Process and current status
The EU BREF for “Common Waste Water and Waste Gas Treatment/Management Systems in the Chemical Sector” has a name that is as confusing as it is long.
A better name for the CWW BREF would be “Chemical Sector Waste Water Treatment (CWWT)” because it does not address air emissions and would also address stand-alone waste water treatment.
The first (IPPC) CWW BREF was finalised in February 2003 and took 3 years to write it from scratch.
Its revision started in 2008, the revised CWW BAT Conclusions were published eight years later on 9 June 2016 (see BAT Conclusions in the Official Journal of the EU, Commission Implementing Decision 2016/902 of 30 May 2016. This means that the requirements had to be complied with by the latest in June 2020. The full CWW IED BREF is available here.
The EEB thoroughly assessed the CWW BREF requirements and a spot sampling of Member States implementation in a report entitled ‘Wasted ink on Waste Water’, published in April 2021.
The CWW BREF should be reviewed in 2024, not only as per the IED requirements (8 years review cycle) but also due to the absence of dedicated at the source pollution prevention requirements in relation to PFAS pollution (see STM BREF related developments).
Main Environmental issues and discussion points on BAT / BATAE(P)Ls
The chemical industry’s waste water is a potential source of many pollutants in high quantities. It is important that these pollutants are eliminated (abated) at the source prior to their released to surface waters.
As highlighted in the dedicated publication ‘Wasted ink on Waste Water’, published in April 2021. The 2016 CWW BREF:
- Fails to address waste gas treatment (that would be addressed through the WGC BREF)
- Includes management systems, but not more so than any other recent BREF
- Provides laxist BAT-AELs on many parameters. Real pollutant concentrations are often much lower than the levels defined in the CWW BREF, resulting in little incentive for operators to optimise, improve and invest.
- Based on E-PRTR and selected permit data, we showcase examples where room for improvement is particularly impressive.
- Fails to address dedicated pollution prevention requirements on PFAS (forever pollutants).
These findings contrast with the IED’s objective to prevent or reduce emissions and the explicit aim of the BREF to serve as a driver towards improved environmental performance across the Union.
The main issues identified by the EEB / the European Commission are available in the following documents:
- Background Paper for the final meeting, summarising the main points made ( 30 October 2013)
- EEB input (10 December 2013) to Final TWG meeting on 10-13 December 2013
- EEB Split views made on various issues (17 January 2014)
- EIPPCB Split view assessment response (20 February 2014)
How can you make a difference?
The EEB would wish to kick start the review of the outdated CWW BREF , the main focus should be on the phase out of PFAS and at the source substitution of the chemical industry of chemicals of concern. The following information would thus be appreciated:
- Performance data on substitution of / PFAS abatement in waste water stage including effluent characterisation (see STM BREF)
- best performers data in relation to phase out of other Priority Hazardous Substances (at least below mid-point range below relevant BAT-AEPLs)
- sate of the art monitoring (very low detection limits) and best practice on making monitoring data publicly available
- application of the whole effluent assessment approach in permitting
- other supplementary information backing up need for fast-track review and improving ambition level of protection of human health and the environment.