EU draft update of Slaughterhouse BAT BREF

Draft update of EU BAT BREF for Slaughterhouse & Animal By-Product and Co-Product Industries is published. Public comments are invited. IED (Industrial Emissions Directive) Forum members (includes ESPP) are invited to input comments by 11^th May latest, so please send any comments to ESPP by 1^st May. The 540 document is a proposed update of the existing 2005 BAT BREF. Techniques presented as BAT (Best Available Technology) include: phosphorus recovery as struvite for resource recovery ($2.3.2.7 page 96) and wastewater treatment ($2.3.6.5.3 page 157) and in BAT12 and BAT14 (for wastewaters with P_total > 50 mg/l, $5.1.6 and $5.1.7 pages 450-451); P-removal from wastewater by chemical precipitation or enhanced biological P-removal (EBPR); dicalcium phosphate manufacture from gelatine production ($4.5.2.2 page 427); anaerobic digestion with use of digestates as N, P, K containing fertiliser ($2.1.2 page 31). It is indicated page 378 that wastewater treatment sludge can be sent to incineration then P-recovery. Total phosphorus and total nitrogen emissions to water are KEIs (Key Environmental Indicators, p.25). Use of sludge from gelatine production, feathermeal, PAP processed animal proteins or blood byproducts directly on farmland as a fertilising material are cited (pages 354, 369, 374, 433). Ammonia N-recovery from rendering condensate is cited ($4.3.4.2.2 page 397). BAT14 specifies limits (for direct discharge) of 4 – 30 mg/l for N_total and 0.25 – 2 mg/l for P_total – ESPP suggests that these limits seem non-ambitious compared to limits widely applicable to municipal wastewater treatment plants. ESPP will input comments to propose to add to BAT1 (Overall Environmental Performance) a nutrient valorisation plan, conform to the waste hierarchy (food, feed, fertiliser). ESPP will also comment that anaerobic digestion should ensure Animal By-Product Regulation 142/2011 End-Point heat/time conditions, to ensure sanitisation, and to enable use of digestates as fertiliser.

Draft “Best Available Techniques (BAT) Reference Document for the Slaughterhouses, Animal By-products and/or Edible Co-products Industries”, proposed update of existing 2005 BREF http://eippcb.jrc.ec.europa.eu/reference/ Comments to ESPP by 1^st May.