Scores of companies in the food and drink sector are due to fall under IPPC from June 2004. The new regime applies to large operations treating and processing animal and vegetable raw materials. Large dairies processing milk are also caught.
At EU level, work on a best available techniques reference (BREF) document for the sector - on which UK guidance will be based - began only in January and is likely to continue into 2003. The Agency's interim guidance is designed to help companies applying for a permit - and to help the sector as a whole prepare for the challenges of IPPC.
The food and drink sector has little experience of integrated pollution control (IPC). Recent conferences have revealed considerable uncertainty among companies about how IPPC will affect them (ENDS Report 305, pp 15-16 ), and experience in the paper sector indicates that the worries may not be unfounded (see p 8 ).
Bringing the food and drink sector under IPPC will also be a challenge for the Agency. 1,100 installations in this very diverse sector will have to be permitted.
Traditionally, the industry has not seen itself as a major polluter, but impacts can be significant. The guidance says that the key issues for the sector include water and energy consumption, solid waste, effluent and odour emissions. A recent survey found that the sector now spends more than any other on pollution control (ENDS Report 319, pp 4-5 ).
Waste minimisation and water consumption seem to be the Agency's priorities for improvements. The guidance requires most items on an improvement programme to be carried out within three years. For water and waste, both new and existing installations have one year after a permit is issued to submit audits on the potential to reduce wastage and water consumption.
For water use, the guidance requires companies to conduct mass-balance analysis across the whole installation and consider the potential to minimise consumption. Benefits include reducing the volume of effluent and conserving water resources.
However, 65% of operations are batch processes which are inherently water-intensive. Hygiene is of paramount importance with large quantities of water being used for cleaning.
The guidance sets out a large number of "best available techniques" (BAT) for water use. These include using fresh water only when necessary. Opportunities for water recycling or re-use should be evaluated.
Operators will have to consider membrane technology to enable water recycling - a practice which with one exception is not yet used in the industry. One obstacle is the industry's fears over customer perception and hygiene, concerns which the Agency says are unfounded. Membranes can also produce valuable by-products, it says.
Robert Wiseman Dairies' new works in Droitwich uses a type of membrane, reverse osmosis, to recover milk from rinse water. The recovered product is used in animal feed. The innovation was driven by its coming under IPPC (ENDS Report 316, p 9 ).
The guidance also says that the costs of membrane technology are falling and could have more ambitious applications in effluent treatment. Companies will be keen to see how strongly the future BREF document pushes membrane technology.
The Agency's document is rather light on indicative BAT requirements for specific activities in the sector. For instance, peeling is a fundamental part of many vegetable processing activities. It has a significant impact: potato peels can account for up to 80% of the biochemical oxygen demand (BOD) in effluent. Yet apart from identifying the main control issues, no further techniques are identified.
The same is true for the large number of freezing processes. The guidance simply says that energy efficiency and fugitive emissions of refrigerant are the main issues. The forthcoming BREF is likely to describe techniques to minimise impacts currently in use across the EU.
Point source emissions to surface water and sewer are other impacts of concern. The guidance says BOD in the industry's effluents can be up to 100 times stronger than domestic sewage and levels of suspended solids can often be measured at several thousand mg/l.
Companies will have to provide a description of effluent treatment techniques with their PPC permit applications, and demonstrate that they are BAT by confirming compliance with indicative requirements or justifying departures.
The guidance describes a range of established BAT for effluent treatment. It specifies emissions benchmarks for new installations of 10-20 mg/l for BOD. But again, the guidance seems to lack a comprehensive set of benchmark emissions levels pending production of the BREF.
Odour is likely to be a potential problem at most food and drink operations, the guidance says. Companies are required to submit an odour management plan with the permit application, but no further details are yet available. The Agency plans to produce specific guidance on odour control under IPPC.