EU-Twinning Project IS12ENPAPEN07

Support in the Establishment and Implementation of a System

of Integrated Pollution Prevention and Control and PRTR

Wastewater regulations in Germany

Implementation, practical examples

Dipl. Ing. Walter Reinhard, Regierungspräsidium Darmstadt

walter.reinhard@rpda.hessen.de

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 1
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

Water Protection in Germany

The precautionary principle

The polluter-pays principle

The principle of cooperation

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 2
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

The precautionary
principle

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 3
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

• avoidance and limitation of pollutant emission at the

source of pollution
• away from end-of-the-pipe technology
• towards to environmentally compatible production and
process engineering measures at the point of origin
• waste water pre-treatment for special industrial waste
water take priority over later treatment in biological
wastewater treatment plants

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 4
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

Framework law defines basic regulations

- Water Management- Act -

• demands permit (discharge consent) with limits for utilization of water

(e.g. discharges into surface-water, groundwater, water-intake)

• Waste Water Ordinance - AbwV

rules for 57 industrial branches with regulations

on the field of waste water avoidance, reduction and limits
for indirect and direct effluents (waste water treatment
according to BAT)
Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 5
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

Content of permit
 Subject and scale of the permit (which kind of
wastewater etc.)
 Layout plans, description, alert plan,
 Limits (flow, concentration, load)
 Limit values for partial flow (with hazardous substances –
pre-treatment)
 Advices concerning obeying the limits (no dilution, which
kind of samples …)
 Costs of state supervision (6 times a year)
 Duty of information in case of malfunction of the plant
 Inspection of sewer system
 Self monitoring program

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 6
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

Pre-treatment is required for wastewater streams

containing contaminants for which the elimination
capacity of the central plant is not sufficient

E. g. the chemical site of Merck Darmstadt has installed:

 Pre-treatment of wastewater containing mercury

 Pre-treatment of wastewater containing nickel

 Pre-treatment of wastewater containing arsenic

 Elimination of highly volatile solvents

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 7
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

State discharge monitoring

Discharger has to pay the costs for sampling and analising

State inspectors:
 take the samples
 Check the self monitoring
 Check the operationel conditions
 Give advices to operating personal

Certified labs analyse the samples (samples get befor

delivery coded numbers)
Results will be compared with the limits of the permit!

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 8
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 9
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 10
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 11
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 12
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 13
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

System of effluent monitoring (direct discharger)

Collecting systems
(urban or industrial waste water)

Central wastewater treatment

plant (biological)

Monitoring point
(limits of permit)

river

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 14
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

System of effluent permit and monitoring (indirect/direct dischargers)

Monitoring site
Collecting system
(municipal) Industry
Industry,
installation Limit of Monitoring
permit (mg/l) site
(pre-treatment)

Biol. waste water treamtment plant

Monitoring point
Limits of permit
(mg/l , kg/d)

river

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 15
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

The polluter-pays
principle

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 16
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

Waste Water Charges Act

• Stipulates that polluters must pay contribution / charge for
discharges of waste-water into surface-water

• amount of the contribution is orientated to the amount and

characteristic of parameters

• discharger has to pay for: COD, Ptot, Ntot, AOX (clorine in org.

compounds), Hg, Cd, Cr, Ni, Pb, Cu, toxicity to fisheggs

• Waste-water charge is paid to the federal Länder

• is used for investment in municipal WWTP and sewerage systems

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 17
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

Waste Water Charges Act

parameter:
 COD
 Phosphorus (Ptot)
 Nitrogen (Ntot)
 AOX (adsorbable halogen compounds)
 Hg, Cd, Cr, Ni, Pb, Cu
 Toxicity to fisheggs (TF)
charge:
35,79 € per pollution unit

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 18
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

Pollution units
Parameter Unit threshhold value
COD 50 kg 20 mg/l and
250 kg/a
Phosphorus 3 kg 0,1 mg/l and
15 kg/a
Nitrogen 25 kg 5 mg/l and
125 kg/a
AOX 2 kg 100 g/l and
10 kg/a
Hg 20 g 100 g/a
Cd 100 g 500 g/a
Cr 500 g 2,5 kg/a
Ni 500 g 2,5 kg/a
Pb 500 g 2,5 kg/a
Cu 1000 g 5 kg/a
TF 3000 cbm/TF TF = 2

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 19
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

charge for wastewater discharging

parameter permit (consent) wastewater amount per year

COD, N, P, limit (L) (WA)
AOX, Tf (mg/l) m³/a
heavy metals

L x WA = PL
pollutant load per year

PL : unit (parameter) = AU
(AU) = amount of units

AU x fee (35 Euro) =

charge in Euro

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 20
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

Waste Water Charges Act

Example for the parameter COD:

Enterprise discharges yearly 500.000 m³ wastewater into the river (WA)

In the permit the COD is limited with : 200 mg/L (L)
(200 g/m³ = 0,2 kg/m³)

Which sum the enterprise has to pay (concerning COD) ?

500.000 m³ x 0,2 kg/m³ = 100.000 kg (PL)
100.000 kg / 50 kg (unit for COD) = 2000 pollution units (AU)

2000 x 35 € (fee) = 70.000 €

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 21
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

Waste Water Charges Act

 Reduction of the pollution unit about

50 % when the discharge limits of the permit are in
accordance with BAT and not exceeded after the state
monitoring

 When the enterprise (discharger) reduce a limitvalue of

the permit for more than 20% (e.g. from 10 mg/L to 8
mg/L) they can account the investment for the reduction
(costs for instalations) with the sum of charge
This is a appreciation for the improvement !

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 22
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

Waste Water Charges Act

 In accordance with its statute the community (town) can put a

financially supplement to the industrial plants (so called indirect
dischargers) that discharges with high concentrations of COD
(e. g. COD >1600 mg/L) into the municipal wastewater sewer
(heavily influence to the design,size and maintenance of the
municipal wastewater treatment plant)

 The comunity has to invest this contribution for the construction

and improvement of the municipal sewer system and the
wastewater treatment plant

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 23
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

European influences

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 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

IPPC Directive (1996/61/EC) concerning

integrated pollution prevention and control

 permit shall include emission limit values for e. g. heavy

metals, arsenic, organohalogen compounds, BOD,
COD (listed in Annex III)

Water Framework Directive, WFD (2000/60/EC)

 strategies against pollution of water

 to achieve good surface water status (at the latest 15

years after entry into force of the WFD)

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 25
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

WFD - The combined approach (Art. 10)

 Combined emission and quality objective of surface water
(BAT – emission limit values at the point of discharge
and / or surface water quality objective)

 The stricter condition is valid!

 Set out at the latest 12 years after date of entry of WFD

 All were adoptad into the German „Water Management

Act“

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 26
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR
Article 10 IPPC WFD Combined Approach
Best available technique and environmental quality standards

Standard treatment (BAT)+

additional measures ( like sand
filtration, activated carbon etc. …)

Water intake (drinking

water

Standard treatment (BAT),

minimum requirements

Activities 1.2, 2.4 – Water topics 12th of February 2014 27

Walter Reinhard, Michael Döpper 27
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

The principle of
cooperation

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 28
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

Cooperation !
Administration
and industry

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 29
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 30
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

Macrozoobenthos in the Rhine

200 12
1996-
2000
175
10
1900-1920 2006

oxygen concentration [mg/l]

150
number of species

8
125
1989-
100 1995 6
1986-
75 1988
4
50 1955
1978
1971 2
25

0 0
00

55

60

65

70

75

80

85

90

95

00

05
Graphik: IKSR
19

19

19

19

19

19

19

19

19

19

20

20
sponges turbellaria leeches crustaceans
molluscs insecta bryozoa oxygen conc.

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 31
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 32
 EU-Twinning Project IS12ENPAPEN07
Support in the Establishment and Implementation of a System
of Integrated Pollution Prevention and Control and PRTR

Activities 1.2, 2.4 – Water topics 12th of February 2014 Walter Reinhard, Michael Döpper 33