RRD COMPLIES WITH THE ENVIRONMENTAL STANDARDS IN FORCE

Legislative Decree 152/06 and subsequent amendments identifies, in art. 74, paragraph 1, letter h): "industrial waste water": any type of waste water discharged from buildings or plants where commercial activities or the production of goods are carried out, other than domestic waste water and run-off rainwater. This definition would seem to subject to industrial wastewater also the wastewater of the Analysis Laboratory, which should, should respect qualitative and quantitative limits. Furthermore, art. 107 - Discharges into the sewerage network, paragraph 1, of Legislative Decree 152/06, specifies that: Without prejudice to the mandatory emission limit values ??referred to in table 3 / A of Annex 5 to the third part of this decree and, limited to parameters referred to in note 2 of Table 5 of the same Annex 5, to Table 3, the discharges of industrial waste water that enter the sewerage system are subject to the technical standards, regulatory requirements and limit values ??adopted by the Competent Authority area based on the characteristics of the plant, and in such a way that the protection of the receiving water body is ensured, as well as compliance with the regulations on discharges of urban waste water defined pursuant to article 101, paragraphs 1 and 2. Therefore, Art. 107 refers to Table 3 of Annex 5 to Part Three of the same Legislative Decree 152/06, for the discharge limits, but assigns to the Area Authority (ATO in Liguria) the definition of any technical standards, regulatory requirements and limit values. RRD systems have been designed to "regularize" these discharges throughout their treatment cycle.

The following indications are reported:

Legislative Decree 152/06 and subsequent amendments identifies, in Art. 74, paragraph 1, letter h): "industrial waste water": any type of waste water discharged from buildings or plants in which commercial activities or the production of goods are carried out, other than domestic waste water and run-off rainwater. This definition would seem to subject also the waste water of the Analysis Laboratory to industrial waste water, which, therefore, should respect specific qualitative and quantitative limits. Furthermore, Art. 107 - Discharges into sewer networks, paragraph 1, of Legislative Decree 152/06, specifies that: Without prejudice to the mandatory emission limit values ??referred to in table 3 / A of Annex 5 to the third part of this decree and, limited to the parameters referred to in note 2 of Table 5 of the same Annex 5, to Table 3, the discharges of industrial waste water that deliver to sewer networks are subject to the technical standards, regulatory requirements and limit values ??adopted by Competent area authority based on the characteristics of the plant, and in such a way that the protection of the receiving water body is ensured, as well as compliance with the regulations on urban wastewater discharges defined pursuant to Article 101, paragraphs 1 and 2..

Therefore, Art. 107 refers to Table 3 of Annex 5 to Part Three of the same Legislative Decree 152/06, for the discharge limits, but assigns to the Area Authority (ATO in Liguria) the definition of any technical standards, regulatory requirements and limit-values. The same "opening" is also defined in Annex 5 to Part Three of Legislative Decree 152/06, where, in Art. 1.2.1, it is specified that: The discharges of industrial waste water into surface waters must comply with the emission limits indicated in the following table 3 or with the relative regulations established by the Regions. The emission limit values, which the discharges concerned must not exceed, are generally expressed in concentration. However, the Regions, in the exercise of their autonomy, in implementing the water protection plans, taking into account the maximum permissible loads and the best available techniques, define the emission limit values, other than those referred to in table 3 in maximum permissible concentration and in maximum quantity per unit of time.

So what happens at this point?Let’s take the Liguria Region as an example:

About 16 months after the publication of Legislative Decree 152/06, the Liguria Regional Law 29/07 is published, which, in Art. 1 and, above all, to Art. 3, paragraph 1, establishes: For the purposes of the discipline and the authorization system of discharges, waste water is assimilated to domestic wastewater, pursuant to article 101, paragraph 7, letter e) of Legislative Decree 152/06, industrial companies that have the qualitative and quantitative characteristics referred to in Annex A. The aforementioned letter e) of Article 101, paragraph 7, of Legislative Decree 152/06, reads: Except for the provisions of Article 112, for the purposes of discharges and authorizations, waste water is assimilated to domestic wastewater..... having qualitative characteristics equivalent to domestic ones and indicated by the Regional Regulations. Therefore, for various reasons, currently, the crucial point is represented by Sheet 1 - activities whose industrial waste water is assimilated to domestic waste water, regardless of any size threshold, which, among the various activities, identifies Services of the centers and factories for physical well-being, dental offices and dental technicians, analysis laboratories, provided that Conditions 2) and 3) of Sheet 1 are respected, namely: 2) reagents, reagents, products analyzed must be disposed of as waste pursuant to Legislative Decree 152/06, part four; 3) compliance with current legislation on medical waste (Presidential Decree 15.07.2003 no. 254 - Regulation governing the management of medical waste, art. 24 of Law no. 179 of 31 July 2002 ");

PRELIMINARY CONCLUSIONS

As stated above, Condition 2) of Form 1 of the Regional Law Liguria 29/07 requires that all reagents (regardless of size thresholds) be disposed of as waste. Therefore, as preliminary conclusions, it can be stated that, since in the analysis process, carried out in the Laboratory, reagents are used (not better specified by the Manufacturer of the Analysis Machines), it follows that, of course, the discharges must be treated as waste " Concentrates ”, which, as generally stated by the Manufacturer of the Analyzing Machines, consist of“ liquid compounds deriving from the sample and the reagent, recovered from the couvettes and the washing solution ”. As regards the "Diluted" drains, which consist of "waste liquids, deriving from the washing water used for the cuvettes, mixers, etc.", it is necessary to verify, with analytical determinations, the level of concentration, in order to evaluate its impact.