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EPA Issues Guidance on BAT Conclusions

The Environmental Protection Agency (EPA) has published Frequently Asked Questions (FAQs) for licensees affected by the implementation of the Common Waste Gas Management and Treatment Systems in the Chemical Sector (WGC) BAT Conclusions, as outlined in the Commission Implementing Decision (CID) 2022/2427. The EPA has also published FAQs for licensees affected by the implementation of the Common Wastewater and Waste Gas Treatment/Management Systems in the Chemical Sector (CWW) BAT Conclusions, as outlined in Commission Implementing Decision (CID) 2016/902.

CID 2022/2427 sets out new requirements for emission limit values and the management of volatile organic compounds (VOCs) and is relevant to Industrial Emissions (IE) licensed facilities that carry out any activity listed in Section 4 (Chemical Industry) of Annex I of the Industrial Emissions Directive (IED).

CID 2016/902 sets out new requirements for emission limit values and management of volatile organic compounds (VOCs) and is relevant to Industrial Emissions (IE) licensed facilities that carry out any activity listed in Section 4 (Chemical Industry) and Section 6.11 (Independently operated treatment of waste water) of Annex I of the Industrial Emissions Directive (IED).

The EPA is currently reviewing all relevant IE licences within the scope of each CID to ensure compliance with the relevant BAT Conclusions. As part of this process, the EPA has requested affected licensees to assess their current licences against BAT Conclusions. In many cases, this assessment will necessitate either a Technical Amendment or a full Licence Review. The FAQ documents address several queries from licensees regarding the EPA's approach to implementing the relevant BAT Conclusions. To access the WGC FAQ document, click here. To access the CWW FAQ document, click here.

Please note that where a full licence review is required, there may be additional amendments to licence conditions and emission limits beyond the scope of the BAT Conclusions.

It should also be noted that where it is determined that a licence review is required, the process will be initiated by the Agency. The licensee will not be required to remit any fee to the EPA in instances where a licence review is initiated by the Agency.

Environet Solutions has extensive experience in carrying out assessments of this nature and can provide support to licensees required to undertake these assessments.

November 2024