17 August 2018 BAT conclusions for waste treatment published following a European Union wide review of BAT implementing decision EU 2018/1147 of 10 August 2018"


2 of April 2019 EA confirmed EnglishWaSCs that their AD facilities needed to comply with IED

6 January 2011 ED entered into force

20 February 2013 IED transposed into UK law


Sewage sludge anaerobic digestion ( AD ) facilities need to comply with industrial emissions directive IED

7 January 2014 IED deadline for existing installations to obtain an environmental permit.

July 2014 EA deferred the need for WASC to submit permit applications for these facilities to allow for consideration of whether they were already covered under the UWWTR.

Therefore, the implementation of this aspect of the IED has been delayed for over five years at the point of the EA confirmation to the WASCS on 2 April 2019

April 2021 to October 2022 WASCS must provide definitive lists of all facilities used to carry out biological treatment of sewage sludge to EA
21 Sept 2022 EA published ‘ biological waste treatment: appropriate measures for permitted facilities’
25 November 2024 just a few short months ago, The EA updated their publication ‘ Biological waste treatment: appropriate measures for permitted facilities’


The IED recast the directive on integrated pollution prevention and control IPPc and introduced a revised schedule of industrial activities falling within the scope of its permitting requirements.

The schedule of waste management activities includes the recovery of non-hazardous waste with a capacity exceeding 75 tons per day involving biological treatment But excludes activities covered by the urban waste water treatment regulations UWWTR .


The IED seeks to achieve a high level of protection for the environment, taken as a whole, from the harmful effects of industrial activities.it does so by requiring each of the industrial insulation is to be operated under a permit with conditions based around the best available techniques BAT. NOTE THAT THIS IS QUOTED BY THE ENVIRONMENT AGENCYAS TECHNIQUES AND NOT TECHNOLOGY.

BAT applies to new waste sewage sludge treatment not covered by the UWWTR. The installation operations at seven Trent Mansfield sewage treatment works are existing but will be brought under environmental regulation for the first time and are required to operate and use BAT.

Given the delay in implementing the IED in England, the EA subsequently have sought to ensure that all sewage sludge AD facilities obtain and operate under an environmental permit in as short a time scale as can reasonably be achieved.

THE EA ASKED THE WASCS TO PROVIDE A DEFINITIVE LIST OF ALL FACILITIES USED TO CARRY OUT BIOLOGICAL TREATMENT OF SEWAGE SLUDGE.

A submission schedule was provided to the WASCS allowing applications for these facilities to be submitted in stages between the 1st of April 2021 and 1 October 2022.


1. when appropriate measures apply

St: Assessing the appropriate measures that will apply to a permitted facility that handlesbiowaste

This guidance applies to aerobic and anaerobic processes, including;

Composting and open air and closed in vessel systems

Aerobic processes of organic fractions by mechanical and biological treatment MVT and mechanical heat treatment MHT

Thermophilic aerobic digestion

Anaerobic digestion, including the combustion or upgrading of the resulting by gas and treating the digest date (Anaerobic treatment can include wet, dry and dry batch digestion)

Rated lagoons and activated sludge (As a waste water treatment)

Collecting and storing methane from lagoons and tanks and upgrading to buy methane

Treating sewage start using any of these biological processes

Storing feed stock compost and digest state

Receiving wastes destined for biological treatment

There is overlap between best available techniques BAT for waste installations and necessary measures for waste operations. The environment agency uses the term appropriate measures to cover both sets of requirements

This guidance set out what you must consider when you assess the appropriate measures for your facility.

It is not definitive and it does not replace your obligation to assess appropriate measures fully for your site.

Some measures may not be suitable or relevant to your operation. Appropriate measures will depend on the:

Complexity of the activities being carried out

Size and nature of the activities

Location of the site

Where an operator wants to propose an alternative measure this must achieve the same level of environmental protection.

The operator must also provide evidence of why the alternative equivalent to or better than what this guidance proposes.


In certain situations are higher standard of environmental protection may be needed. For example:

Where there are local sensitive receptors

If the facilities affecting the local environment or human health despite using appropriate measures

If there is a risk that you may breach and environmental quality standard


Other technical guidance relating to emission order and may also apply.

Best available techniques

Bat 1. Implement and adhere to an environmental management system

In order to improve the overall environmental performance VAT is to implement and adhere to an environmental management system EMS . The scope meaning the level of detail and nature of the EMS as to whether it is standardised or non-standardised for example would generally be related to the nature scale and complexity of the installation and the range of environmental impacts it may have( Determined also by the type and amount of wastes processed )the EMs must incorporate the following features

Commitment of management, including senior management

Definition by the management of environmental policy that includes the continuous improvement of the environment of the performance and installation

Planning in establishing the necessary procedures, objectives and targets in conjunction with financial planning and investment etc

Bat 2. Use all of the techniques given below:

Set up an implement waste characterisation and pre-acceptance procedures

Set up an implement waste acceptance procedures

Set up an implement a waste tracking system and inventory

Set up an implement and output quality management system

Ensure waste segregation

Ensure waste compatibility prior to mixing or blending of waste

Sort incoming solid waste

BAT 3 Establish and maintain an inventory of waste water and waste gas streams as part of the EMS. 

The inventory incorporate all of the following features

Information about the characteristics of the ways to be treated and the waste treatment processes including simplified process flow sheets that show the origin of the emissions

Descriptions of process integrated techniques and waste water waste gas treatment at source, including their performances







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