases
Suspended Solids
F3
Suspended Solids
Dissolved Inorganics
F4
Suspended Solids
F5,F6
BOD
F6
Oxygen and CO2 gas balancing
Page 48 of 132
F7, F8, F9, F10
Final effluent - treatment
Metal removal/precipitation
Reduction in S.S.
5.
5.1
Emission Limit Values
REFERENCE CONDITIONS
The reference conditions for concentrations of substances in emissions to air from
contained sources are:
For non-combustion gases:
Temperature 273 oK; Pressure 101.3 kPa; no correction for water vapour content.
For combustion gases:
Temperature 273oK; Pressure 101.3 kPa; dry gas; oxygen content 3% for liquid
and gaseous fuels and 6% for solid fuels.
These units and reference conditions may not be suitable for continuous
monitoring methods and may, by agreement with the Agency, be converted, for
day to day control purposes, into values more suitable for the available
instrumentation.
5.2
INTERPRETATION OF COMPLIANCE
Unless otherwise detailed in the licence, the following interpretation of
compliance with limit values should apply:
5.2.1
Emissions to Air
For continuously monitored emissions, the following will be required for
compliance with measurements based on 30 minute mean values (unless
otherwise stated):
(i)
97% of all 30 minute mean measurements shall be below 1.2 times the
emission limit.
Page 49 of 132
(ii)
No 30 minute mean measurement shall exceed 2.0 times the emission
limit.
(iii)
All daily mean values shall be less than the emission limit.
Where periodic monitoring is used to check compliance, all samples should
meet the consent conditions.
5.2.2
Emissions to waters
The limit values for discharges to water are based on 24 hour flow proportional
composite samples unless otherwise specified.
5.3
EMISSIONS TO AIR
Emission Limit Values representing BATNEEC are given in Table 5.1 below.
Table 5.1 - Emission Limit Values for Emissions to Air
Emission
Limit Value
Particulates
1 mg/m3
Metals
As per T.A. Luft
Hydrogen sulphide
0.01 mg/m3
(Achievement of ELV concentrations by the introduction of dilution air is not
permitted.)
5.4
Emissions to Water
Effluent should be minimised by recovery of materials wherever practicable. The use of
lower quality water may be possible for some parts of the process rather than fresh
water.
All releases to waters are subject to a licence from the Agency. However any discharge
to sewer will require the consent of the sanitary authority. BATNEEC to minimise the
release of substances will generally include minimisation at source and either specific
treatment of contaminated waste streams to remove particular substances or cotreatment of combined effluent streams or both. The Emission Limit Values for effluent
discharges to waters are set out in Table 5.2.
Page 50 of 132
Notwithstanding the Limit Values specified for particular parameters in the totality of
the process and other effluents due regard shall be paid to the overriding principal of
maintenance of the relevant environmental quality objectives in the receiving systems.
Table 5.2 - Emission Limit Values for Discharges to Water*
Constituent Group
or Parameter
pH
BOD
Toxic Units
Total Nitrogen (mg/l as N)**
Total Phosphorus (mg/l as P)**
Total Ammonia (mg/l as N)
Oils, Fats and Grease (mg/l)
Fish Tainting
Mineral Oil (Interceptor) (mg/l)
Mineral Oil (Effluent) mg/l
Metals, Cyanides, etc.
*
Limit Value
Notes
6-9
90% removal
or 25 mg/l
5 Tu
> 80% Removal
or 15 mg/l
>80% Removal
or 2 mg/l
5
25
No Tainting
100
1
As appropriate
4
1,4
2,4
4,5
4
4
4
3,4
4
4
6
All values refer to daily averages, except where otherwise stated to the contrary,
and except for pH which refers to continuous values. Limits apply to effluent
prior to dilution with uncontaminated streams, e.g. stormwaters, cooling waters,
etc.
** Only applicable to waters subject to eutrophication. One or both limits may apply
depending on the sensitivity of the receiving waters.
Notes for Table 5.2
1.
The daily raw waste load for BOD and Suspended Solids is defined as the
average daily mass arising for treatment over any three month period.
Calculations of the removal rates for BOD and Suspended Solids should be
based on the differences between the waste loads arising for disposal and
those discharges to the receiving waters. The amounts removed by
treatment (physical, chemical, biological) may be included in the
calculation.
2.
The toxicity of the effluent shall be determined by testing an appropriate
aquatic species. The number of toxic units (Tu) = 100/x hour EC/LC50 in
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percentage vol/vol so that higher Tu values reflect greater levels of
toxicity. For test regimes where species death is not easily detected,
immobilisation is considered equivalent to death.
3.
No substances shall be discharged in a manner which, or at a concentration
which, following initial dilution causes tainting of fish or shellfish,
interferes with normal patterns of fish migration or which accumulates in
sediments or biological tissues to the detriment of fish, wildlife or their
predators.
4.
Consent conditions for these parameters for discharge to municipal
treatment plants can be established with the Licensing Authority, and
different values may apply.
5.
Reduction in relation to influent load. Total nitrogen means the sum total of
Kjeldahl-nitrogen plus nitrate-nitrogen plus nitrite-nitrogen.
6.
Determination of limits at the time of licensing based on consideration of
appropriate technologies and the requirement of the receiving environment.
In this regard particular attention should be paid to the maximum
acceptable concentration standards (wherever relevant and applicable) for
the chemical parameters of;
(a) S.I. 293 of 1988 - European Communities
(Quality of Salmonid Waters) Regulations, 1988.
(b) S.I. 294 of 1989 - European Communities
(Quality of Surface Water intended for Abstraction of Drinking Water
intended for Human Consumption) Regulations, 1989.
(c) S.I. 200 of 1994 - European Communities
(Quality of Shellfish Waters) Regulations, 1994.
Page 52 of 132
Extract from EPA Batneec Guidance Note For The Pig Production
Sector
4. CONTROL TECHNOLOGIES
4.1 Introduction
As explained in Section 2, this Guidance Note identifies BATNEEC, but obviously
does so in the absence of site-specific information. Accordingly, it represents the
requirements expected of any new activity covered by the Note, but does not exclude
additional requirements which may form part of the granting of a licence for a specific
site.
The approach to be used in selecting BATNEEC is based on the following hierarchy:
 Process design/redesign and selection changes to minimise the production of
manure, wash-water, carcasses and packaging waste that might pose
environmental problems.
 Process design/redesign and selection changes to minimise emissions that
might pose environmental problems.
 Substitution of feed, materials, machinery etc., by environmentally less
harmful ones.
 Demonstration of waste minimisation by means of production process
control, inventory control and recycling technologies etc.
The existing, or possible measures for reduction and control of emissions are
described in this section. These range from relatively simple siting and containment
measures to recovery/recycling and manure treatment technologies and include:
1. Siting pig units.
2. Load minimisation.
3. Containment.
4. Manure spreading.
5. Recovery/recycling.
6. Treatment of manure.
The technical feasibility of the measures listed below has been demonstrated by
various sources. Used singly or in combination, these measures represent BATNEEC
solutions when implemented in the appropriate circumstances. The circumstances
depend on farm scale, feed and materials used, type of pig housing, number and type
of pigs produced, degree of integration of the plant, etc.
Pig manure and wash water should be spread parallel to ground contours taking
account of safety requirements. Note that where hazardous (including asphyxiant)
dusts or vapours occur, safety procedures (acceptable to Health & Safety Authority)
should be adopted. In these, and any other matters concerning safety, appropriate safe
working practices should be adopted and nothing in this note should be construed as
advice to the contrary.
4.2 Pig housing and manure
There are two main types of pig housing:
1. Non-bedded based housing producing pig slurry with a dry matter content
ranging between 5 and 10%.
2. Bedded based housing, where suitable bedding, generally straw, is used
producing pig dung with a dry matter content ranging between 15 and 20%.
Page 53 of 132
There are three main types of pig units:
 A breeding unit, producing and rearing pigs to c. 32kg liveweight.
 A finishing unit, in which pigs are reared from c. 32kg to c. 95kg liveweight.
 An integrated unit, producing and finishing pigs at c. 95kg liveweight.
The characteristics of pig manure are a function of:
 water:feed ratio
 feed quantity
 feed quality
 amount of bedding used, if any
Account should be taken of these variables when estimating the quantity and
associated characteristics of the manure from a specific unit; account may also have to
be taken, where appropriate of additions to the manure in storage from extraneous
water including wash-water and contaminated surface water.
4.3 Siting pig units
BATNEEC for the siting of pig units is based on the following hierarchy:
 A mass balance of nutrients within a control area.
 Protection of both surface and groundwater resources in the vicinity of the
site and landspreading areas.
 Avoidance of nuisance due to malodours for dwellings in the vicinity of the
site.
 Protection of the environment in the event of the de-stocking of the unit due
to an emergency, e.g. an outbreak of a Class A disease as identified in
accordance with the current list of scheduled and notifiable diseases
compiled by the Department of Agriculture, Food and Forestry under the
provisions of the ‘Diseases of Animals Act’, 1966.
The management of pig manure should be based on a mass balance of nutrients within
a control area, whether the area be a farm, group of farms or a region. Thus, pig units
should preferably be sited in close proximity to suitable landspreading areas such as
land used for tillage crop production, where they can operate as ‘back to back’
enterprises to:
 Facilitate the utilisation of manure for crop production.
 Avoid a surplus of manure prevailing within a region.
 Reduce manure transportation costs.
In order to protect both surface and groundwater resources in the vicinity of the site
and landspreading areas a site investigation is essential and it is generally advisable
that it be carried out by a qualified hydrogeologist. The site investigation should
provide information on:
 Depth to water table (if shallow).
 Depth to bedrock (if shallow) and details of bedrock outcrops.
 Subsoil and bedrock type and quantitative assessment of permeability.
 Presence or absence of karst features - caves, swallow holes etc. - if bedrock
is limestone.
 Aquifer classification and groundwater vulnerability in accordance with the
provisions of ‘Groundwater protection schemes in Ireland: A proposed
approach’, (Daly, 1995).
 Private wells within 200 metres and all public wells within 1 kilometre of
site and 300 metres of the landspreading areas.
 Direction of groundwater flow.
Page 54 of 132
 Baseline information on surface and groundwater quality.
 Location of all watercourses adjacent to the site and landspreading areas.
In addition the investigation should include information on soil types and nutrient
status.
Pig units should be sited a distance of preferably not less than 400 metres from the
nearest neighbouring dwelling and all operations on site shall be carried out in a
manner such that air emissions and/or odours do not result in significant impairment
of or significant interference with amenities or the environment beyond the site
boundary.
Pig units should be sited such that in the event of an outbreak of disease requiring destocking there is an appropriate site available for the construction of a lined carcass
disposal site for the disposal of all carcasses. The carcass disposal site shall be
appropriately constructed in order to avoid any detrimental impacts on both surface
and groundwater quality in accordance with the provisions contained in ‘Class A
disease outbreak - a multi-disciplinary approach’, (Duggan, O’Laoide and Finn,
1995.)
4.4 Load minimisation
All feedingstuffs in the pig production sector shall comply with the provisions of
current national legislation thereon.
Load minimisation for the pig production sector is based on the following hierarchy
although the appropriate selection in a particular case will depend on the specific
circumstances which apply to the individual site.
Minimisation of pig manure and reduction of mineral excretion by:
1. Feeding to requirements.
2. Maintaining feeding systems in a good working condition so that feed
wastage and spoilage are kept to a minimum.
3. Increasing the digestibility of the phosphorus in feed.
4. Using low phosphorus feed, where appropriate.
5. Maintaining all drinkers in a good working condition such that leaks are
prevented.
6. Separate collection of all uncontaminated surface water run-off from roofs
and clean paved areas within the proposed development and its direct
disposal to field drains or soakpits according to S129: ‘Minimum
specification for farmyard drainage, concrete yards and roads.’, (DAFF,
1993).
Minimisation of odour emissions by:
 Adequate cleaning of pig houses between batches.
 Using adequate bedding in litter based pig housing.
 Provision of adequate manure storage capacity.
 Stocking pig units at design level.
 Designing ventilation system to facilitate efficient operation including
maintenance.
 Filling and emptying liquid manure storage tanks from below the surface of
the stored manure, where feasible.
 Minimising the agitation of manure.
Minimisation of carcass waste by reducing mortality rates on the unit.
Minimisation of wash-water is facilitated by the use of automatic cut-off trigger
operated high pressure hoses for washing.
Page 55 of 132
4.5 Containment of emissions
Containment of emissions for the pig production sector is based on the following
hierarchy although the appropriate selection in a particular case will depend on the
specific circumstances which apply to the individual site.
Litter-free pig manure or pig slurry should be stored in one of the following:
 In underground, partly underground or overground concrete structures
constructed according to S123: ‘Minimum specification: Slatted livestock
units; Reinforced concrete tanks’, (DAFF, 1994).
 In an overground steel structure constructed on an impermeable concrete
base. Steel structures must be certified by the manufacturer as being watertight and they must be guaranteed for a 10 year period. The design
specification and subsequent construction for the concrete base must be
certified by a chartered engineer.
 Overground manure storage structures shall be provided with two valves in
line and an external safety ladder and railed platform to facilitate inspection.
Pig dung should be stored:
 In a manure pit structure constructed according to S108: ‘Minimum
specification for manure pit’, (DAFF, 1987) and sited where the risk of both
water pollution and spread of disease to other pig houses is minimal. The
manure pit should be suitably roofed to exclude rainwater, preferably with a
permanent structure. The manure pit should be provided with a roof and
walls as necessary to protect the manure from the elements.
The following applies to all pig manure and wash-water storage structures whether or
not on the site of the unit:
 A minimum of six months storage capacity dedicated to the unit is required.
 All construction work should be certified by a chartered engineer as having
been constructed according to either S108 or S123 as appropriate, (DAFF,
1987 and 1994).
 Where the pig manure storage structures are constructed to another design
specification, then both the design specification and the subsequent
construction work should be certified by a chartered engineer as being
suitable for the task and comparable to the Department of Agriculture, Food
and Forestry specifications.
 All storage tanks should be inspected by a chartered engineer and certified as
structurally sound for the purpose they were intended subsequent to
construction and at appropriate intervals thereafter.
 Leak detection facilities based on inspection chambers and perimeter wall
and under floor drains should be provided as appropriate.
Spreading or applying manure to landspreading areas should be carried out according
to Section 0.
Transport of pig manure should be in suitably contained, leakproof vehicles.
The septic tank drainage system should be constructed in accordance with SR6
‘Septic tank systems: Recommendations for domestic effluent treatment and disposal
from a single domestic dwelling’, (NSAI, 1991).
Oil storage tanks on site should be placed on impervious bases and shall be located
within oil tight bunds, capable of holding 110% of the volume of the largest tank
within the bund. The fill and draw pipes shall be enclosed within the bund.
Odour emissions should be contained by:
Page 56 of 132
 Reducing uncontrolled air movement.
 Filling and emptying liquid manure storage tanks from below the surface of
the stored manure, where feasible.
 Transporting manure in suitably contained, leakproof vehicles.
 Minimising the agitation of manure.
 Minimising the generation of odours during meteorological conditions which
favour the spread of odours.
 Landscaping pig houses using shelter-belts.
Carcasses should be stored on site in covered containers and transported to a
rendering facility in covered, leakproof containers as soon as practical and at least
once per week.
Wash-water from pig houses should be stored:
 In underground, partly underground or overground concrete structures
constructed according to S123: ‘Minimum specification: Slatted livestock
units; Reinforced concrete tanks’, (DAFF, 1994).
 In an overground steel structure constructed on an impermeable concrete
base. Steel structures must be certified by the manufacturer as being leakproof and they must be guaranteed for a 10 year period. The design
specification and subsequent construction for the concrete base must be
certified by a chartered engineer.
 Overground manure storage structures shall be provided with two valves in
line and an external safety ladder and railed platform to facilitate inspection.
Packaging waste, contaminated drums, equipment and protective clothing should be
collected and stored in suitably sealed leakproof containers, where practicable.
4.6 Spreading pig manure
The owner of the pig unit where the manure and wash-water is produced shall be
responsible for its proper management.
BATNEEC for spreading pig manure is based on the following hierarchy:
 Suitable landspreading areas.
 Buffer-zones required.
 Time of application.
 Manner of application.
 Spreading rate.
Units where landspreading areas are obtained by agreement with other landowners,
should have a reserve landspreading area available to them of at least 50% of the
landspreading area obtained by agreement. (e.g.: Where a pig farmer owns 80ha and
requires 100ha of landspreading areas, then he/she should obtain 30ha by agreement.)
Pig manure and wash-water should be landspread or applied to the following
landspreading areas based on the following preferred hierarchy:
 Tillage crop production.
 Conserved grassland.
 Grazed grassland.
Pig manure and wash-water should be spread parallel to ground contours.
Pig manure and wash-water should not be landspread or applied to the following
landspreading areas:
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 On land where the existing phosphorus (P) content is above 15 mg/l soil, or
such figure as may be determined by the Agency; soil phosphorus levels to
be determined by Morgan’s P-Test in accordance with ‘A modified single
solution method for the determination of phosphate in natural waters’,
(Murphy and Riley, 1962) and (Peach and English, 1944).
 On waterlogged land.
 On frozen or snow covered land.
 On exposed bedrock.
 Fields that are pipe or mole drained and the soil is cracked down to the drains
or backfill.
 Fields that have been pipe or mole drained in the last 12 months.
 Fields that have been subsoiled over a pipe or mole drainage system in the
last 12 months.
 Within 15 metres of exposed cavernous (karstified) limestone or karst
limestone features such as swallow holes and collapse features.
 Where permeable bedrock is overlain by shallow (i.e. less than 1 metre from
the surface) free draining subsoils, such as sands, gravels and sandy tills.
Where the bedrock is highly permeable limestone or dolomite (these are
usually classed as regionally important or major aquifers) a greater depth of
subsoil (i.e. 2 metres) is desirable.
 Where the water table is within 1 metre of the surface in free draining areas,
at the time of application.
 Where surface gradients are excessive; gradients should preferably be less
than 20%.
Pig manure and wash-water should be landspread or applied to land observing the
following ‘buffer zones’:
Table 1: Buffer zones for landspreading pig manure.
Area
Buffer zone (m)
Sensitive buildings (hospitals, schools and churches)
200
Dwelling houses
100
Lakes and main river channels1
20
Small watercourses
10
1
Public roads1
10
Domestic wells1
50
Public water supplies1,2
50 to 300
1
Note: The above distances to be increased if the gradient is greater than 6%.
2
Note: The appropriate distance depends on vulnerability and groundwater flow direction.
Unless good management practice otherwise dictates, the factors listed below must be
taken into account and pig manure and wash-water generally should not be landspread
or applied to landspreading areas at the following times, to take account of nutrient
uptake, slurry runoff and the generation of odour nuisance:
 During the period November to February inclusive.
(However in certain locations in particular years it may not be appropriate to
adhere rigidly to these dates; depending on the weather Spring landspreading
Page 58 of 132
operations may well commence before the end of February but may also
have to be deferred to a later date.)
 Manure should not be spread late in the year on land which will be barren
over the winter.
 Manure should be spread earlier rather than later in the growing season.
 When heavy rain is forecast within 48 hours.
 Manure should only be spread during daylight hours.
 When the wind direction is towards population centres or neighbours houses.
 When the risk of causing odour nuisance to the public is greatest e.g.
Sundays or public holidays.
 Meteorological conditions which give rise to odour nuisance.
Pig manure and wash-water should be landspread or applied in the following manner:
 Manure/wash-water should be spread by an appropriate band-spreader,
shallow injector or muck-spreader (for pig dung only).
The rate of landspreading or application of pig manure or wash-water should take
account of:
 The nutrient content of the manure.
 The nutrient requirements of the crop.
 The nutrient status of the soil.
 Other organic manures and chemical fertilisers being spread.
The rate of landspreading or application of pig manure or wash-water should be in
accordance with the provisions contained in either of the following sources:
 ‘Rural Environment Protection Scheme, Farm Development Service: Agrienvironmental specifications’, (Current edition of DAFF Guidelines).
or,
 ‘Soil analysis and fertiliser, lime, animal manure and trace element
recommendations’, (Current edition of Teagasc Guidelines).
Regardless of the dilution factor, the maximum hydraulic loading per single
application should not exceed 25m3 per hectare on shallow limestone soils and in no
case should exceed 50m3 per hectare.
4.7 Technologies for recovery and recycling
Load minimisation for the pig production sector is based on the following hierarchy
although the appropriate selection in a particular case will depend on the specifics.
A Nutrient Management Plan (NMP) should be established to optimise the re-use and
recycling of available nutrients in the pig manure - in particular nitrogen, phosphorus
and potassium - and should also take account of the hydraulic load. (See also section
5.4).
Carcasses should be stored on site in covered containers and transported to a
rendering facility in covered, leakproof containers as soon as practical and at least
once per week.
The Nutrient Management Plan should incorporate the quantity of wash-water.
Waste packaging materials should be recovered and recycled, where practicable.
4.8 Treatment of manure
Considerable research has been carried out in recent years in manure treatment. The
objectives of manure treatment may include:
 Reduction of odour.
 Production of biogas.
 Improvement in ease of handling.
Page 59 of 132
 Reduction of pathogens.
Treatment of manure may include the following:
 Mechanical separation.
 Aeration.
 Composting.
 Anaerobic digestion.
 Drying.
 Pelletising.
 Incineration.
There are several large scale plants in Europe providing centralised manure treatment.
To date, such facilities are rarely provided on individual farms. However, it may in
certain circumstances be appropriate to provide treatment facilities on an individual
farm. The type of treatment required and the technology employed will depend on the
specific circumstances applying to the individual site.
4.9 Technologies for the treatment and disposal of wastes
In the event of the unit being de-stocked, due to an emergency, e.g. an outbreak of a
Class A disease as identified in accordance with the current list of scheduled and
notifiable diseases compiled by the Department of Agriculture, Food and Forestry
under the provisions of the ‘Diseases of animals act’, 1966 - the Department of
Agriculture’s Veterinary Inspectors should be contacted immediately.
Packaging waste, contaminated drums, equipment and protective clothing which are
not reused or recycled, should be disposed of at an authorised facility.
5. COMPLIANCE MONITORING
The methods proposed for monitoring the emissions from this sector are set out
below.
5.1 Air emissions
Periodic monitoring of air quality with regard to odour nuisance at the boundary of
the site and spreading areas as per licence.
5.2 Surface water quality monitoring scheme
Periodic water quality monitoring of relevant parameters as per licence.
5.3 Groundwater quality monitoring scheme
Establish the baseline conditions of groundwater quality in the neighbourhood of the
site and all of its landspreading areas prior to start-up. Periodic water quality
monitoring of relevant parameters as per licence. Where appropriate, test wells should
be provided at the site of the pig unit and on the landspreading areas used for
spreading manure.
5.4 Nutrient Management Plan
A Nutrient Management Plan (NMP) should be maintained on site for the
management of pig manure and wash-water arising at the unit and should include:
 Calculation of the quantity of manure and the amount of nutrients available
from manure including any manure or other wastes imported.
Page 60 of 132
 The results of soil fertility and drainage tests on existing or proposed
landspreading areas.
 A representative soil sample, to a depth of 10 cm should normally be taken
biennially from every 2 to 4 hectares and at least one per farm. However,
where soil types are similar and cropping and treatment of the lands were the
same during the previous 5 years or more, a composite sample from an area
of up to 12 hectares is acceptable.
 An assessment of the relationships between manure application rates,
cropping routine, crop nutrient requirements and existing soil nutrient status
on all landspreading areas.
 Ordinance Survey Maps to a scale of 1:10,560 showing the location of the
said landspreading areas and all environmentally sensitive features on the
lands or in their vicinity; including interalia dwellings houses and sensitive
buildings, drains, streams, watercourses and other sources of water supply.
 Agreements between ‘importers’ and ‘exporters’ of all animal manures or
other wastes are required.
The Nutrient Management Plan should be up-dated and issued to the Agency for
approval on an annual basis.
Page 61 of 132
Extract from EPA Batneec Guidance Note For The Rendering of
Animal By-products
4.
4.1
CONTROL TECHNOLOGIES
Introduction
As explained in Section 2, this Guidance Note identifies BATNEEC for a new
activity, but obviously does so in the absence of site-specific information.
Accordingly it represents the minimum requirements expected of any new activity
covered by the Note, but does not exclude additional requirements which may form
part of the granting of a licence for a specific site.
The approach to be used in selecting BATNEEC is based on the following
hierarchy:

Process design / redesign changes to prevent emissions and eliminate
wastes that might pose environmental problems.

Substitution of materials (e.g. low sulphur fuel) by environmentally less
harmful ones.

Demonstration of waste minimisation by means of process control,
inventory control and end-of-pipe technologies etc.
The existing or possible measures for preventing, reducing and controlling
emissions are described in this section. These range from relatively simple
containment measures to sophisticated recovery and "end-of-pipe" technologies
and include:
(i)
(ii)
(iii)
(iv)
(v)
Load minimisation
Containment
Recovery/recycle
Emission reduction
Waste treatment and disposal.
The technical feasibility of the measures listed below has been demonstrated by
various sources. Used singly or in combination, the measures represent BATNEEC
solutions when implemented in the appropriate circumstances. The circumstances
depend on plant scale, chemicals used, nature of the products made, number of
different products produced, etc. A summary of the treatments for various
emissions is given at the end of the section.
4.2
Technologies for load minimisation
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
 Inventory control.
 Optimisation of water recirculation and reuse.
Page 62 of 132
 Dry equipment cleaning and dry vacuum systems, where feasible.
 Separation of cooling water, storm water and process effluents of different
origin in order to permit appropriate treatment options.
 Introduction of non-condensable oven off-gases into boiler.
 Appropriate storage facilities.
4.3
Prevention of emissions
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
 Transport of materials to the site should be in suitably contained vehicles.
 Enclosure of all materials, storage, handling, processing and transfer within a
suitable building.
 Secondary containment of building releases by maintenance of negative
pressure within the building.
 Closed transfer systems for milled material, raw materials etc.
 Bunding of tanks.
 Overground pipelines and transfer lines.
 Only totally enclosed conveyors to be used.
 Check system to ensure “first-in-first processed”.
 Overfilling protection on bulk storage tanks.
 Prevention of rain ingress, wind entrainment etc. for stored materials.
 Heat recovery to be used where practicable.
 Local extract systems as appropriate e.g. drier unloading, mill, coolers,
separators etc.
 Condensers on all appropriate process equipment e.g. coolers, evaporators etc.
 Sealed manhole covers where appropriate.
4.4
Technologies for recovery and recycle
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).




4.5
Recovery of materials from separator/centrifuge liquors.
Interceptor tanks at each process building.
Reuse internally or alternatively in another rendering facility.
Recycle of interceptor and WWTP sludges to process plant where such does
not contravene S.I. No. 257 of 1994 .
Specific technologies for treating air emissions
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
 Condensation (T1).
 Biofilters as final air treatment (T2).
 Selective chemical reaction scrubbers, e.g. acid scrubber for ammonia removal
prior to biofilter (T3).
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



4.6
Cyclones (T4).
Filtration (fabric filters normally adequate) (T4).
Thermal oxidation (T5).
Carbon filtration (T6).
Specific technologies for treating water emissions
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
S.I. No. 257 of 1994 requires specific treatment of certain waste streams and
nothing in this note should be construed as advice to the contrary.
4.6.1 Primary Treatment




pH Correction/neutralisation (F1).
Coagulation/flocculation/precipitation (F2).
Sedimentation/filtration/floatation (F2).
Centrifugation (F2).
4.6.2 Secondary Treatment





Biofilters (F3).
Anaerobic treatment (F3).
Activated sludge/aeration lagoons (F3).
Extended aeration (F3).
Nitrification/denitrification (F3).
4.6.3 Tertiary Treatment
 Filtration/coagulation/precipitation (F4).
 Ozonation/Oxidation (F5, F6).
 Activated Carbon polishing (F5).
4.6.4 Sludge Treatment





4.7
Gravity thickening.
Dissolved air floatation.
Filtration.
Centrifugation.
Sludge digestion.
Specific technologies for the treatment and disposal of wastes
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
 Engineered landfill of wastes.
 Landspreading of wastes (as fertiliser).
 Recycle of interceptor and WWTP sludges to process plant where such does
not contravene S.I. No. 257 of 1994 .
Page 64 of 132
Table 4.1 - Summary of Technologies for Treating Air Emissions
Technology
Emissions
T1
Condensable Organics, Partial Odour
Removal
T2, T5, T6
Organics/Odours
T3
Ammonia
T4
Particulates
Table 4.2 - Summary of Technologies for Treating Water Emissions
Technology
Emissions
F1
Ammonia
F2
Organics/BOD
Oils/Fats/Greases
Suspended Solids
F3
Organics
Ammonia
Nitrates
Phosphorus
F4
Suspended Solids
Phosphorus Removal
F5
Trace Organics
F6
Disinfection
Page 65 of 132
5.
5.1
EMISSION LIMIT VALUES
Reference Conditions
The reference conditions for concentrations of substances in emissions to air from
contained sources are:
For non-combustion gases
Temperature 273 K; Pressure 101.3 kPa; no correction for water vapour content.
For combustion gases
Temperature 273 K; Pressure 101.3 kPa; dry gas; oxygen content 3% for liquid
and gaseous fuels and 6% for solid fuels.
These units and reference conditions may not be suitable for continuous
monitoring methods and may, by agreement with the Agency, be converted for
day to day control purposes into values more suitable for the available
instrumentation.
5.2
Interpretation of Compliance
Unless otherwise detailed in the licence, the following interpretation of
compliance with limit values should apply.
5.2.1 Emissions to Air
Achievement of ELV concentration by the introduction of dilution air is not
permitted.
For continuously monitored emissions, the following will be required for
compliance with measurements based on 30 minute mean values (unless
otherwise stated):
(i)
(ii)
(iii)
97% of all 30 minute mean measurements shall be below 1.2 times the
emission limit.
No 30 minute mean measurement shall exceed 2.0 times the emission
limit.
All daily mean values shall be less than the emission limit.
Page 66 of 132
Where periodic monitoring is used to check compliance, all samples should
meet the consent conditions.
5.2.2 Emissions to Waters
The limit values for discharges to water are based on 24 hour flow proportional
composite samples unless otherwise specified.
5.3 Emissions to Air
Emission Limit Values representing BATNEEC are given in Table 5.1 below.
Table 5.1 - Emission Limit Values for Emissions to Air
Emission
Limit Value
Total Particulate Matter
(including emissions from material handling)
50 mg/m3
Ammonia
50 ppm v/v
Amines
5 ppm v/v
Hydrogen sulphide, and mercaptans
5 ppm v/v
Smoke
<1 (Ringlemann Shade)
Note 1: Achievement of ELV concentration by the introduction of dilution air is not
permitted.
5.4 Emissions to Water
Effluent should be minimised by recovery of materials wherever practicable. The
use of water other than fresh water may be possible for some parts of the process
e.g. the use of condensate for yard washing.
All releases to waters are subject to a licence from the Agency. However any
discharge to sewer will require the consent of the sanitary authority. BATNEEC to
minimise the release of substances will generally include minimisation at source
and either specific treatment of contaminated waste streams to remove particular
substances or co-treatment of combined effluent streams or both. The Emission
Limit Values for effluent discharges to waters are set out in Table 5.2.
Page 67 of 132
Table 5.2 - Emission Limit Values for Emissions to Water*
Constituent Group
or Parameter
pH
BOD
Toxic Units
Total Nitrogen(as N)**
Total Phosphorus (as P)**
Limit Value
Notes
6-9
>90% removal
or 40 mg/l
5
>80% Removal
or 15 mg/l
>80% Removal
or 2 mg/l
25
15
No Tainting
20
4
1,4
2,4
4,5
4,5
Total Ammonia (mg/l as N)
4
Oils, Fats and Grease (mg/l)
4
Fish Tainting
3,4
Mineral Oil (Interceptor) (mg/l)
4
* All values refer to daily averages, except where otherwise stated to the contrary, and except for pH which refers
to continuous values. Limits apply to effluent prior to dilution by uncontaminated streams, e.g. stormwater,
cooling water, etc.
** Only applicable to waters subject to eutrophication. One or both limits may apply, depending on the sensitivity
of the receiving waters
Notes for Table 5.2:
1. The daily raw waste load for BOD is defined as the average daily mass arising for
treatment over any three month period.
2. Calculations of the removal rates for BOD should be based on the differences
between the waste loads arising for disposal and those discharges to the receiving
waters. The amounts removed by treatment (chemical, physical, biological) may be
included in the calculation.
3. Toxicity Unit (TU) = 100/x hour E(L)C 50 in percentage vol/vol, where x is
defined by the test procedure. The toxicity of the process effluent to at least two
appropriate aquatic species shall be determined. Higher TU values reflect greater
levels of toxicity.
4. No substances shall be discharged in a manner which, or at a concentration which,
following initial dilution causes tainting of fish or shellfish, interferes with normal
patterns of fish migration or which accumulates in sediments or biological tissues to
the detriment of fish, wildlife or their predators.
5. Consent conditions for these parameters for discharge to municipal treatment plants
can be established with the Licensing Authority, and different values may apply.
6. Reduction in relation to influent load. Total nitrogen means the sum total of
Kjeldahl-Nitrogen plus nitrate-nitrogen plus nitrite-nitrogen.
Page 68 of 132
Extract from EPA Batneec Guidance Note For The Slaughter of
Animals
4.
4.1
CONTROL TECHNOLOGIES
INTRODUCTION
As explained in Section 2, this Guidance Note identifies BATNEEC but obviously
does so in the absence of site-specific information. Accordingly it represents the
requirements expected of any new activity covered by the Note, but does not
exclude additional requirements which may form part of the granting of a licence
for a specific site.
The approach to be used in selecting BATNEEC is based on the following
hierarchy:

Process design / redesign changes to prevent emissions and eliminate
wastes that might pose environmental problems.

Substitution of materials (e.g. low sulphur fuel) by environmentally less
harmful ones.

Demonstration of waste minimisation by means of process control,
inventory control and end-of-pipe technologies etc.
The existing or possible measures for preventing, reducing and controlling
emissions are described in this section. These range from relatively simple
containment measures to sophisticated recovery and end-of-pipe technologies and
include:
(i)
(ii)
(iii)
(iv)
(v)
Load minimisation
Containment
Recovery/recycle
Emission reduction
Waste treatment and disposal
The technical feasibility of the measures listed below has been demonstrated by
various sources. Used singly or in combination, the measures represent BATNEEC
solutions when implemented in the appropriate circumstances.
Note that where hazardous (including asphyxiant) dusts or vapours occur, safety
procedures (acceptable to HSA) should be adopted. In these, and any other matters
concerning safety, appropriate safe working practices should be adopted and
nothing in this note should be construed as advice to the contrary.
4.2
TECHNOLOGIES FOR LOAD MINIMISATION
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
Page 69 of 132
 Optimisation of water usage (e.g. use of pressure cleaning throughout).
 Fit all cleaning hose ends with trigger hand operated spray nozzles.
 Optimisation of blood collection.
 Selection of equipment for secondary processing to minimise effluent and
waste
arising.
4.3
PREVENTION OF EMISSIONS
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
 Enclosure
of materials (excluding bulk liquids), storage, handling, processing and
transfer within a suitable building.
 Bunding of tanks.
 Overground pipelines and transfer lines.
 Overfilling protection on bulk storage tanks.
 Prevention of rain ingress, wind entrainment etc. for stored materials.
4.4
TECHNOLOGIES FOR RECOVERY AND RECYCLE
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).




4.5
Reuse in a rendering or pet food facility.
Blood and bone collection for use in edible products for human consumption.
Fresh fat rendering.
Optimisation of offal recovery and reuse for downstream processing.
TECHNOLOGIES FOR TREATING EMISSIONS TO AIR
Note:
4.6
No treatment is normally required for fresh fat rendering or dehairing,
other than adequate stack discharge in the case of non wet rendering. For
technologies suitable for rendering other materials the Guidance Note on
Rendering should be referred to.
TECHNOLOGIES FOR TREATING WATER EMISSIONS
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
(Symbols refer to Table 4.1)
4.6.1 Primary Treatment
 Coagulation/flocculation/precipitation (F1).
 Sedimentation/filtration/floatation (F2).
4.6.2 Secondary Treatment
 Biofilters (F3).
 Anaerobic treatment (F4).
 Activated sludge/aeration lagoons
 Extended aeration (F6).
(F5).
Page 70 of 132
4.6.3 Tertiary Treatment
 Nitrification/denitrification (F7).
 Filtration/coagulation/precipitation
4.7
(F8).
TECHNOLOGIES FOR THE TREATMENT AND DISPOSAL OF WASTES
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
4.7.1 Sludge Treatment
 Gravity thickening.
 Dissolved air floatation.
 Filtration.
 Centrifugation.
 Sludge digestion.
 Drying.
4.7.2 Disposal
 Rendering.
 Reuse in downstream processing.
 Engineered landfill of wastes.
 Landspreading of wastes (as fertiliser).
Table 4.1 - Summary of Technologies for Treating Water Emissions
(Symbols refer to section 4.6)
Emission Type
Technology
Organics
F1, F2, F3, F4, F5, F6
Oils/Fats/Grease
F1, F2
Nitrates/Ammonia
F4, F5, F6,F7
Phosphorus
F8
Page 71 of 132
5.
5.1
Emission Limit Values
INTERPRETATION OF COMPLIANCE
Unless otherwise detailed in the licence, the following interpretation of compliance with
limit values should apply:
5.1.1 Emissions to waters
The limit values for discharges to water are based on 24 hour flow proportional
composite samples unless otherwise specified.
5.2
Releases to Water
Effluent should be minimised by recovery of materials wherever practicable. The use of
lower quality water may be possible for some parts of the process rather than fresh
water.
All releases to waters are subject to a licence from the Agency. However, any discharge
to a sewer, will also require the consent of the sanitary authority. BATNEEC to
minimise the release of substances will generally include minimisation at source and
either specific treatment of contaminated waste streams to remove particular substances
or co-treatment of combined effluent streams or both. The Emission Limit Values for
effluent discharges to waters are set out in Table 5.1 overleaf.
Table 5.1 - Emission Limit Values for Discharges to Water*
Constituent Group
or Parameter
pH
BOD
Toxic Units
Total Nitrogen (as N)**
Total Phosphorus (as P)**
Total Ammonia (mg/l as N)
Oils, Fats and Grease (mg/l)
Fish Tainting
Mineral Oil (Interceptor) (mg/l)
Limit Value
Notes
6-9
>90% removal
or 40 mg/l
5
>80% Removal
or 15 mg/l
>80% Removal
or 2 mg/l
10
15
No Tainting
20
4
1,4
Page 72 of 132
2,4
4,5
4,5
4
4
3,4
4
* All values refer to daily averages, except where otherwise stated to the contrary,
and except for pH which refers to continuous values. Limits apply to effluents prior
to dilution by any uncontaminated streams, e.g. cooling water, stormwater, etc.
** Only applicable to waters subject to eutrophication. One or both limits may apply,
depending on the sensitivity of the receiving waters.
Notes for Table 5.1:
1. The daily raw waste load for BOD is defined as the average daily mass arising
for treatment over any three month period.
Calculations of the removal rates for BOD should be based on the differences
between the waste loads arising for disposal and those discharged to the receiving
waters. The amounts removed by treatment (chemical, physical, biological) may
be included in the calculation.
2. The toxicity of the effluent shall be determined on an appropriate aquatic
species. The number of Toxicity Units (TU) = 100/96 hr LC50 in percentage
vol/vol. so that higher TU values reflect greater levels of toxicity.
3. No substances shall be discharged in a manner which, or at a concentration
which, following initial dilution causes tainting of fish or shellfish, interferes with
normal patterns of fish migration or which accumulates in sediments or biological
tissues to the detriment of fish, wildlife or their predators.
4. Consent conditions for these parameters for discharge to municipal treatment
plants can be established with the Licensing Authority, and different values may
apply.
5. Reduction in relation to influent load. Total nitrogen means the sum total of
Kjeldahl-nitrogen plus nitrate-nitrogen plus nitrite-nitrogen.
Page 73 of 132
Extract from EPA Batneec Guidance Note For The Manufacture of
Sugar
4.
4.1
CONTROL TECHNOLOGIES
INTRODUCTION
As explained in Section 2, this Guidance Note identifies BATNEEC but obviously
does so in the absence of site-specific information. Accordingly it represents the
requirements expected of any new activity covered by the Note, but does not
exclude additional requirements which may form part of the granting of a licence
for a specific site.
The approach to be used in selecting BATNEEC is based on the following
hierarchy:

Process design / redesign changes to eliminate emissions and wastes that
might pose environmental problems.

Substitution of materials (e.g. low sulphur fuel) by environmentally less
harmful ones.

Demonstration of waste minimisation by means of process control,
inventory control and end-of-pipe technologies etc.
The existing or possible measures for preventing, reducing and controlling
emissions are described in this section. These range from relatively simple
containment measures to sophisticated recovery and "end-of-pipe" technologies
and include:
(i)
(ii)
(iii)
(iv)
(v)
Load minimisation
Containment
Recovery/recycle
Emission reduction
Waste treatment and disposal
The technical feasibility of the measures listed below has been demonstrated by
various sources. Used singly or in combination, the measures represent BATNEEC
solutions when implemented in the appropriate circumstances. The circumstances
depend on plant scale, number of different products produced, etc. A summary of
the treatments for various emissions is given at the end of the section.
Note that where hazardous (including asphyxiant) dusts or vapours occur, safety
procedures (acceptable to HSA) should be adopted. In these, and any other matters
concerning safety, appropriate safe working practices should be adopted and
nothing in this note should be construed as advice to the contrary.
Page 74 of 132
4.2 TECHNOLOGIES FOR LOAD MINIMISATION
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).





Sulphur reduction by using boiler gases for direct drying.
Inventory control.
Optimisation of water usage.
Dry equipment cleaning and dry vacuum systems, where feasible.
Separation of cooling water, storm water and process effluents of different origin
in order to permit appropriate treatment options.
4.3 PREVENTION OF EMISSIONS
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).











Enclosure of materials (excluding beet and bulk liquids), storage, handling,
processing and transfer within a suitable building.
Closed storage and transfer systems for milled material, raw material, etc.
Bunding of tanks.
Overground pipelines and transfer lines.
Only totally enclosed conveyors to be used for dusty materials.
Check system to avoid acceptance of improper materials and to ensure "first-infirst processed".
Overfilling protection on bulk storage tanks.
Heat recovery to be used where practicable e.g. boiler gases for drying.
Local extract systems as appropriate e.g. drier, mill, cookers, diffusers, etc.
Condensers on all appropriate process equipment e.g. evaporators, vacuum pans,
etc.
Lime handling to be carried out in a suitably controlled manner to contain dust
emissions.
4.4 TECHNOLOGIES FOR RECOVERY AND RECYCLE
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).

Reuse of process wastes and sludges (e.g. lime, pulp, molasses, sand, vegetable
fines, etc.)
 Recovery of water vapour for reuse.
4.5 TECHNOLOGIES FOR TREATING EMISSIONS TO AIR
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
(Symbols refer to table 4.1).




Condensation (T1).
Filtration (fabric filters normally adequate) (T2).
Cyclones (T3).
Scrubbers (T4).
Page 75 of 132
4.6
TECHNOLOGIES FOR TREATING WATER EMISSIONS
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
(Symbols refer to table 4.2).
4.6.1 Primary Treatment



pH Correction/neutralisation (F1).
Coagulation/flocculation/precipitation (F2).
Sedimentation/filtration/floatation (F3).
4.6.2 Secondary Treatment





Biofilters (F4).
Anaerobic treatment (F5).
Activated sludge/aeration lagoons (F6).
Extended aeration (F7).
Nitrification/denitrification (F8).
4.6.3 Tertiary Treatment

Filtration/coagulation/precipitation (F9).
4.7 TECHNOLOGIES FOR THE TREATMENT AND DISPOSAL OF WASTES
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
4.7.1 Sludge Treatment






Gravity thickening.
Dissolved air floatation.
Filtration.
Centrifugation.
Sludge digestion.
Drying.
4.7.2 Disposal




Reuse of process waste for animal feed and downstream processing.
Engineered landfill of wastes.
Landspreading of wastes (as fertiliser).
Land reclamation/soil conditioning (e.g. sand, soil, etc.)
Page 76 of 132
Table 4.1 - Summary of Technologies for Treating Emissions to Air
(Symbols refer to section 4.5)
Emission Type
Technology
Steam
T1
Particulates
T2, T3, T4
Table 4.2 - Summary of Technologies for Treating Water Emissions
(Symbols refer to Section 4.6)
Emission Type
Technology
Organics
F2, F3, F4, F5, F6, F7
Suspended Solids
F2, F3, F9
Nitrates/Ammonia
F8, F7, F6, F5, F4
Alkali (e.g. lime)
F1
5.
Emission Limit Values
5.1
REFERENCE CONDITIONS
The reference conditions for concentrations of substances in emissions to air from
contained sources are:
For non-combustion gases:
Temperature 273 K; Pressure 101.3 kPa; no correction for water vapour content.
For combustion gases:
Temperature 273 K; Pressure 101.3 kPa; dry gas; oxygen content 11%.
Page 77 of 132
These units and reference conditions may not be suitable for continuous
monitoring methods and may, by agreement with the Agency, be converted, for
day to day control purposes, into values more suitable for the available
instrumentation.
5.2
INTERPRETATION OF COMPLIANCE
Unless otherwise detailed in the licence, the following interpretation of
compliance with limit values should apply:
5.2.1
Emissions to Air
For continuously monitored emissions, the following will be required for
compliance with measurements based on 30 minute mean values (unless
otherwise stated):
(i)
97% of all 30 minute mean measurements shall be below 1.2 times the
emission limit.
(ii)
No 30 minute mean measurement shall exceed 2.0 times the emission
limit.
(iii)
All daily mean values shall be less than the emission limit.
Where periodic monitoring is used to check compliance, all samples should
meet the consent conditions.
5.2.2
Emissions to Water
The limit values for discharges to water are based on 24 hour flow proportional
composite samples unless otherwise specified.
5.3
EMISSIONS TO AIR
Emission Limit Values representing BATNEEC are given in Table 5.1 below.
Table 5.1 - Emission Limit Values for Emissions to Air
Emission
Limit Value
Total Particulate Matter
50 mg/m3
Page 78 of 132
5.4
RELEASES TO WATER
Effluent should be minimised by recovery of materials wherever practicable. The use of
lower quality water may be possible for some parts of the process rather than fresh
water (e.g. condensate for washing raw materials).
All releases to waters are subject to a licence from the Agency. However any discharge
to sewer will require the consent of the sanitary authority. BATNEEC to minimise the
release of substances will generally include minimisation at source and either specific
treatment of contaminated waste streams to remove particular substances or cotreatment of combined effluent streams or both. The Emission Limit Values for effluent
discharges to waters are set out in Table 5.2.
Table 5.2 - Emission Limit Values for Discharges to Water*
Constituent Group
or Parameter
pH
BOD
Toxic Units
Total Nitrogen(as N)**
Total Phosphorus (as P)**
Ammonia (mg/l as N)
Oils, Fats and Grease (mg/l)
Fish Tainting
Mineral Oil (Interceptor) (mg/l)
Limit Value
Notes
6-9
>90% removal
or 40 mg/l
5
>80% Removal
or 15 mg/l
>80% Removal
or 2 mg/l
10
15
No Tainting
20
4
1,4
2,4
4,5
4,5
4
4
3,4
4
* All values refer to daily averages, except where otherwise stated to the contrary,
and except for pH which refers to continuous values. Limits apply to effluent prior
to dilution by any uncontaminated streams, e.g. stormwater, cooling water, etc.
**Only applicable to waters subject to eutrophication. One or both limits may apply
depending on the sensitivity of the receiving waters.
Notes for Table 5.2:
1.
The daily raw waste load for BOD is defined as the average daily mass
arising for treatment over any three month period.
Calculations of the removal rates for BOD should be based on the
differences between the waste loads arising for disposal and those
Page 79 of 132
discharged to the receiving waters. The amounts removed by treatment
(chemical, physical, biological) may be included in the calculation.
2.
The toxicity of the effluent shall be determined on an appropriate aquatic
species. The number of Toxicity Units (TU) = 100/96 hr LC50 in
percentage vol/vol. so that higher TU values reflect greater levels of
toxicity.
3.
No substances shall be discharged in a manner which, or at a concentration
which, following initial dilution causes tainting of fish or shellfish,
interferes with normal patterns of fish migration or which accumulates in
sediments or biological tissues to the detriment of fish, wildlife or their
predators.
4.
Consent conditions for these parameters for discharge to municipal
treatment plants can be established with the Licensing Authority, and
different values may apply.
5.
Reduction in relation to influent load. Total nitrogen means the sum total of
Kjeldahl-nitrogen plus nitrate-nitrogen plus nitrite-nitrogen.
Page 80 of 132
Extract from EPA Batneec Guidance Note For The Manufacture Or
Use Of Coating Materials
4.
4.1
CONTROL TECHNOLOGIES
INTRODUCTION
As explained in Section 2, this Guidance Note identifies BATNEEC but obviously
does so in the absence of site-specific information. Accordingly it represents the
requirements expected of any new activity covered by the Note, but does not
exclude additional requirements which may form part of the granting of a licence
for a specific site.
The approach to be used in selecting BATNEEC is based on the following
hierarchy:

Process design / redesign changes to eliminate emissions and wastes that
might pose environmental problems (e.g. use of powder coating instead of
solvent based).

Substitution of materials (e.g. water based coatings instead of solvent based)
by environmentally less harmful ones.

Demonstration of waste minimisation by means of process control,
inventory control and end-of-pipe technologies, etc.
The existing or possible measures for preventing, reducing and controlling
emissions are described in this section. These range from relatively simple
containment measures to sophisticated recovery and "end-of-pipe" technologies
and include:
(i)
(ii)
(iii)
(iv)
(v)
Load minimisation
Containment
Recovery/recycle
Emission reduction
Waste treatment and disposal
The technical feasibility of the measures listed below has been demonstrated by
various sources. Used singly or in combination, the measures represent BATNEEC
solutions when implemented in the appropriate circumstances. The circumstances
depend on plant scale, materials used, nature of the products made, number of
different products produced, etc. A summary of the treatments for various
emissions is given at the end of the section.
Note that where hazardous (including asphyxiant) dusts or vapours occur, safety
procedures (acceptable to the Health and Safety Authority) should be adopted. In
these and any other matters concerning safety, appropriate safe working practices
Page 81 of 132
should be adopted and nothing in this note should be construed as advice to the
contrary.
4.2 TECHNOLOGIES FOR LOAD MINIMISATION
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).





















Inventory control.
Optimisation of water usage.
Dry equipment cleaning and dry vacuum systems, where feasible (dry sweeping
to be avoided).
Separation of cooling water, storm water and process effluents of different origin
in order to permit appropriate treatment options.
Water based cleaning systems to be selected instead of solvent based systems.
Where practicable, use of non-nitrogenated pre-treatment chemicals.
Except where unavoidable, the following shall not be used:
(i) Halogenated substances.
(ii) Aromatic solvents.
(iii) Organic solvents containing compounds classified as Carcinogens,
Mutagens, or Toxic to Reproduction under Directive 67/548/EEC (with
labels containing the R phrases R45, R46, R49, R60, R61).
(iv) Chlorine based oxidising substances.
(v) Solvents containing formaldehyde or n-hexane.
Inplant measures to extend the service life of pre-treatment baths e.g. filtration,
oil skimming, etc.
Use of countercurrent rinsing and suitable techniques to minimise drag-out.
Spray application to be selected instead of bath immersion where appropriate.
Shot blasting is preferred to sand blasting.
Ultrasonic cleaning.
Substitution of solvent based coatings with powder coatings or, where this is not
practicable, with water based coatings.
Use of organic pigments rather than metal based pigments.
Use of Chrome III rather than Chrome VI in chromating.
Use of high solid content coating materials.
Use of hot melt adhesives.
Radiation cure (e.g. UV, electron beam) rather than oven cure.
Optimisation of mixing procedure to minimise VOC emissions (e.g. reduced
mixing times, cooling of mixer etc.)
Oven temperature to be controlled to minimise the emission of organic coating
breakdown products.
Where practicable, spray coatings to be applied using one of the following
systems to achieve a transfer efficiency of > 65%.
(i) High volume low pressure (HVLP).
(ii) Electrostatic application techniques.
4.3 PREVENTION OF EMISSIONS
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
Page 82 of 132

Enclosure of materials (excluding bulk liquids), storage, handling, processing and
transfer within a suitable building.
 Bunding of tanks.
 Overground pipelines and transfer lines.
 Overfilling protection on bulk storage tanks.
. Heat recovery to be used where practicable.
 Local extract and abatement systems as appropriate e.g. dryers, coating and pretreatment areas etc.
 Minimisation of tank filling losses by e.g. vapour return systems.
 Single controlled emission point for all large dedicated plants.
 Check system to avoid mixing incompatible materials.
 Use of closed transfer systems and lidded holding vessels.
 Solvent vapour emissions to be contained by e.g. refrigerated freeboards, covered
baths etc.
 The cleaning of plant and equipment to be carried out in a dedicated system with
VOC capture and recovery.
 Curing ovens emissions to be suitably contained by e.g. end zone exhaust
ventilation or air curtains.
 Flash-off zones and coating application areas to be extracted by local exhaust
ventilation.
 Ovens and ductwork should be maintained gas tight if under positive pressure
and
leakproof if under negative pressure.
4.4 TECHNOLOGIES FOR RECOVERY AND RECYCLING
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).


Solvent recovery plant.
VOC abatement with solvent recovery (e.g. carbon adsorption and regeneration).
4.5 TECHNOLOGIES FOR TREATING EMISSIONS TO AIR
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
(Symbols refer to Table 4.1)







Condensation (T1).
Filtration (fabric or paper filters normally adequate) (T2).
Vapour incineration (Thermal, catalytic and regenerative) (T3).
Wet scrubbers (T4).
Carbon adsorption (T5).
Cyclones (T6).
Biofilters (T7).
4.6 TECHNOLOGIES FOR TREATING WATER EMISSIONS
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
(Symbols refer to Table 4.2).
Page 83 of 132
4.6.1 Pre-treatment

Reduction (F1).
4.6.2 Treatment




pH Correction/neutralisation (F2).
Coagulation/flocculation/precipitation (F3).
Sedimentation/filtration/flotation (F4).
Centrifugation (F5).
4.6.3 Polishing


Resin beds (F6).
Reverse osmosis (F7).
4.7 TECHNOLOGIES FOR THE TREATMENT AND DISPOSAL OF WASTES
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
4.7.1 Sludge Treatment



Gravity thickening.
Filtration.
Centrifugation.
4.7.2 Disposal




Engineered landfill of wastes.
Incineration. (Incinerator emissions are subject to a separate note).
Waste encapsulation.
Reuse in another industry (e.g. as fuel).
Table 4.1 - Summary of Technologies for Treating Emissions to Air
(Symbols refer to section 4.5)
Emission Type
Technology
Particulates
T2, T4, T6
Odours
T1, T3, T4, T5, T7
Acids/Alkalis
T4
VOC's
T1, T3, T5, (T7)
Page 84 of 132
Table 4.2 - Summary of Technologies for Treating Water Emissions
(Symbols refer to section 4.6)
Emission Type
Technology
Acids/Alkalis
F2
Phosphates
F3
Ammonia/Nitrates
-
Suspended Solids
F3, F4, F5
Metals
F1, F3, F6, F7
Oils
F4
5.
Emission Limit Values
5.1
REFERENCE CONDITIONS
The reference conditions for concentrations of substances in emissions to air from
contained sources are:
Temperature 273K; Pressure 101.3 kPa; no correction for water vapour content.
These units and reference conditions may not be suitable for continuous
monitoring methods and may, by agreement with the Agency, be converted, for
day to day control purposes, into values more suitable for the available
instrumentation.
5.2
INTERPRETATION OF COMPLIANCE
Unless otherwise detailed in the licence, the following interpretation of
compliance with limit values should apply:
Page 85 of 132
5.2.1
Emissions to Air
For continuously monitored emissions, the following will be required for
compliance with measurements based on 60 minute mean values (unless
otherwise stated):
(i) No 60 minute mean measurement shall exceed 1.5 times the emission limit.
(ii) All 8 hour moving average values shall be less than the emission limit.
Only the periods in which the installations or processes are actually in operation
are to be taken into account.
Where periodic monitoring is used to check compliance, all samples should
meet the consent conditions.
The mass emission of solvents should be determined by a mass balance to derive
total solvent loss using throughput data and solvent purchase and recovery
records. A detailed inventory of solvent purchase should be kept.
Where odourous materials are released, lower ELV values may be required in
specific cases to prevent odour nuisance.
5.2.2
Emissions to waters
The limit values for discharges to water are based on 24 hour flow proportional
composite samples unless otherwise specified.
5.3
EMISSIONS TO AIR
Emission Limit Values representing BATNEEC are given in Tables 5.1 - 5.4 .
Page 86 of 132
Table 5.1 - Emission Limit Values for Emissions to Air for All Sources
(Tables 5.2 - 5.4 also apply as appropriate)
Emission
Total Solvent
Limit Values for Waste Gas Discharges
Source
Use or Consumption
(mg/m3)
All
Above the threshold
1
Class A (total): 2
(tonnes/annum) given in
(for mass emissions > 10 g/h of Class A compounds)
Tables 5.2 - 5.4
2
Class B (total): 20
(for mass emissions > 100 g/h of Class B compounds)
Particulates (spray painting operations): 3
Other Emissions: See tables 5.2 - 5.4
All
1
Below the threshold
Class A (total): 2
(for mass emissions > 10 g/h of Class A compounds)
(tonnes/annum)
given in Tables 5.2 - 5.4
2
Class B: As per T.A. Luft 1986 for Organic compounds
of Classes I and II. Otherwise include in other emissions.
Other Emissions plus Class B compounds: 150 (as C)
(for mass emissions > 3 kg/h total)
Particulates (spray painting operations): 3
(Achievement of ELV concentrations by the introduction of dilution air is not
permitted).
1
Class A compounds are substances with labels containing the R phrases R45, R46,
R49, R60 or R61 as classified under Directive 67/548/EEC ( as modified by Directive
93/21/EEC). Examples of these are:
R45
R60-61
benzene; 1,2-dichloroethane; 2-nitropropane;
1,2-dibromoethane; 1,3-dichloro-2-propanol
2-methoxyethanol; 2-ethoxyethanol;
2-methoxyethylacetate; 2-ethoxyethylacetate.
2
Class B compounds are chlorinated organic solvents with labels containing the risk
phrase R40 as classified under Directive 67/548/EEC (as modified by Directive
Page 87 of 132
93/21/EEC). Examples of these are 1,1,2,2-tetrachloroethane, dichloromethane,
tetrachloromethane and tetrachloroethylene.
Table 5.2 - Emission Limit Values for Emissions to Air from Printing Processes
(These values apply in addition to those in Table 5.1 as appropriate)
Emission Source
Heatset web
Solvent
Limit Values for Waste Gas Discharges
Use or
(mg/m3)
Consumption
15 - 25
tonnes/annum
Total organics (as C):150
offset
Publication
>25
tonnes/annum
Total organics (as C): 20
>25
tonnes/annum
Total organics (as C): 100
>15
tonnes/annum
Total organics (as C): 150
rotogravure
Other
rotogravure,
flexography,
rotary screen,
laminating,
varnishing
(Achievement of ELV concentrations by the introduction of dilution air is not
permitted.)
Page 88 of 132
Table 5.3 - Emission Limit Values for Emissions to Air from Vehicle Coating
(These values apply in addition to those in Table 5.1 as appropriate)
Emission Source
New cars
New truck
cabins
New vans trucks
and trailers
Solvent
Limit Values for Waste
Number of
Total Emission
Use or
Gas Discharges
vehicles
Limit
Consumption
(mg/m3)
>15
tonnes/annum
Total organics (as C): 50
>15
tonnes/annum
>15
tonnes/annum
Total organics (as C): 50
Total organics (as C): 50
>5000 cars
/annum
<70 g/m2
(cars above 6
seats)
<45 g/m2
(cars up to 6
seats)
<5000 cars
/annum
<90 g/m2
>5000
cabins/annum
<55 g/m2
<5000
cabins/annum
>2500
units/annum
<65 g/m2
<70 g/m2
<90 g/m2
<2500
units/annum
New buses
Vehicle coating
and refinishing
>15
tonnes/annum
>10
tonnes/annum
Total organics (as C): 50
>500
buses/annum
<150 g/m2
<500
buses/annum
210 g/m2
-
25%
(of solvent
input)
Total organics (as C): 50
(Achievement of ELV concentrations by the introduction of dilution air is not
permitted.)
Page 89 of 132
Table 5.4 - Emission Limit Values for Emissions to Air from Other Coating Processes
(These values apply in addition to those in Table 5.1 as appropriate)
Emission
Source
Solvent
Use or
Consumption
Limit Values for Waste
Gas Discharges
(mg/m3)
Total
Emission
Limit
(as solvent
usage)
Coating and drying
Total organics (as C): 50
Coil
coating
>25
tonnes/annum
Leather
coating
10-25
tonnes/annum
-
<85g/m2 of total
coated surface
>25
tonnes/annum
-
<75g/m2 of total
coated surface
Adhesives
coating
Other coating
(e.g. textiles,
fabric, film &
paper)
>10
tonnes/annum
10 - 15
tonnes/annum
-
Coating and drying
Total organics (as C):
150 (absorption and reuse)
50 (incineration)
Coating and drying
Total organics (as C):150
-
-
>15
tonnes/annum
Coating
Total organics (as C):100
Drying
Total organics (as C):50
(Achievement of ELV concentrations by the introduction of dilution air is not
permitted.)
Page 90 of 132
Table 5.4 - Continued
(These values apply in addition to those in Table 5.1 as appropriate)
Emission Source
Pharmaceutical
finishing
Wood
coating
Solvent
Use or
Consumption
>50
tonnes/annum
15-25
tonnes/annum
>25
tonnes/annum
Manufacture of
coatings,
varnishes, inks
>100
tonnes/annum
Limit Values for Waste Gas Discharges
(mg/m3)
Total organics (as C): 150 (reuse)
Total organics (as C): 20 (no reuse)
Coating and drying
Total organics (as C): 150
Coating
Total organics (as C): 100
Drying
Total organics (as C): 50
Total organics (as C): 150
and adhesives
(Achievement of ELV concentrations by the introduction of dilution air is not
permitted.)
5.4 Emissions to Water
Effluent should be minimised by recycling and re-use of materials wherever
practicable. The use of lower quality water may be possible for some parts of the
process rather than fresh water.
All releases to waters are subject to a licence from the Agency. However any
discharges to sewer will require the consent of the sanitary authority. BATNEEC to
minimise the release of substances will generally include minimisation at source and
either specific treatment of contaminated waste streams to remove particular substances
or co-treatment of combined effluent streams or both. The Emission Limit Values for
effluent discharges to waters are set out in Table 5.5.
Page 91 of 132
Table 5.5 - Emission Limit Values for Discharges to Water*
Constituent Group
or Parameter
pH
BOD
Toxic Units
Total Nitrogen (as N)**
Total Phosphorus (as P)**
Ammonia (mg/l as N)
Fish Tainting
Oil (mg/l)
Organohalogens (mg/l as Cl)
Zinc (mg/l)
Chromium VI (mg/l)
Chromium (Total) (mg/l)
E.C. List 1
*
Limit Value
Notes
6-9
3
25 mg/l
3
5
1,3
>80% Removal
or 15 mg/l
>80% Removal
or 2 mg/l
10
No Tainting
20
0.1 (monthly ave.)
0.5
0.1
0.5
As per 76/464/EEC
and amendments
3,4
3,4
3
2,3
3
3
3
3
3
-
All values refer to daily averages, except where otherwise stated to the contrary,
and except for pH which refers to continuous values. Limits apply to effluent
prior to dilution by any uncontaminated streams, e.g. storm water, cooling water,
etc.
** Only applicable to waters subject to eutrophication. One or both parameters may
be applied depending on the local situation.
Notes for Table 5.5
1.
The toxicity of the effluent shall be determined by testing an appropriate
aquatic species. The number of Toxicity Units (TU) = 100/96 hr LC50 in
percentage vol/vol. so that higher TU values reflect greater levels of
toxicity.
2.
No substances shall be discharged in a manner which, or at a concentration
which, following initial dilution causes tainting of fish or shellfish,
interferes with normal patterns of fish migration or which accumulates in
sediments or biological tissues to the detriment of fish, wildlife or their
predators.
3.
Consent conditions for discharge to sewer must be established with the
sanitary authority, and different values may apply.
Page 92 of 132
4.
Reduction in relation to influent load. Total nitrogen means the sum total of
Kjeldahl-nitrogen plus nitrate-nitrogen plus nitrite-nitrogen.
Page 93 of 132
Extract from EPA Batneec Guidance Note For Textile Finishing
4.
4.1
CONTROL TECHNOLOGIES
INTRODUCTION
As explained in Section 2, this Guidance Note identifies BATNEEC but obviously
does so in the absence of site-specific information. Accordingly it represents the
requirements expected of any new activity covered by the Note, but does not
exclude additional requirements which may form part of the granting of a licence
for a specific site.
The approach to be used in selecting BATNEEC is based on the following
hierarchy:

Process design / redesign changes to eliminate emissions and wastes that
might pose environmental problems (e.g. use of powder coating instead of
solvent based).

Substitution of materials (e.g. water based coatings instead of solvent based)
by environmentally less harmful ones.

Demonstration of waste minimisation by means of process control,
inventory control and end-of-pipe technologies, etc.
The existing or possible measures for preventing, reducing and controlling
emissions are described in this section. These range from relatively simple
containment measures to sophisticated recovery and "end-of-pipe" technologies
and include:
(i)
(ii)
(iii)
(iv)
(v)
Load minimisation
Containment
Recovery/recycle
Emission reduction
Waste treatment and disposal
The technical feasibility of the measures listed below has been demonstrated by
various sources. Used singly or in combination, the measures represent BATNEEC
solutions when implemented in the appropriate circumstances. The circumstances
depend on plant scale, materials used, nature of the products made, number of
different products produced, etc. A summary of the treatments for various
emissions is given at the end of the section.
Note that where hazardous (including asphyxiant) dusts or vapours occur, safety
procedures (acceptable to the Health and Safety Authority) should be adopted. In
these and any other matters concerning safety, appropriate safe working practices
should be adopted and nothing in this note should be construed as advice to the
contrary.
Page 94 of 132
4.2 TECHNOLOGIES FOR LOAD MINIMISATION
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).













Inventory control.
Optimisation of water usage.
Countercurrent rinsing.
Chlorine-free bleaching.
Dry equipment cleaning and dry vacuum systems, where feasible.
Separation of cooling water, storm water and process effluents of different origin
in order to permit appropriate treatment options.
Except where unavoidable, the following shall not be used:
(i) Halogenated substances.
(ii) Phosphates.
(iii) Sodium perborate.
(iv) Substances containing PCP (pentachlorophenol) or its precursors,
polybrominated diphenylethers, and biphenyls.
(v) Heavy metal based dyestuffs (where unavoidable, low metal based dyes
must be selected).
(vi) Reductive sulphur containing bleaches (peroxide bleaches are an
alternative).
(vii) Sodium hydrosulphite.
(viii) Urea.
(ix) "Chrome" oxidation (alternatives are alkaline and acid hydrogen peroxide).
(x) White spirits and aromatic solvents.
Raw materials shall be investigated for their potential contribution of EC List 1
substances to aquatic discharges. Alternatives shall be sought for those with such
potential.
Except where unavoidable, only biodegradable chemicals shall be used. (wetting
agents, emulsifiers, surfactants, sizing agents, etc).
Dyestuffs containing any of the following substances shall not be used:
(i) PCB's (Polychlorinated biphenyls).
(ii) Cadmium.
(ii) Benzidine bases.
(iv) Carriers containing chlorine.
(v) Carcinogens (R45 risk phase under EC Dir. 67/548/EEC).
(vi) Formaldehyde.
Chlorine free shrinkproofing is preferred.
High temperature dyeing (redundancy of carried use).
Use of reactive dyes (to eliminate chromate for fixation).
4.3 PREVENTION OF EMISSIONS
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).

Enclosure of materials (excluding bulk liquids), storage and handling within a
suitable building.
 Bunding of tanks.
Page 95 of 132





Single controlled emission point for all large dedicated plants.
Overground pipelines and transfer lines.
Check system to avoid mixing incompatible materials.
Bunding of all stored materials with separate bunding for incompatibles.
Overfilling protection on bulk storage tanks.
4.4 TECHNOLOGIES FOR RECOVERY AND RECYCLE
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
 Heat Recovery.





4.5
Recycle of process liquors.
Cryogenic condensation on reactor overheads.
Carbon adsorption/desorption on vapour streams containing organics.
Reuse in another industry.
Onsite solvent recovery.
TECHNOLOGIES FOR TREATING EMISSIONS TO AIR
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
(Symbols refer to Table 4.1)



Bag filters (T1).
Wet electrostatic precipitators (T2).
Vapour incineration (thermal, catalytic and regenerative) (T3).
4.6 TECHNOLOGIES FOR TREATING WATER EMISSIONS
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
(Symbols refer to Table 4.2)
4.6.1 Pre-Treatment




Precipitation (F1).
Oxidation (F2).
Adsorption (F3).
Membrane filtration (F4).
4.6.2 Primary Treatment



pH Correction/neutralisation (F5).
Coagulation/flocculation/precipitation (F6).
Sedimentation/filtration/floatation (F7).
4.6.3 Secondary Treatment




Biofilters (F8).
Anaerobic treatment (F9).
Wet air oxidation (F10).
Activated sludge/aeration lagoons (F11).
Page 96 of 132



Extended aeration (F12).
Nitrification/denitrification (F13).
Ozonation/oxidation (F14).
4.6.4 Tertiary Treatment



Filtration/coagulation/precipitation (F15).
Activated Carbon polishing (F16).
Resin beds (F17).
4.7 TECHNOLOGIES FOR THE TREATMENT AND DISPOSAL OF WASTES
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
4.7.1 Sludge Treatment






Gravity thickening
Dissolved air floatation
Filtration
Centrifugation
Sludge digestion
Drying
4.7.2 Disposal



Incineration (Incinerator emissions are the subject of a separate note).
Engineered landfill of wastes.
Landspreading of wastes.
Table 4.1 - Technologies for Treating Emissions to Air
(Symbols refer to section 4.5)
Emission Type
Technology
Dust and lint, fabric fibres
T1, T2
VOC's
T3
Oils, greases, waxes
T2
Page 97 of 132
Table 4.2 - Technologies for Treating Effluent
(Symbols refer to section 4.6)
Emission Type
Technology
Heavy Metals
Sulphides
Biocides
AOX
Mineral Oils
Acids/Alkalis
Phenols
Organics
F1, F16, F17
F2, F10, F11, F12, F14
F3, F6, F10
F3, F16, F10
F4
F5
F3, F10, F11, F12, F14, F16
F6, F7, F8, F9, F10, F11, F12, F14, F16,
F17
F4, F9, F10
F6, F7, F10
F6, F7, F10
F4, F6, F10, F14, F15, F16
F13, F9, F10, F11, F12, F14
Sizing Agents
Polyester latex, Polyacrylates
Oils/Fats/Grease
Dyes
Ammonia/Nitrate
5.
Emission Limit Values
5.1
REFERENCE CONDITIONS
The reference conditions for concentrations of substances in emissions to air from
contained sources are:
For non-combustion gases:
Temperature 273 oK; Pressure 101.3 kPa; no correction for water vapour content.
These units and reference conditions may not be suitable for continuous
monitoring methods and may, by agreement with the Agency, be converted, for
day to day control purposes, into values more suitable for the available
instrumentation.
5.2
INTERPRETATION OF COMPLIANCE
Unless otherwise detailed in the licence, the following interpretation of
compliance with limit values should apply:
Page 98 of 132
5.2.1
Emissions to Air
For continuously monitored emissions, the following will be required for
compliance with measurements based on 30 minute mean values (unless
otherwise stated):
(i)
97% of all 30 minute mean measurements shall be below 1.2 times the
emission limit.
(ii)
No 30 minute mean measurement shall exceed 2.0 times the emission
limit.
(iii)
All daily mean values shall be less than the emission limit.
Where periodic monitoring is used to check compliance, all samples should
meet the consent conditions.
5.2.2
Emissions to waters
The limit values for discharges to water are based on 24 hour flow proportional
composite samples unless otherwise specified.
5.3
EMISSIONS TO AIR
Emission Limit Values representing BATNEEC are given in Table 5.1.
Table 5.1 - Emission Limit Values for Emissions to Air
Substance
Emission Limit mg/m3
VOC's (as C) >1kg/h
(excluding Formaldehyde)
50 (no reuse)1
Particulates
50
Isocyanates (as NCO)
0.1
Formaldehyde
20
(Achievement of ELV concentrations by the introduction of dilution air is not
permitted).
Note 1. Where reuse occurs the ELV’s shall be as for T.A. Luft Organics. Re-use
means use of recovered solvents for any technical or commercial purpose,
including use as a fuel when this is demonstrated to the satisfaction of the
Agency, but excluding the final disposal of such recovered solvent as waste.
Page 99 of 132
5.4
Emissions to Water
Effluent should be minimised by recovery of materials wherever practicable. The use
of lower quality water may be possible for some parts of the process rather than fresh
water.
All releases to waters are subject to a licence from the Agency. However any
discharge to sewer will require the consent of the sanitary authority. BATNEEC to
minimise the release of substances will generally include minimisation at source and
either specific treatment of contaminated waste streams to remove particular
substances or co-treatment of combined effluent streams or both. The Emission Limit
Values for effluent discharges to waters are set out in Table 5.2.
Page 100 of 132
Table 5.2 - Emission Limit Values for Discharges to Water1
Constituent Group
or Parameter
pH
BOD
Number of Toxicity Units
Total Nitrogen (as N)2
COD (mg O2 /l)
Total Phosphorus (as P)2
Total Ammonia (mg/1 as N)
Oils, Fats & Grease (mg/1)
Phenols (mg/l)
Mercury (mg/1)
Nickel (mg/l)
Cobalt (mg/l)
Lead (mg/l)
Antimony (mg/l)
Tin (mg/l)
Chromium (mg/l as Cr VI)
Chromium (mg/l as total Cr)
Arsenic (mg/l)
Cadmium (mg/l)
Zinc (mg/l)
Copper (mg/l)
Mineral Oil (mg/l) (Interceptors)
EC. List 1
Benzene & Toluene & Xylene
(mg/l combined)
Mineral oils (mg/l)(Biological Treatment)
Organochlorine pesticides (mg/l as Cl)
Mothproofing agents (mg/l as Cl)
Organophosphorus pesticides (mg/l as P)
Adsorbable organic halogen compounds
(mg AOX/l)3
Sulphide (mg/l as S)
Fish Tainting
Limit Value
Notes
6-9
>90% removal
or 50 mg/l
5
4
1,4
>80% Removal
or 15 mg/l
>80% Removal
or 160 mg/l
>80% Removal
or 2 mg/l
10
10
1.0
0.001
0.5
0.5
0.1
1.0
1.0
0.1
0.5
0.2
0.01
2.0
0.5
20
As per 76/464/EC and
amendments
0.1
(monthly mean)
1.0
0.003
0.0003
0.0003
1.0
4,5
0.5
No Tainting
4
3,4
2,4
4,5
4,5
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
1
All values refer to daily averages, except where otherwise stated to the contrary, and
except for pH which refers to continuous values. Limits apply to effluent prior to
dilution by any uncontaminated streams. e.g. stormwater, cooling water, etc. For
activities using well developed water conservation techniques alternative ELV’s may
be calculated based on the loads arising from these limits.
2
Only applicable to waters subject to eutrophication. One or both limits may apply,
depending on the sensitivity of the receiving waters.
Page 101 of 132
3
Absorbable organic halogen compounds.
Notes for Table 5.2
1.
The daily raw waste load for BOD is defined as the average daily mass
arising for treatment over any three month period.
Calculations of the removal rates for BOD should be based on the
differences between the waste loads arising for disposal and those
discharges to the receiving waters. The amounts removed by treatment
(chemical, physical, biological) may be included in the calculation.
2.
The toxicity of the effluent shall be determined by testing an appropriate
aquatic species. The number of toxic units (Tu) = 100/x hour EC/LC50 in
percentage vol/vol so that higher Tu values reflect greater levels of
toxicity. For test regimes where species death is not easily detected,
immobilisation is considered equivalent to death.
3.
No substances shall be discharged in a manner which, or at a concentration
which, following initial dilution causes tainting of fish or shellfish,
interferes with normal patterns of fish migration or which accumulates in
sediments or biological tissues to the detriment of fish, wildlife or their
predators.
4.
Consent conditions for discharge to sewer must be established with the
sanitary authority, and different values may apply.
5. Reduction in relation to influent load. Total nitrogen means the sum total of
Kjeldahl-Nitrogen plus nitrate-nitrogen plus nitrite-nitrogen.
Page 102 of 132
Extract from EPA Batneec Guidance Note For Waste
4.
4.1
CONTROL TECHNOLOGIES
Introduction
As explained in Section 2, this Guidance Note identifies BATNEEC, but
obviously does so in the absence of site-specific information. Accordingly, it
represents the requirements expected of any new activity covered by the Note,
but does not exclude additional requirements which may form part of the
granting of a licence for a specific site.
The approach to be used in selecting BATNEEC is based on the following
hierarchy:
 Incineration/Waste Fuel process design and selection to eliminate emissions
that pose environmental problems.
 Substitution e.g. of fuels by environmentally less harmful ones.
 Demonstration of waste minimisation by means of process control, inventory
control and end-of-pipe technologies etc.
The existing, or possible, measures for reduction and control of emissions are
described in this section. These range from relatively simple containment
measures to sophisticated recovery and end-of-pipe technologies and include:
(i)
Load Minimisation
(ii)
Containment
(iii) Recovery/recycle
(iv) Emission reduction
(v)
Waste treatment & disposal.
The technical feasibility of the measures listed below has been demonstrated by
various sources. Used singly or in combination, these measures represent
BATNEEC solutions when implemented in the appropriate circumstances. The
circumstances depend on plant scale, chemicals used, nature of the products
made, number of different products produced, degree of plant integration etc. A
summary of the treatments for various emissions is given at the end of this
section. Note that where flammable / explosive dusts or vapours are handled,
safety procedures (acceptable to the Health and Safety Authority ) should be
adopted and nothing in this note should be construed as advice to the contrary.
4.2
Load Minimisation:
Page 103 of 132
Incineration:












Screening/filtering of liquid wastes where appropriate.
Uncontaminated fuel supply for support burners.
Wastes should not be introduced to the incinerator before the optimum
temperature is reached in the final combustion chamber.
The waste charging system should be interlocked with the temperature
monitoring and control system to prevent waste additions, should the
operating temperature fall below the required limits.
Rapid quenching of waste gases should be incorporated into incinerator
design, where appropriate.
Minimum operating temperature (as measured at inner wall of combusion
chamber) of 850oC.
Minimum residence time of two seconds at the operating temperature.
Minimum oxygen content of 6% v/v (except when the furnace is fuelled with
liquid hazardous waste only or with a mixture of gaseous substances and
powdered solids from a thermal pretreatment of hazardous waste under
oxygen deficiency, and when the gaseous part provides more than 50% of the
entire heat released, the oxygen content after the last injection of combustion
air shall amount to at least 3% v/v).
Minimum operating temperature for hospital waste is 1100oC.
Minimum operating temperature for waste with >1% organochlorine
substances is 1100oC.
Gas cooling, quenching (possible heat recovery).
Dry equipment cleaning and dry vacuum systems, where feasible.
Waste Derived Fuel:




Screening to remove grit, dust and putrescible material.
Inventory control.
Avoid undue delays in processing material.
Segregation and prescreening of material into similar streams prior to arrival
on-site.
 Dry equipment cleaning and dry vacuum systems, where feasible.
4.3
Containment of Emissions:
(No priority ranking is intended, and the appropriate selection in a particular
case
will depend on the specifics of the process
concerned and on site constraints.)
Incineration:





Enclosure of materials (excluding bulk liquids), storage, handling, processing
and transfer within a suitable building.
Minimisation of tank filling losses by, e.g., vapour return systems.
Vent collection and ducting from tank farms to central abatement systems.
Mimimisation of tank breathing losses by pressure vacuum valves, isolation
and/or tanks painted white.
Overground pipelines and transfer lines.
Page 104 of 132








Floating roofs on bulk storage tanks.
Incinerator chamber design to withstand pressure surges.
Storage of delivered materials pending detailed analysis.
Check system to avoid mixing incompatible materials, where required.
Bunding of all stored materials with separate bunding for incompatibles.
Overfilling protection on bulk storage tanks.
Prevention of rain ingress, wind entrainment etc. for stored materials.
Inventory control.
Waste Derived Fuel:






4.4
Technologies for recovery and recycling:
(No priority ranking is intended, and the appropriate selection in a particular
case
will depend on the specifics of the process concerned and on site
constraints.)



4.5
Enclosure of materials (excluding bulk liquids), storage, handling, processing
and transfer within a suitable building.
Bunding of tanks.
All material handling under cover.
Check system to avoid blending inappropriate wastes.
Prevention of rain ingress, wind entrainment etc. for stored materials.
Separation of cooling waters, storm waters and process effluent of different
origins in order to permit appropraite treatment options.
Interceptor tanks at each process building.
Separation and reuse in another industry.
Gas cooling, quenching (possibly heat recovery).
Technologies for treating air emissions:
(No priority ranking is intended, and the appropriate selection in a particular
case
will depend on the specifics of the process concerned and on site
constraints.)
(Symbols in brackets explained in Table 4.1 below)
Incineration:







Scrubbers (T1).
Filters (T2).
Biofilters (T3).
Cyclones(T4).
Wet electrostatic precipitators (T5).
Thermal conditioning of plume (T6).
Combined bag filters, lime and activated carbon injection (T7).
Waste Derived Fuel:


Wet scrubbing (T1).
Filters (T2).
Page 105 of 132

Odour control by frequent cleaning and disinfection (e.g. 1-2 times/day)
(T8).
 Biofiltration (specialised plant) (T3).
 Afterburners (minimum 850oC, 6% O2 v/v) (T9).
Table 4.1 Technologies to treat Air Emissions.
Emission
Particulates
Sulphur and compounds
Nitrogen and compounds
Halogens and compounds
Metals, metalloids and compounds
Organic compounds
Phosphorus and compounds
Odours
Water vapour
4.6
Technologies
T2, T4, T5, T7, T9
T1, T3, T7
T3
T1, T7
T2, T4, T5, T7
T1, T3, T7, T9
T1, T7
T1, T3, T8, T9
T6
Technologies for treating water emissions:
(No priority ranking is intended, and the appropriate selection in a particular
case
will depend on the specifics of the process concerned and on site
constraints.)
Incineration:


Filtration /Coagulation/Precipitation (Heavy metals).
pH Correction / neutralisation (Acids & alkalis).
Waste Derived Fuel:









4.7
Precipitation (Heavy metals).
pH Correction / neutralisation (Acids & alkalis).
Coagulation / flocculation / precipitation (Dissolved & colloidal solids and
heavy metals).
Settlement / filtration / floatation (Solids removal).
Activated sludge (Organic treatment for BOD removal).
Extended aeration (Organic treatment for BOD removal).
Activated Carbon polishing (Trace organic removal).
Resin beds (Dissolved solids).
Phosphate removal.
Technologies for the treatment and disposal of wastes:
Page 106 of 132
(No priority ranking is intended, and the appropriate selection in a particular
case
will depend on the specifics of the process concerned and on site
constraints.)
Incineration:




Waste encapsulation.
Reuse in downstream processing.
Vitrification of waste.
Engineered landfill of wastes.
Waste Derived Fuel:

5.
5.1
Engineered landfill of wastes.
EMISSION LIMIT VALUES
Reference Conditions
5.1.1 Incineration Processes
The reference conditions for concentrations of substances in emissions to air
from contained sources are:
Temperature 273 K (00C),Pressure 101.3 kPa (1 atmosphere), Oxygen 11% v/v,
(except for waste oil incineration, 3% v/v), Dry Gas.
These units and reference conditions may not be suitable for continuous
monitoring methods and may, subject to licence, be converted for day-to-day
control purposes, into values more suitable for the available instrumentation.
5.1.2 Waste Derived Fuel
The reference conditions for concentrations of substances in emissions to air
from contained sources are:
Temperature 273 K (00C), Pressure 101.3 kPa (1 atmosphere), no correction for
oxygen or water content.
Page 107 of 132
These units and reference conditions may not be suitable for continuous
monitoring methods and may, subject to licence, be converted for day-to-day
control purposes, into values more suitable for the available instrumentation.
5.2
Interpretation of Compliance
5.2.1 Air emissions
5.2.1.1
Hazardous and Clinical Waste Incineration
For continuously monitored emissions, the following will be required for
compliance with measurements based on 30 minute mean values (unless
otherwise stated):
(i)
No 30 minute mean measurements shall exceed the 30 minute
emission limit values in Table 5.1.
(ii)
All daily mean values shall be less than the daily emission
concentration limits in Table 5.1
.
Where periodic monitoring is used to check compliance, all samples should
meet the consent conditions.
5.2.1.2
Animal Carcass and Other Incineration
For continuous monitoring, 95% of the 24-hour rolling average values shall
comply with the Emission Limit Values, and no hourly result shall exceed 1.5
times the Emission Limit Value.
5.2.2 Emissions to waters
The limit values for discharges to water are based on 24 hour flow
proportional composite samples taken over a representative production
period.
Page 108 of 132
5.3
Releases to Air
5.3.1 Incineration processes
Carbon Monoxide
The concentration of carbon monoxide after the last injection of combustion
air should not exceed the following levels:
(a)
50 mg/m3 of combustion gas determined as a daily average value;
(b)
100 mg/m3 of combustion gas determined as an hourly average
value;
(c)
150 mg/m3 of combustion gas of at least 95% of all measurements
determined as 10 minute average values taken in any 24 hour
period.
Other Emission Limits
For all new plant the following concentration limits apply to release from
contained sources:
Page 109 of 132
Table 5.1. Emission limit values for releases to air
Hazardous & ClinicalAnimal
Waste Incineration
Other
Incineration
C
a
r
c
a
s
s
Incineration
Averaging Period
30 min.
Daily
Volatile organic compounds 20 mg/m3 10 mg/m3
(excluding particulate matter)
expressed as total organic
carbon
Hourly
Hourly
-
20mg/m3
Total particulate matter
30 mg/m3 10 mg/m3
100 mg/m3
30 mg/m3
Hydrogen chloride
60 mg/m3 10 mg/m3
30 mg/m3
30 mg/m3
Hydrogen fluoride
4 mg/m3
-
2 mg/m3
200 mg/m3 50 mg/m3
300 mg/m3
300 mg/m3
0.1 ng/m3
0.1 ng/m3
0.1 ng/m3
Sulphur dioxide
Dioxins*
(
6-8 hours
samples)
-
1 mg/m3
Note: Achievement of ELV concentration by the introduction of dilution air is not
permitted
For the following metals and their compounds, including the gaseous and vapour
forms of the metal, expressed as the metal, the following limits apply to all
Incineration Processes (sampling period between 0.5 and 8 hours)
mg/m3
Cadmium, thallium taken together
Mercury
Antimony, arsenic, chromium, cobalt, copper,
lead, manganese, nickel, tin and vanadium,
taken together
*
0.05
0.05
0.5
Toxic Equivalent (TEQ) - see Appendix 2.
Page 110 of 132
Dioxins
The emission of polychlorinated dibenzo-p-dioxins (PCDDs) and
polychlorinated dibenzofurans (PCDFs) should be reduced as far as
possible. The aim should be to achieve a guide TEQ value of 0.1 ng/
m3 .
For hazardous waste incineration, subject to the EC establishing
harmonised measurement methods by the 01/07/96, this guide value
becomes an emission limit value from the 01/01/97.
Odours
Emissions from the process should not give rise to any nuisance
odour detectable outside the boundary where the process is carried
on.
Smoke
For all plant, emissions during normal operation, including start-up
and shut-down and within 5 minutes of start-up from cold, should be
free from visible smoke.
5.3.2 Waste Derived Fuel Processes
For all new plant the following concentration limits apply to
releases from contained sources:
Total particulate matter
50 mg/m3
For the following metals and their compounds, including the
gaseous and vapour forms of the metal, expressed as the metal, the
following limits apply:
mg/m3
Odour
Arsenic, chromium, copper, lead, manganese,
nickel and tin, taken together
1.0
Cadmium
0.1
Mercury
0.1
Emissions from the process should not give rise to any nuisance odour
detectable outside the boundary where the process is carried on.
Page 111 of 132
5.4 Releases to Water
Effluent load should be minimised by recovery of materials wherever
practicable. The use of lower quality water may be possible for some parts of
the process rather than fresh water.
Excluding uncontaminated stormwaters, all releases to waters are subject to a
licence from the Agency. However, any discharge to sewer, will also require the
consent of the local authority or sewerage undertaker. BATNEEC to minimise
the release of substances will generally include minimisation at source and
either specific treatment of contaminated waste streams to remove particular
substances or co-treatment of the mixed effluent or both.
Page 112 of 132
Tables 5.2 and 5.3 contain the identified emission limit values.
Table 5.2 - Emission Limit Values for all Sectors*
Constituent Group
or Parameter
pH
BOD (mg/1)
Limit Value
Notes
6-9
25
2
2
Number of Toxicity Units
5
**
Total Nitrogen (as N)
>80% removal or 15 mg/l
Total Phosphorus (as P)**
>80% removal or 2 mg/l
Total Ammonia (mg/1 as N)
10
Oils, Fats & Grease (mg/1)
10
Phenols (mg/l)
1.0
Cyanide (mg/l as CN)
0.2
Mercury (mg/1)
0.05
Tin (mg/l)
2.0
***
Lead (mg/l)
0.5
Chromium (mg/l as Cr VI)
0.1
***
Chromium (mg/l as total Cr)
0.5
Cadmium (mg/l)
0.05
Zinc (mg/l)***
0.5
***
Copper (mg/l)
0.5
Fish Tainting
No Tainting
Mineral Oil (mg/l) Interceptors
20.0
MineralOil (mg/l)Biological Treatment
1.0
*
1
2 ,3
2,3
2
2
2
2
2
2
2
2
2
2
2
2
2
2
All values refer to daily averages, except where otherwise stated to the
contrary, and except for pH which refers to continuous values. Limits
apply to effluent prior to dilution by uncontaminated streams, e.g.
stormwater, cooling water, etc.
** Only applicable to waters subject to eutrophication. One or both limits
may apply
depending on the sensitivity of the receiving waters.
*** Where the sum of the loads of these metals is <200 g/day prior to
treatment, the respective emission limit value may be increased by a
factor of four - in justified cases.
Page 113 of 132
Table 5.3 - Additional Emmision Limit Values for Incineration Processes
Substance
Spot
Sample
Organic solvents other than
alcohols mg/l
-
Organohalogens (as Cl) mg/l
-
Monthly*
Sample
Notes
0.1
(monthly
mean)
0.1
(monthly
mean)
2
2
Dieldrin ng/l
100
50
2
Gamma-hexachlorocyclohexane ng/l
100
100
2
Polychlorinated biphenyls ng/l
100
50
2
Trifuralin ng/l
50
50
2
Hexachlorobenzene ng/l
400
300
2
Hexachlorobutadiene ng/l
50
50
2
Trichlorobenzene ng/l
50
50
2
Dichlorvos ng/l
50
50
2
Fenitrothion ng/l
100
50
2
Simazine ng/l
400
300
2
Atrazine ng/l
400
300
2
Pentachlorophenol and its
compounds ng/l
500
300
2
Tributyltin compounds ng/l
200
100
2
Triphenyltin compounds ng/l
200
100
2
* Flow weighted automatic seven day sample
Page 114 of 132
Notes for Tables 5.2 and 5.3:
1.
Toxicity unit (TU) = 100/x hour E(L)C 50 in percentage vol/vol, where x
is defined by the test procedure. The toxicity of the process effluent to at
least two appropriate aquatic species shall be determined.
2.
Consent conditions for these parameters for discharge to municipal
treatment plants can be established with the Licensing Authority, and
different values may apply.
3. Removal means reduction in relation to influent load. Total Nitrogen means
the sum of Kjeldahl Nitrogen, Nitrate N and Nitrite N.
Page 115 of 132
Extract from EPA Batneec Guidance Note For The Production of
Cement
4. CONTROL TECHNOLOGIES
4.1
Introduction
As explained in Section 2, this Guidance Note identifies BATNEEC but obviously
does so in the absence of site-specific information. Accordingly, it represents the
requirements expected of any new activity covered by the Note, but does not
exclude additional requirements which may form part of the granting of a licence
for a specific site.
The approach to be used in selecting BATNEEC is based on the following
hierarchy:

Process design / redesign changes to eliminate emissions and wastes that
might pose environmental problems. (This includes fuel efficiency).

Substitution of fuels etc. by environmentally less harmful ones.

Demonstration of waste minimisation and reduction by means of process
control, inventory control and end-of-pipe technologies etc.
The existing or possible measures for reducing and controlling emissions are
described in this section. These range from relatively simple containment
measures to sophisticated recovery and end-of-pipe technologies and include:
(i)
(ii)
(iii)
(iv)
(v)
Load minimisation
Containment
Recovery/Recycle
Emission reduction
Waste treatment and disposal.
The technical feasibility of the measures listed below has been demonstrated by
various sources. Used singly, or in combination, the measures represent
BATNEEC solutions when implemented in the appropriate circumstances. These
circumstances depend on plant scale, fuels used, nature of abatement technology
etc. A summary of the treatments for various emissions is given at the end of this
section.
Note that where flammable/explosive vapours or dusts are handled, safety
procedures (acceptable to HSA) should be adopted and nothing in this note should
be construed as advice to the contrary.
4.2 Technologies for load minimisation:
Page 116 of 132
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).







Control of peak flame temperatures in the kiln (for NOx and CO minimisation).
Selection of raw materials and fuels (to minimise production of H2S, mercaptans,
odours, metals, halogens, sulphur etc.).
Prevention of rain ingress, wind entrainment for stored materials.
Inventory control.
Optimisation of water usage.
Separation of cooling water, storm water, bund and effluents of different origin in
order to permit appropriate treatment options.
Dry equipment cleaning and dry vacuum systems, where feasible.
4.3 Containment of emissions:
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).














Except for storage of coarse raw materials, storage, handling and transfer should
be enclosed.
Bunding of materials, tanks etc.
Totally enclosed belt conveyors to be used for dusty materials, vented to suitable
arrestment plant.
Conveyors should be fitted with wind boards or equivalent protection.
Overground pipelines and transfer lines.
Good housekeeping practise.
Conveyor transfer points should be reduced to the minimum number practicable
and should be designed for minimum free fall, fully enclosed and vented to
suitable arrestment plants.
Conveyors fitted with effective means for keeping the return belt clean, and for
collection of material removed by this cleaning operation.
Clinker cooler-to-store conveyors totally enclosed, and extracted.
Covered storage for dusty material stockpiles (to contain fugitive emissions).
Dust from bulk and bag filling of product to be contained by use of local
extraction systems. (Wet suppression to be considered as an alternative where
dry extraction is not practicable).
Fugitive emissions for stockpile and yard areas to be minimised by means of wet
suppression techniques.
Clinker storage indoors.
Overfilling protection on bulk storage tanks.
Page 117 of 132
4.4 Technologies for recovery and recycle:
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).

Fines collected in dust abatement systems should where practicable be recycled in
enclosed systems to the process.
4.5 Technologies for treating air emissions:
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
(Symbols refer to Table 4.1).






Electrostatic precipitators (T1).
Fabric filters (> 99.5% removals) (T2).
Gravel bed filters (T3).
Cyclones (for precleaning) (T4).
Wet suppression (T5).
Ceramic filters (T6).
4.6 Technologies for treating water emissions:
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).
(Symbols refer to Table 4.2).




pH Correction / neutralisation (F1).
Coagulation / flocculation / precipitation (F2).
Sedimentation / filtration / flotation (F3).
Oil/water separation system (F4).
4.7 Specific technologies for the treatment and disposal of wastes:
(No priority ranking is intended, and the appropriate selection in a particular case
will depend on the specifics of the process concerned and on site constraints).



Sludge dewatering.
Engineered landfill of wastes.
Outlets should be sought for the reuse of wastes arising from plant cleaning,
baghouses etc.
Page 118 of 132
Table 4.1 Summary of Technologies for Treating Air Emissions
(Symbols refer to section 4.5)
Emission Type
Particulates
Technology
T1, T2, T3, T4, T5, T6
Other emissions (e.g. sulphur, halogens, Controlled under load minimisation
odours etc.)
Table 4.2 Summary of Technologies for Treating Water Emissions
(Symbols refer to section 4.6)
Emission Type
Particulates
Metals
Oils etc.
Technology
F2, F3
F1, F2, F3
F4
5. Emission Limit Values
5.1 Reference Conditions
The reference conditions for concentrations of substances in emissions to air from
contained sources are:
For non-combustion gases:
Temperature 273 K; Pressure 101.3 kPa; no correction for water vapour content.
For combustion gases:
Temperature 273 K; Pressure 101.3 kPa; dry gas.
Oxygen content 10%.
These units and reference conditions may not be suitable for continuous monitoring
methods and may, by agreement with the Agency, be converted, for day-to-day
control purposes, into values more suitable for the available instrumentation.
Page 119 of 132
All period averages should cover operating hours only, but excluding start-up and
shutdown. In the case of dust emissions, Trip-outs of the ESPs for safety reasons
are also excluded from period averages.
5.2 Interpretation of Compliance
5.2.1 Air Emissions
95 % of the daily means of continuous monitoring during steady plant operation (
excluding start-up and shut-down and, in the case of dust, safety trip-outs) shall
comply with the limit value over a calendar year. 100% of the half hourly means,
similarly obtained shall be less than twice the limit value.
monitoring, all results shall be below 1.5 times the limit value.
For periodic
5.2.2 Emissions to Waters
The limit values for discharges to water are based on 24 hour flow proportioned
composite samples taken over a representative production period.
5.3 Releases to Air
Table 5.1 Emission Limit Values for Air
Emission
Dust
Source
Kiln/milling/drying
>500,000 t/a clinker capacity
of plant
<500,000 t/a clinker capacity
of plant
Clinker cooling
Clinker grinding
Other sources
Concentration
Limit (mg/Nm3)
Note 1
Mass Emission
Limit (kg/t
kiln dry feed.)
50
0.15
100
-
100
0.05
75
50
-
SO2
Kiln
400-750*
-
NOx
Kiln
1300-1800
-
Note 1: Achievement of ELV concentration by the introduction of dilution air is not permitted.
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* The SO2 emission is dependent upon the sulphur content of the fuel and raw material.
5.4
Releases to water
Effluent should be minimised by recycling and re-use wherever practicable. The
use of lower quality water may be possible for some parts of the process rather
than fresh water.
All releases to waters are subject to a licence from the Agency. However, any
discharge to a sewer, will require the consent of the sanitary authority. BATNEEC
to minimise the release of substances will generally include minimisation at source
and either specific treatment of contaminated waste streams to remove particular
substances or co-treatment of combined effluent streams or both. The Emission
Limit Values for effluent discharges to waters are set out in Table 5.2.
Table 5. 2 - Emission Limit Values for Discharges to Water*
Constituent Group
or Parameter
Limit Value
Notes
6-9
2
BOD (mg/l)
25
2
Suspended Solids (mg/l)
35
2
Number of Toxicity Units
1
1,2
Mineral Oil (Interceptors) (mg/l)
20
2
pH
*
All values refer to daily averages, except where otherwise stated to the contrary,
and except for pH which refers to continuous values. Limits apply to effluent
prior to dilution by uncontaminated streams, e.g. stormwater, cooling water, etc.
Metals will be a matter for licensing.
Notes for Table 5.2
1.
Toxicity Unit (TU) = 100/x hour E(L)C 50 in percentage vol/vol, where x is
defined by the test procedure. The toxicity of the process effluent to at least two
appropriate aquatic species shall be determined. Higher TU values reflect greater
levels of toxicity.
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2.
Consent conditions for these parameters for discharge to municipal treatment
plants can be established with the Licensing Authority, and different values may
apply.
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Extract from EPA Batneec Guidance Note For The Poultry
Production Sector
4 CONTROL TECHNOLOGIES
4.1 Introduction
As explained in Section 2, this Guidance Note identifies BATNEEC, but obviously
does so in the absence of site-specific information. Accordingly, it represents the
requirements expected of any new activity covered by the Note, but does not exclude
additional requirements which may form part of the granting of a licence for a specific
site.
The approach to be used in selecting BATNEEC is based on the following hierarchy:
 Process design/redesign and selection changes to minimise the production of
manure, wash-water, carcasses and packaging waste that might pose
environmental problems.
 Process design/redesign and selection changes to minimise emissions that
might pose environmental problems.
 Substitution of feed, materials, machinery etc., by environmentally less
harmful ones.
 Demonstration of waste minimisation by means of production process
control, inventory control and recycling technologies etc.
The existing, or possible measures for reduction and control of emissions are
described in this section. These range from relatively simple siting and containment
measures to recovery/recycling and manure treatment technologies and include:
1. Siting poultry units.
2. Load minimisation.
3. Containment.
4. Manure spreading.
5. Recovery/recycling.
6. Treatment of manure.
The technical feasibility of the measures listed below has been demonstrated by
various sources. Used singly or in combination, these measures represent BATNEEC
solutions when implemented in the appropriate circumstances. The circumstances
depend on farm scale, feed and materials used, type of poultry housing, number and
type of different birds/eggs produced, degree of integration of the plant, etc.
Poultry manure and wash water should be spread parallel to ground contours taking
account of safety requirements. Note that where hazardous (including asphyxiant)
dusts or vapours occur, safety procedures (acceptable to Health & Safety Authority)
should be adopted. In these, and any other matters concerning safety, appropriate safe
working practices should be adopted and nothing in this note should be construed as
advice to the contrary.
4.2 Poultry housing and manure
There are three main types of poultry housing:
1. Litter based housing.
2. Non-litter based housing with air drying of the manure.
3. Non-litter based housing without air drying of the manure.
Litter based housing is commonly used in pullet, broiler and turkey houses. It is also
used in aviary laying houses. Suitable bedding, comprising of wood shavings,
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chopped straw, shredded paper or moss peat is used to cover the floor. The manure
produced combined with the litter can have a dry matter content of c. 70%,
particularly when good insulation and ventilation are provided and water spillages are
minimised.
4.2.1 Non-litter based housing with air drying of the manure
Non-litter based housing is commonly used in laying hen houses. The birds are
housed in cages and the manure is dried to c. 55% dry matter content by two main
methods:
1. The manure drops through the floor of the cages onto ‘manure drying
conveyor belts’ beneath the cages. Dry air is blown over the surface of this
manure on the ‘manure drying conveyor belt’ thus drying the manure.
2. The manure drops through the floor of the cages into a ‘deep pit’ concrete
structure beneath the house where the ventilation air dries the manure.
Preliminary drying may occur on cleaning plates fixed underneath the cages
before the manure is scrapped off the plates into the ‘deep pit’ below.
4.2.2 Non-litter based housing without air drying of the manure
Non-litter based housing without air drying should normally be used only in the
housing of ducks. The birds are housed on a wire mesh floor, with the manure stored
in a concrete structure underneath. Water is added to the manure and mechanical
agitation of the manure/water slurry takes place prior to spreading.
4.2.3 Poultry manure
The characteristics of poultry manure are a function of:
 water:feed ratio
 feed quantity
 feed quality
 amount of bedding used, if any
Account should be taken of these variables when estimating the quantity and
associated characteristics of the manure from a specific unit; account may also have to
be taken, where appropriate of additions to the manure in storage from extraneous
water including wash-water and contaminated surface water.
The approximate characteristics of manure produced by the four main types of poultry
are given in Table 2.
Table 2: Approximate characteristics of poultry excreta
Type of Poultry
place
1
Approx.
Bodyweight
(kg)
Excreta
(l/week)
% Dry
Matter of
Excreta
Nitrogen
(kg/place/
annum)
Phosphorus
(kg/place/
annum)
Laying Hen
2.0
1.1
25
0.84
0.2
Broiler
2.0
0.2
601
0.34
0.08
Turkey
7.0
2.0
23
1.29
0.53
Ducks (Duckling)
2.0
1.4
12
1.00
0.27
Note: This amount includes bedding.
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4.3 Siting poultry units
BATNEEC for the siting of poultry units is based on the following hierarchy:
 A mass balance of nutrients within a control area.
 Protection of both surface and groundwater resources in the vicinity of the
site and landspreading areas.
 Avoidance of nuisance due to malodours for dwellings in the vicinity of the
site.
 Protection of the environment in the event of the de-stocking of the unit due
to an emergency, e.g. an outbreak of a Class A disease as identified in
accordance with the current list of scheduled and notifiable diseases
compiled by the Department of Agriculture, Food and Forestry under the
provisions of the ‘Diseases of Animals Act’, 1966.
The management of poultry manure should be based on a mass balance of nutrients
within a control area, whether the area be a farm, group of farms or a region. Thus,
poultry units should preferably be sited in close proximity to either mushroom
compost production areas or suitable landspreading areas such as land used for tillage
crop production in which they can operate as ‘back to back’ enterprises to:
 Facilitate the utilisation of manure for mushroom compost or crop
production.
 Avoid a surplus of manure prevailing within a region.
 Reduce manure transportation costs.
In order to protect both surface and groundwater resources in the vicinity of the site
and landspreading areas a site investigation is essential and it is generally advisable
that it be carried out by a qualified hydrogeologist. The site investigation should
provide information on:
 Depth to water table (if shallow).
 Depth to bedrock (if shallow) and details of bedrock outcrops.
 Subsoil and bedrock type and quantitative assessment of permeability.
 Presence or absence of karst features - caves, swallow holes etc. - if bedrock
is limestone.
 Aquifer classification and groundwater vulnerability in accordance with the
provisions of ‘Groundwater protection schemes in Ireland: A proposed
approach’, (Daly, 1995).
 Private wells within 200 metres and all public wells within 1 kilometre of
site and 300 metres of the landspreading areas.
 Direction of groundwater flow.
 Baseline information on surface and groundwater quality.
 Location of all watercourses adjacent to the site and landspreading areas.
In addition the investigation should include information on soil types and nutrient
status.
Poultry units should be sited a distance of preferably not less than 400 metres from
the nearest neighbouring dwelling and all operations on site shall be carried out in a
manner such that air emissions and/or odours do not result in significant impairment
of or significant interference with amenities or the environment beyond the site
boundary.
Poultry units should be sited such that in the event of an outbreak of disease requiring
de-stocking there is an appropriate site available for the construction of a lined carcass
disposal site for the disposal of all carcasses. The carcass disposal site shall be
appropriately constructed in order to avoid any detrimental impacts on both surface
and groundwater quality in accordance with the provisions contained in ‘Class A
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disease outbreak - a multi-disciplinary approach’, (Duggan, O’Laoide and Finn,
1995.)
4.4 Load minimisation
All feedingstuffs in the poultry production sector shall comply with the provisions of
current national legislation thereon.
Load minimisation for the poultry production sector is based on the following
hierarchy although the appropriate selection in a particular case will depend on the
specific circumstances which apply to the individual site.
Minimisation of poultry manure and reduction of mineral excretion by:
1. Feeding to requirements.
2. Maintaining feeding systems in a good working condition so that feed
wastage and spoilage are kept to a minimum.
3. Increasing the digestibility of the phosphorus in feed.
4. Using low phosphorus feed, where appropriate.
5. Maintaining all drinkers in a good working condition such that leaks are
prevented. If suitable for the type of birds, nipple and drip cups (or similar
system) are preferable to hanging bowl drinkers, as they minimise water
spillage.
6. Separate collection of all uncontaminated surface water run-off from roofs
and clean paved areas within the proposed development and its direct
disposal to field drains or soakpits according to S129: ‘Minimum
specification for farmyard drainage, concrete yards and roads.’, (DAFF,
1993).
Minimisation of odour emissions by:
 Adequate cleaning of poultry houses between batches.
 Using adequate bedding in litter based poultry housing.
 Provision of adequate manure storage capacity.
 Stocking poultry units at design level.
 Designing ventilation system to facilitate efficient operation including
maintenance.
 Filling and emptying liquid manure storage tanks from below the surface of
the stored manure, where feasible.
 Minimising the agitation of manure.
Minimisation of carcass waste by reducing mortality rates on the unit.
Minimisation of wash-water by:
 Construction and maintenance of poultry houses to allow efficient cleaning.
 Use of dry cleaning and dry vacuum systems where feasible.
 Use of automatic cut-off trigger operated high pressure hoses for washing.
4.5 Containment of emissions
Containment of emissions for the poultry production sector is based on the following
hierarchy although the appropriate selection in a particular case will depend on the
specific circumstances which apply to the individual site.
Poultry manure should be managed in order to achieve approximate dry matter
contents as detailed in 0.
Poultry manure from litter based housing should be stored:
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In a manure pit structure constructed according to S108: ‘Minimum
specification for manure pit’, (DAFF, 1987) and sited where the risk of both
water pollution and spread of disease to other poultry houses is minimal. The
manure pit should be provided with a roof and walls as necessary to protect
the poultry manure from the elements.
 Discrete quantities of manure may be stored for up to two weeks, on suitable
landspreading areas as detailed in Section 0, prior to landspreading. Only the
quantity required for spreading in a particular field should be stored in that
field. Such short storage of manure, where practised should be in accordance
with ‘Control of farmyard pollution: Guidelines and recommendations’,
(DAFF, 1996).
Litter-free air dried poultry manure should be stored in either:
 A reinforced concrete structure constructed according to S123: ‘Minimum
specification: Slatted livestock units; Reinforced concrete tanks’, (DAFF,
1994) placed below the poultry house but with access for emptying and
provision for adequate ventilating airflow to dry the manure in the ‘deep pit’.
 In a manure pit structure constructed according to S108, (DAFF, 1987) and
sited where the risk of both water pollution and infection of other poultry
houses is minimal. The manure pit should be provided with a roof and walls
as necessary to protect the air dried poultry manure from the elements
Litter-free poultry manure without air drying should be stored:
 In underground, partly underground or overground concrete structures
constructed according to S123: ‘Minimum specification: Slatted livestock
units; Reinforced concrete tanks’, (DAFF, 1994).
 In an overground steel structure constructed on an impermeable concrete
base. Steel structures must be certified by the manufacturer as being watertight and they must be guaranteed for a 10 year period. The design
specification and subsequent construction for the concrete base must be
certified by a chartered engineer.
 Overground manure storage structures shall be provided with two valves in
line and an external safety ladder and railed platform to facilitate inspection.
The following applies to all poultry manure and wash-water storage structures
whether or not on the site of the unit:
 A minimum of six months storage capacity dedicated to the unit is required.
 All construction work should be certified by a chartered engineer as having
been constructed according to either S108 or S123 as appropriate, (DAFF,
1987 and 1994).
 Where the poultry manure storage structures are constructed to another
design specification, then both the design specification and the subsequent
construction work should be certified by a chartered engineer as being
suitable for the task and comparable to the Department of Agriculture, Food
and Forestry specifications.
 All storage tanks should be inspected by a chartered engineer and certified as
structurally sound for the purpose they were intended subsequent to
construction and at appropriate intervals thereafter.
 Leak detection facilities based on inspection chambers and perimeter wall
and under floor drains should be provided as appropriate.
Spreading or applying manure to landspreading areas should be carried out according
to Section 0.
Transport of poultry manure should be in suitably contained, leakproof vehicles.

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The septic tank drainage system should be constructed in accordance with SR6
‘Septic tank systems: Recommendations for domestic effluent treatment and disposal
from a single domestic dwelling’, (NSAI, 1991).
Oil storage tanks on site should be placed on impervious bases and shall be located
within oil tight bunds, capable of holding 110% of the volume of the largest tank
within the bund. The fill and draw pipes shall be enclosed within the bund.
Odour emissions should be contained by:
 Reducing uncontrolled air movement.
 Filling and emptying liquid manure storage tanks from below the surface of
the stored manure, where feasible.
 Transporting manure in suitably contained, leakproof vehicles.
 Minimising the agitation of manure.
 Minimising the generation of odours during meteorological conditions which
favour the spread of odours.
 Landscaping poultry houses using shelter-belts.
Carcasses should be stored on site in covered containers and transported to a
rendering facility in covered, leakproof containers as soon as practical and at least
once per week.
Wash-water from poultry houses should be stored:
 In underground, partly underground or overground concrete structures
constructed according to S123: ‘Minimum specification: Slatted livestock
units; Reinforced concrete tanks’, (DAFF, 1994).
 In an overground steel structure constructed on an impermeable concrete
base. Steel structures must be certified by the manufacturer as being leakproof and they must be guaranteed for a 10 year period. The design
specification and subsequent construction for the concrete base must be
certified by a chartered engineer.
 Overground manure storage structures shall be provided with two valves in
line and an external safety ladder and railed platform to facilitate inspection.
Packaging waste, contaminated drums, equipment and protective clothing should be
collected and stored in suitably sealed leakproof containers, where practicable.
4.6 Spreading poultry manure
The owner of the poultry unit where the manure and wash-water is produced shall be
responsible for its management.
BATNEEC for spreading poultry manure is based on the following preferred
hierarchy:
 Suitable landspreading areas.
 Buffer-zones required.
 Time of application.
 Manner of application.
 Spreading rate.
Units where landspreading areas are obtained by agreement with other landowners,
should have a reserve landspreading area available to them of at least 50% of the
landspreading area obtained by agreement. (e.g.: Where a poultry farmer owns 80ha
and requires 100ha of landspreading areas, then he/she should obtain 30ha by
agreement.)
Poultry manure and wash-water should be landspread or applied to the following
landspreading areas based on the following hierarchy:
 Tillage crop production.
 Conserved grassland.
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
Grazed grassland.
Poultry manure and wash-water should be spread parallel to ground contours.
Poultry manure and wash-water should not be landspread or applied to the following
landspreading areas:
 On land where the existing phosphorus (P) content is above 15 mg/l soil or
such figure as may be determined by the Agency; soil phosphorus levels to
be determined by Morgan’s P-Test in accordance with ‘A modified single
solution method for the determination of phosphate in natural waters’,
(Murphy and Riley, 1962) and (Peach and English, 1944).
 On waterlogged land.
 On frozen or snow covered land.
 On exposed bedrock.
 Fields that are pipe or mole drained and the soil is cracked down to the drains
or backfill.
 Fields that have been pipe or mole drained in the last 12 months.
 Fields that have been subsoiled over a pipe or mole drainage system in the
last 12 months.
 Within 15 metres of exposed cavernous (karstified) limestone or karst
limestone features such as swallow holes and collapse features.
 Where permeable bedrock is overlain by shallow (i.e. less than 1 metre from
the surface) free draining subsoils, such as sands, gravels and sandy tills.
Where the bedrock is highly permeable limestone or dolomite (these are
usually classed as regionally important or major aquifers) a greater depth of
subsoil (i.e. 2 metres) is desirable.
 Where the water table is within 1 metre of the surface in free draining areas,
at the time of application.
 Where surface gradients are excessive; gradients should preferably be less
than 20%.
Poultry manure and wash-water should be landspread or applied to land observing the
following ‘buffer zones’:
Table 3: Buffer zones for landspreading poultry manure.
Area
Buffer zone (m)
Sensitive buildings (hospitals, schools and churches)
200
Dwelling houses
100
Lakes and main river channels1
20
Small watercourses1
10
Public roads1
10
Domestic wells
50
1
Public water supplies1,2
50 to 300
1
Note: The above distances to be increased if the gradient is greater than 6%.
2
Note: The appropriate distance depends on vulnerability and groundwater flow direction.
Page 129 of 132
Unless good management practice otherwise dictates, the factors listed below must be
taken into account and poultry manure and wash-water generally should not be
landspread or applied to landspreading areas at the following times, to take account of
nutrient uptake, slurry runoff and the generation of odour nuisance:
 During the period November to February inclusive.
(However in certain locations in particular years it may not be appropriate to
adhere rigidly to these dates; depending on the weather Spring landspreading
operations may well commence before the end of February but may also
have to be deferred to a later date.)
 Manure should not be spread late in the year on land which will be barren
over the winter.
 Manure should be spread earlier rather than later in the growing season.
 When heavy rain is forecast within 48 hours.
 Manure should only be spread during daylight hours.
 When the wind direction is towards population centres or neighbours houses.
 When the risk of causing odour nuisance to the public is greatest e.g.
Sundays or public holidays.
 Meteorological conditions which give rise to odour nuisance.
Poultry manure and wash-water should be landspread or applied in the following
manner:
 Manure/wash-water should be spread by an appropriate band-spreader,
shallow injector or muck-spreader (for poultry litter only).
The rate of landspreading or application of poultry manure or wash-water should take
account of:
 The nutrient content of the manure.
 The nutrient requirements of the crop.
 The nutrient status of the soil.
 Other organic manures and chemical fertilisers being spread.
The rate of landspreading or application of poultry manure or wash-water should be in
accordance with the provisions contained in either of the following sources:
 ‘Rural Environment Protection Scheme, Farm Development Service: Agrienvironmental specifications’, (Current edition of DAFF Guidelines).
or,
 ‘Soil analysis and fertiliser, lime, animal manure and trace element
recommendations’, (Current edition of Teagasc Guidelines).
Regardless of the dilution factor, the maximum hydraulic loading per single
application should not exceed 25m3 per hectare on shallow limestone soils and in no
case should exceed 50m3 per hectare.
4.7 Technologies for recovery and recycling
Load minimisation for the poultry production sector is based on the following
hierarchy although the appropriate selection in a particular case will depend on the
specifics.
A Nutrient Management Plan (NMP) should be established to optimise the re-use and
recycling of available nutrients in the poultry manure - in particular nitrogen,
phosphorus and potassium - and should also take account of the hydraulic load. (See
also section 5.4).
Carcasses should be stored on site in covered containers and transported to a
rendering facility in covered, leakproof containers as soon as practical and at least
once per week.
The Nutrient Management Plan should incorporate the quantity of wash-water.
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Waste packaging materials should be recovered and recycled, where practicable.
4.8 Treatment of manure
Considerable research has been carried out in recent years in manure treatment. The
objectives of manure treatment may include:
 Reduction of odour.
 Production of biogas.
 Improvement in ease of handling.
 Reduction of pathogens.
Treatment of manure may include the following:
 Mechanical separation.
 Aeration.
 Composting.
 Anaerobic digestion.
 Drying.
 Pelletising.
 Incineration.
There are several large scale plants in Europe providing centralised manure treatment.
To date, such facilities are rarely provided on individual farms. However, it may in
certain circumstances be appropriate to provide treatment facilities on an individual
farm. The type of treatment required and the technology employed will depend on the
specific circumstances applying to the individual site.
4.9 Technologies for the treatment and disposal of wastes
In the event of the unit being de-stocked, due to an emergency, e.g. an outbreak of a
Class A disease as identified in accordance with the current list of scheduled and
notifiable diseases compiled by the Department of Agriculture, Food and Forestry
under the provisions of the ‘Diseases of animals act’, 1966 - the Department of
Agriculture’s Veterinary Inspectors should be contacted immediately.
Packaging waste, contaminated drums, equipment and protective clothing which are
not reused or recycled, should be disposed of at an authorised facility.
5 COMPLIANCE MONITORING
The methods proposed for monitoring the emissions from this sector are set out
below.
5.1 Air emissions
Periodic monitoring of air quality with regard to odour nuisance at the boundary of
the site and spreading areas as per licence.
5.2 Surface water quality monitoring scheme
Periodic water quality monitoring of relevant parameters as per licence. Periodic
water quality monitoring of relevant parameters as per licence.
5.3 Groundwater quality monitoring scheme
Establish the baseline conditions of groundwater quality in the neighbourhood of the
site and all of its landspreading areas prior to start-up. Periodic water quality
monitoring of relevant parameters as per licence. Where appropriate, test wells should
be provided at the site of the poultry unit and on the landspreading areas used for
spreading manure.
5.4 Nutrient Management Plan
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A Nutrient Management Plan (NMP) should be maintained on site for the
management of poultry manure and wash-water arising at the unit and should include:
 Calculation of the quantity of manure and the amount of nutrients available
from manure including any manure or other wastes imported.
 The results of soil fertility and drainage tests on existing or proposed
landspreading areas.
 A representative soil sample, to a depth of 10 cm, should normally be taken
biennially from every 2 to 4 hectares and at least one per farm. However,
where soil types are similar and cropping and treatment of the lands were the
same during the previous 5 years or more, a composite sample from an area
up to 12 hectares is acceptable.
 An assessment of the relationships between manure application rates,
cropping routine, crop nutrient requirements and existing soil nutrient status
on all landspreading areas.
 Ordinance Survey Maps to a scale of 1:10,560 showing the location of the
said landspreading areas and all environmentally sensitive features on the
lands or in their vicinity; including interalia dwellings houses and sensitive
buildings, drains, streams, watercourses and other sources of water supply.
 Agreements between ‘importers’ and ‘exporters’ of all animal manures or
other wastes are required.
The Nutrient Management Plan should be up-dated and issued to the Agency for
approval on an annual basis.
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