PAN-010144 - ECL.010.02.01EPTR Issue 1

APPLICATION FOR AN ENVIRONMENTAL
PERMIT UNDER THE ENVIRONMENTAL

PERMITTING (ENGLAND AND WALES)
REGULATIONS 2016 (AS AMENDED)
ENVIRONMENTAL PERMITTING TECHNICAL

REQUIREMENTS
FORWARD WASTE MANAGEMENT

EAST MOORS ROAD HAZARDOUS WASTE
TRANSFER STATION, CARDIFF
LL, HU14 3HH
ECL Ref: ECL.010.02.01/EPTR

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April 2020
TABLE OF CONTENTS
1. INTRODUCTION 1
1.1. Overview 1
1.2. Installation Location 1
1.3. The Applicant 1
2. LISTED ACTIVITIES 2
2.1. Installation Activities 2
2.2. Planning 3
3. MANAGEMENT TECHNIQUES 4
3.1. Technical Competence 4
3.2. Overview of Environmental Management System 4
3.3. Environmental Policy 4
3.4. Details of the Environmental Management System 5
4. OPERATING TECHNIQUES 9
4.1. Overview 9
4.2. Technical Standards 9
4.3. Proposed Waste Activities 9
4.4. Proposed Infrastructure and Drainage Arrangements 16
5. EMISSIONS 18
5.1. Point Source Emissions to Air – Proposed Arrangements 18
5.2. Point Source Emissions to Surface Water – Proposed Arrangements 18
5.3. Point Source Emissions to Sewer – Proposed Arrangements 18
5.4. Point Source Emissions to Land – Current Arrangements 18
5.5. Fugitive Emissions to Air 18
5.6. Fugitive Emissions to Surface Water, Sewer and Groundwater 18
6. GENERAL REQUIREMENTS 20
6.1. Emissions Management 20
6.2. Odour Management 20
6.3. Noise Management 20
6.4. Pest Management 20
6.5. Fire Management 20
7. APPLICATION SITE CONDITION REPORT 22
8. MONITORING 23
8.1. Monitoring of Emissions to Air 23
8.2. Monitoring of Groundwater 23
8.3. Monitoring of Surface Water 23
8.4. Monitoring of Foul Water 23
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TABLE OF CONTENTS (CONT.)
9. RESOURCE EFFICIENCY AND CLIMATE CHANGE 24

9.1. Energy Efficiency Measures 24
9.2. Energy Consumption 24
9.3. Climate Change Agreement 24
9.4. Raw Material Justification 25
9.5. Waste Minimisation 25
10. COMPLIANCE WITH BAT CONCLUSIONS 26

10.1. Overview 26
APPENDICES
APPENDIX I PROPOSED WASTE CODES AND STORAGE ARRANGEMENTS

APPENDIX II ENVIRONMENTAL POLICY
APPENDIX III WASTE PROCEDURES
APPENDIX IV SOLUTEX CAN COMPACTOR 206 MACHINERY SPECIFICATION
LIST OF FIGURES
Figure 1: Illustration of the Solutex Can Crusher 11
LIST OF TABLES
Table 1: Proposed Schedule 1 Activities 2

Table 2: Energy Consumption 24
Table 3: Waste Treatment BREF- General BAT Conclusions 27
Table 4: IPPC S5.06 Guidance Document - Techniques for Pollution Control: BAT Requirements 31
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ACRONYMS / TERMS USED IN THIS REPORT
AMP Accident Management Plan
ASCR Application Site Condition Report
BAT Best Available Techniques
BREF Best Available Techniques Reference Document
CCA Climate Change Agreement
CCTV Closed Circuit Television
CLP Classification, Labelling and Packaging
DGSA Dangerous Goods Safety Advisor
EA Environment Agency
ECL Environmental Compliance Limited
ELVs End of Life Vehicles
EMS Environmental Management System
EP Regulations Environmental Permitting (England and Wales) Regulations 2016
as amended
EP Environmental Permit
ERA Environmental Risk Assessment
FWM Forward Waste Management Limited
IBC Intermediate Bulk Container
IED Industrial Emissions Directive
LED Light-emitting Diode
NGR National Grid Reference
NRW Natural Resources Wales
OS Ordnance Survey
PG Packing Group
PPMR Planned Preventative Maintenance Regime
SEC Specific Energy Consumption
SHEQ Safety, Health, Environment and Quality
The Installation Forward Waste Management East Moors Road Hazardous Waste Transfer
Station
WAMITAB Waste Management Industry Training and Advisory Board
WEEE Waste Electrical and Electronic Equipment
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1. INTRODUCTION
1.1. Overview
1.1.1. Environmental Compliance Limited (“ECL”) has been commissioned by Forward Waste
Management Limited (“FWM”) to produce a bespoke Environmental Permit application
for a waste Installation, hereafter referred to as “the Installation” located at 122-128
East Moors Road, Cardiff, CF24 5EE.
1.1.2. FMW is proposing to operate Forward Waste Management East Moors Road Hazardous
Waste Transfer Station accepting approximately 22,000 tonnes of hazardous waste and
approximately 3,000 tonnes of non-hazardous waste per annum at the Installation.
1.2. Installation Location
1.2.1. The Installation is located on East Moors Road, within a large commercial and industrial
area to the south east of Cardiff City Centre and is centred on Ordinance Survey (“OS”)
National Grid Reference (“NGR”) 319473 175780. The Installation will occupy an area of
approximately 0.25ha.
1.2.2. The exact location of the Installation and the proposed Environmental Permit Boundary
(outlined in green) is indicated on the Site Location Plan (Drawing ECL.010.02.01-01),
which is contained within Section 3 of this application submission.
1.3. The Applicant
1.3.1. FMW was formed in 2006 and currently operates East Moors Waste Transfer Station
permitted under Environmental Permit EPR/ AB3099FT. FWM delivers waste
management solutions to all businesses and specifically those within the manufacturing
industry. FWM operations are founded on the application of the waste hierarchy;
preventing waste production and reusing and recycling redundant resources across the
whole spectrum of wastes from recyclables to hazardous materials.
1.3.2. FWM is proposing to operate a second waste site as detailed in this Environmental Permit
application. This will enable the business to increase their waste acceptance, treatment
and recovery capabilities in order to expand their operations in the UK waste sector.
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2. LISTED ACTIVITIES
2.1. Installation Activities
2.1.1. The proposed Schedule 1 Activities under the Environmental Permitting (England and
Wales) Regulations 2016 as amended (“EP Regulations”) is detailed in Table 1.
Table 1: Proposed Schedule 1 Activities

Activity Schedule 1 Limits of Specified
Description of Specified Activity
Reference Activity Activity
Disposal or recovery of hazardous waste with
a capacity exceeding 10 tonnes per day
involving one or more of the following From material
A1 Section 5.3
activities: entering site to final
Part A(1) (a)
iv) repackaging prior to submission to dispatch offsite.
any of the other activities listed in
this Section or in Section 5.1.
(a) Temporary Storage of hazardous
waste with a total capacity
From material
A2 Section 5.6 Part exceeding 50 tonnes pending any
entering site to final
A(1) of the activities listed in Sections
dispatch offsite.
5.1. 5.2., 5.3 and paragraph (b) of
this Section.
2.1.2. FMW also propose to undertake two Specified Waste Operations as follows:
• the storage of non- hazardous waste with treatment limited to manual or
mechanical bulking up of waste for onward transfer from site for disposal or
recycling; and
• crushing of hazardous containers via mechanical means limited to a treatment
capacity of 5 tonnes per day. The crushed containers will be sent for onward
transfer from site for recycling and/or recovery.
2.1.3. The proposed waste codes to be accepted at the Installation are provided in the
Proposed Waste Codes and Storage Arrangements Document contained in Appendix I.
2.1.4. The waste management operations to be carried out at the site as specified in Annex I
and Annex II of the Waste Framework Directive 2008 are detailed below:
• R3: Recycling/reclamation of organic substances which are not used as solvents
(including composting and other biological transformation processes;
• R4: Recycling/reclamation of metals and metal compounds;
• R5: Recycling/reclamation of other inorganic materials; and
• R12: Exchange of wastes for submission to any of the operations numbered R1
to R11 (other than R3-R5);
• R13: Storage pending any of the operations numbered R1 to R12 (excluding
temporary storage, pending collection, on the site where it is produced);
• D14: Repackaging prior to submission to any of the operations numbered D1 to
D13; and
• D15: Storage pending any of the operations numbered D1 to D14 (excluding
temporary storage pending collection on the site where it is produced).
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2.2. Planning
2.2.1. A Certificate of Lawful Use or Development (Planning Reference 92/01306/R) was

granted for the site at 122-128 East Moors Road by Cardiff County Council on 14th August
1992 for the existing use as indicated on the plan contained in the Decision Notice or as a
scrap metal business with such use beginning more than ten years before date of
application.
2.2.2. Additionally, planning permission (Planning Reference 02/00618/R) was granted on 15th
May 2002 for the single storey industrial unit which is now constructed following the
demolition of the existing unit.
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3. MANAGEMENT TECHNIQUES
3.1. Technical Competence
3.1.1. Under the EP Regulations, the activities at the Installation are classified as a relevant
waste operation, and, accordingly, a Technically Competent Manager will be required. Mr
Craig Housley will fulfil this role; and a copy of his Waste Management Industry Training
and Advisory Board (“WAMITAB”) Certificate and Continuing Certificate of Competence
are provided in Section 1 of this application submission.
3.1.2. Additionally, FWM will be employing a Senior Site Chemist and Reception Chemist at the
Installation who will both hold relevant chemistry qualifications and will undertake the
appropriate WAMITAB course on commencement of employment.
3.2. Overview of Environmental Management System
3.2.1. FWM will operate an Environmental Management System (“EMS”) at the Installation
which will address environmental aspects of the proposed activities. The EMS will be
based on the requirements of the international EMS standard BS EN ISO 14001 adopting
the Standard’s Plan, Do, Check, Act approach.
3.2.2. FWM’S EMS is externally certified to ISO 14001 at their existing East Moors Waste
Transfer Station. FWM will expand the scope of their current EMS to incorporate the
proposed Installation with the aim of the new Installation also possessing external
certification by 2022.
3.2.3. FWM’s Managing Director has overall responsibility for the Installation. Responsibility for
environmental matters at the Installation rests with the Technical Manager. The Safety,
Health, Environment and Quality Manager (“SHEQ”) Manager will be responsible for the
tracking and implementation of procedures.
3.2.4. FWM will establish a documented EMS which:

• ensures compliance with all relevant legislation;
• ensures compliance with the Installation’s Environmental Permit;
• identifies, assesses and minimises the risks of pollution arising from the
Installation’s activities;
• comprises a range of written procedures that cover all aspects of the
Installation’s activities;
• identifies, sets, monitors and reviews environmental objectives and key
performance indicators; and
• includes a requirement to report annually on environmental performance,
objectives, targets and future planned improvements.
3.3. Environmental Policy
3.3.1. A copy of FWM’s current Environmental Policy is provided in Appendix II. This
Environmental Policy will be expanded to cover the proposed operations at the
Installation.
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3.4. Details of the Environmental Management System
3.4.1. Plan
3.4.1.1. The planning element of the EMS will include:

• identification of environmental impacts and aspects associated with the
Installation’s activities, and assessing their significance; including an assessment
of the potential environmental risks posed by the work of contractors;
• identification and evaluation of relevant legal and other relevant requirements;
• identification of environmental objectives and targets that will be focussed on
reducing the impact of the identified significant environmental aspects;
• a series of risk assessments to cover a range of issues, including site operations,
maintenance, accidents, training and records; and
• details of how FWM ensure that any relevant standards, guidance and codes of
practice are met on an ongoing basis; and
• a Site Closure Plan to demonstrate how the Installation can be decommissioned
in its current state to avoid any pollution risk and return the site of operation to
a satisfactory state.
3.4.1.2. The outcomes of the above are:

• a comprehensive understanding of the potential and actual impacts of the
permitted activities on the surrounding environment and people’s health;
• the correct appropriate measures selected to manage environmental risks and
prevent or minimise their effects so as not to cause pollution;
• a series of documented procedures covering all aspects of the Installation’s
activities; and
• a series of documented environmental objectives and targets, together with an
action plan/development programme to ensure that these are met.
3.4.2. Implementation and Operation (Do)
3.4.2.1. This element will include:

• ensuring that EMS roles and responsibilities are clearly defined and
documented, and that site staff are made aware of these;
• ensuring that the Installation is operated by suitably competent staff who have
received the necessary training in all aspects of the plant’s operation, including
where contractors are used, ensuring that they are suitably competent; in this
regard:
o the skills and competencies necessary for key posts are documented;
these key posts include contractors, those responsible for liaising with
contractors and those purchasing equipment and materials,
o training requirements are identified by means of a documented training
needs analysis,
o documented training records are kept and updated as required,
o training specifically addressee’s environmental awareness and
environmental permit requirements, and
o the requirement for ongoing/refresher training is identified;
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• ensuring that there are site layout plans - including drainage plans - and that
they are revised as required to reflect any changes at the Installation;
• ensuring that there are documented procedures covering internal and external
communications;
• ensuring that there are procedures in place for staff and contractors to have
access to the Installation’s permit and management system requirements; with
regard to contractors, ensuring that suitable instructions are provided with
regard to protecting the environment whilst working on site;
• the establishment of a documented planned preventative maintenance regime
(“PPMR”) to ensure that all plant and site infrastructure are kept in suitable
condition and operating effectively; this PPMR programme details what
maintenance, tests and inspections need to done and when; this also details the
measures required to ensure continuing compliance with the permit conditions
during maintenance/shutdown.
• The PPMR also:
o identifies known or predictable malfunctions associated with the
operations and the procedures, spare parts, tools and expertise required
to deal with them,
o includes a record of spare parts held, or details on where they can be
sourced from, together with an assessment of how long they would take
to obtain,
o includes a defined procedure for identifying, reviewing and prioritising
items of plant for which a preventative regime is appropriate,
o includes equipment or plant whose failure could directly or indirectly lead
to an impact on the environment or human health and ‘non-productive’
items,
o ensure the necessary spare parts, tools, and competent staff are available
prior to commencing maintenance;
• ensuring that there are documented procedures covering document control;
• ensuring that there are suitable documented record-keeping arrangements in
place;
• ensuring that there are documented operational procedures and work
instructions covering all aspects of the Installation’s operation;
• ensuring that there are documented procedures that incorporate
environmental issues into the control of process/equipment change, capital
approval and purchasing policy;
• ensuring that there are documented procedures to address non-
conformities/non-compliances and the associated corrective and preventative
action; these will detail the means by which any such non-conformities/non-
compliances are reported to management and the means by which they are
reported to Natural Resources Wales (“NRW”).
• ensuring that there is a documented procedure for dealing with complaints; this
includes requirements to ensure that:
o an appropriate person deals with the complaint,
o the complaint is properly recorded,
o the complaint is properly investigated,
o any action necessary to deal with the cause of the complaint is recorded,
o the impact of the activity causing the problem is minimised,
o steps are taken to ensure that the problem is not repeated,
o details of any justified complaints are reported to senior management,
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o that the complainant (or NRW, as appropriate) is responded to in writing,
o if the complaint came via NRW, a suitable documented response is
provided to NRW,
o if the complaint has come from a neighbour or a member of the public, a
suitable documented response is provided to the complainant, and, if the
complaint is substantiated, a report is provided to NRW, and
o the EMS is amended accordingly to reflect any changes;
• ensuring that there are documented procedures covering emergency
preparedness and response; these will cover such incidents as major plant
failures, significant spillages of potentially polluting substances, loss of mains
electrical power etc.; these will be incorporated into an Accident Management
Plan; FWM ensure that suitable measures are in place to communicate the Plan
to all employees, management and contractors who work at the site; the Plan
details:
o the arrangements for response to an emergency, including defining
specific responsibilities,
o the measures for dealing with the consequences of an incident,
o communicating with NRW and other relevant regulatory bodies,
o communicating with the Installation’s neighbours and the local
community,
o the measures for investigating incidents (and near-misses), including
identifying suitable corrective action and following up implementation of
that action,
o the measures for recording incidents (and near-misses),
o the measures for reporting incidents (and near misses) to Senior
Management, and
o the measures for reporting incidents to NRW;
• ensuring that there are documented procedures for carrying out internal audits;
these describe how to schedule, conduct, report and manage internal audits;
• ensuring that there is a documented contingency plan in place that:
o ensures compliance is maintained with all permit conditions and
operating procedures during maintenance/shutdown at the Installation
or elsewhere,
o ensures that permitted storage limits are not exceeded and appropriate
measures for waste storage and handling continue to be applied, and
o includes ceasing the acceptance of waste unless a clearly defined method
of recovery or disposal has been determined and sufficient permitted
storage capacity is available.
3.4.3. The outcome of the above is evidence that day-to-day activities are taking place in
accordance with the requirements of the EMS and the Installation’s permit, specifically:
• that control measures and procedures are an integral part of the business
operation;
• that the EMS is easy for staff to access, understand and use;
• that staff are suitably trained and competent to carry out procedures and
control measures; and
• that the requirements of the EMS are effectively communicated to
management, staff and contractors.
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3.4.4. Check
3.4.4.1. This element includes:

• ensuring that all regulatory requirements in relation to monitoring and
measurement are complied with, specifically:
o the requirements relating to inspection and testing required under
Environmental Permit and the associated procedures /work instructions,
o the requirements relating to inspection and testing required under the
applicable health and safety legislation and the associated procedures,
o the requirements relating to the control of all inspection, measuring and
test equipment relating to environmental requirements;
• on-going evaluation of compliance with environmental legal requirements,
policy requirements and objectives and targets. Evaluation includes annual
review of the legal register, regular site inspections and internal audit
procedures;
• ensuring that non-conformities are recorded, investigated and appropriate
corrective action is taken by the due date;
• ensuring that the necessary compliance is maintained including reporting and
record-keeping required under the Environmental Permit;
• ensuring that internal audits are carried out in accordance with the documented
procedures and that any audit actions are followed up; and
• ensuring that the results of all audits are made available to Senior Management.
3.4.4.2. The outcomes of the above will be:

• that checks are carried out to ensure that the EMS is being implemented as
intended; and
• the necessary preventative and corrective actions are undertaken to minimise
non-compliances.
3.4.5. Review
3.4.5.1. This element will include:

• an annual management review of the EMS to ensure that it is appropriate, fully
implemented and current;
• a management review of the EMS when:
o there are changes on site (in activities and/or plant/equipment),
o if there is an accident, complaint or breach of permit conditions.
• an annual review of both individual and organisational training needs;
• ensuring that all changes to the EMS are properly recorded;
• an assessment of whether the Installation’s objectives, and any targets, have
been met and reported;
• a review of the Installation’s objectives and targets, and, where appropriate,
any revisions to these so as to effect continual improvement.
3.4.5.2. The outcomes of the above will be:

• the EMS is kept up to date, and
• the EMS is continually improved.
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4. OPERATING TECHNIQUES
4.1. Overview
4.1.1. FWM is proposing to accept a maximum waste throughput of 22,000 tonnes per annum
of hazardous waste, 3,000 tonnes per annum of non-hazardous waste, totalling 25,000
tonnes per annum.
4.2. Technical Standards
4.2.1. European Legislation - The following European Legislation will be used to inform the
variation application:
• the Industrial Emissions Directive (“IED”) is intended to be a single legislative
instrument for permitting, compliance and enforcement of environmental
legislation across all member states. The requirement of the IED will therefore
be considered relevant at this time; and
• the Best Available Techniques Reference Document (“BREF”) for Waste
Treatment (October 2018) will be considered as it covers Installations
associated with a number of waste treatments including recovery and disposal
of waste.
4.2.2. National Legislation – NRW implement the requirements of the IED via the EP
Regulations and have provided a number of guidance documents to assist in the
preparation of Environmental Permit applications and the ongoing management of
permitted Installations. The guidance documents used in the preparation of this
application are as follows:
• NRW’s ‘How to comply with your environmental permit’ (Version 8, October
2014); and
• Environment Agency (“EA”) Sector Guidance Note IPPC S5.06 ‘Guidance for the
Recovery and Disposal of Hazardous and Non-Hazardous Waste’ (Issue 5, Date
2013). No equivalent NRW guidance is available at the time of writing.
4.3. Proposed Waste Activities
4.3.1. Waste Codes to be Accepted at the Installation
4.3.1.1. The proposed waste codes to be accepted at the Installation are provided in the
Proposed Waste Codes and Storage Arrangements Document contained in Appendix I.
4.3.2. Waste Storage
4.3.2.1. A detailed Site Layout Plan (ECL.010.02.01-02) has been submitted as part of this
Environmental Permit application.
4.3.2.2. The Site Layout Plan should be viewed in conjunction with the Proposed Waste Codes
and Storage Arrangements Document contained in Appendix I. This document outlines
the proposed waste types and associated waste storage location corresponding to the
numbered storage bays on the Site Layout Plan (ECL.010.02.01-02).
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4.3.2.3. The main purpose of the Installation will be typical waste transfer station operations
accepting and storing waste prior to dispatching to Approved Waste Contractors for
recycling, recovery, re-processing or disposal if no other route is deemed possible. FWM
will implement the Outbound Waste Procedure (FWM HAZ TS OCP – OUTBOUND
WASTES) contained in Appendix III which provides details on the proposed waste types
and associated recovery/disposal routes.
4.3.2.4. Waste categorisation and associated dedicated storage arrangements on site are crucial
as FWM will abide by the UN Model Regulations on the Transport of Dangerous Goods
classification system assigning each dangerous substance a class that defines the type of
danger the substance presents. The packing group (“PG”) then further classifies the level
of danger according to PGI, PG II or PG III. The class system and PG dictate how
dangerous goods are packaged, labelled and carried. FWM will have a Dangerous Goods
Safety Adviser (“DGSA”) possessing the required qualification.
4.3.3. The UN classes to be accepted and transported from site will be as follows:
• Class 3 – Flammable Liquids
• Class 4 – Flammable Solids;
• Class 5 – Oxidising Substances and Organic Peroxides;
• Class 6 – Toxic Substances
• Class 8 – Corrosive Substances; and
• Class 9 – Miscellaneous Dangerous Substances.
4.3.4. Waste Treatment
4.3.4.1. Waste treatment at the Installation will be limited to the crushing of hazardous waste
containers. FWM is proposing to crush nominally empty waste containers. Due to the
flammable substance residue, the containers will be classified as hazardous waste (15 01
10*).
4.3.4.2. Containers will be crushed using a Solutex Can Compactor 206. The machinery
specification is provided in Appendix IV.
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Figure 1: Illustration of the Solutex Can Crusher
4.3.4.3. The containers will be crushed in Bay 11 and stored in Bay 7 as shown on the Site Layout
Plan (ECL.10.02.01-02). Any residual liquid resulting from the crushing will be directed to
a bunded IBC ready for disposal to an appropriately permitted Facility. The waste pre-
acceptance procedures will prevent incompatible reactions from residues. Additionally,
due to limited residue being present, no emissions to air are anticipated.
4.3.4.4. Not all waste packaging will be crushed on site. Uncrushed containers, such as 25l plastic
containers or 205l drums will remain on pallets in Bay 7.
4.3.4.5. The empty containers will be removed from site and delivered to a single Approved
Waste Contractor for refurnacing or shredding and onward recycling.
4.3.4.6. Empty containers that are in sound condition and free from residual waste will be sent
for recondition and re-use.
4.3.4.7. In the event of prolonged periods of maintenance/shutdown, FWM will ensure planning
meetings are held prior to shutdowns to preventing the accumulation of waste within the
Installation.
4.3.5. Waste Pre-Acceptance Arrangements
4.3.5.1. FWM will put in place a fully documented waste pre-acceptance procedure (FWM HAZ TS
OCP – PRE ACCEPTANCE contained in Appendix III), the purpose of which will be to
ensure that wastes are subject to appropriate technical appraisal prior to acceptance at
the site. In turn, this will ensure that unsuitable wastes are not accepted. These checks
will be carried out before any decision is made to accept a waste.
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4.3.5.2. When a waste enquiry is received the following information must be provided in writing
by the waste producer:
• details of the waste producer, including address and contact details;
• the specific process from which the waste derives; and
• an indication of the waste streams produced, their quantity, physical form,
composition, properties, classification and description.
4.3.5.3. Pre-acceptance checks and subsequent assessments will be conducted. For every case, a
representative sample will be the obtained from the production process/current holder
to compare against the description provided by the waste holder. The only exceptions to
this would be if a sample and subsequent analysis has already been undertaken by a third
party or there is sufficient information provided on a product, such as on an adhesive or
paint label.
4.3.5.4. Following characterisation of the waste and confirmation of a match against the waste
description, a technical assessment of the waste will be undertaken with regard to its
suitability for treatment at the Installation.
4.3.5.5. The Technical Department will assess the waste producer’s audit report. A record of the
assessment will be kept, its conclusions, and any actions taken.
4.3.5.6. Where the audit report is partially incomplete or inadequate, the Technical Department
will request and obtain the required information (or another audit report) prior to
accepting the waste.
4.3.5.7. Should the Technical Assessment be undertaken by a third party, FWM will:
• ensure that all details of the content of any audit tools or methodologies and
assessment criteria used by that party are provided to FWM;
• ensure that the methodology used by the third party meets FWM’s own
procedures in relation to pre-acceptance;
• keep a summary report from the third party which will demonstrate that pre-
acceptance and assessment has been conducted on waste from the relevant
producer with regard to the Installation which contains the following and that
will be updated should any information contained within it change:
o confirmation of the producer types, waste types, containers etc.
o confirm a composite waste classification, description, composition, and
properties for each waste stream and container type destined for the
Installation, derived from each of the pre-acceptance audits and with
reference to the permitted wastes for the site,
o confirmation of any issues that have been identified and what action has
been taken with regard to the producers and wastes affected;
• annually audit a random and representative cross-section of the other party’s
pre-acceptance checks to ensure both the quality of pre-acceptance checks,
subsequent assessments, waste classification and descriptions;
• keep records of all audits and electronic records of the pre-acceptance report
and assessment.
4.3.5.8. There is a clear distinction between sales and technical staff roles and responsibilities. In
the case that non-technical sales staff are involved in waste enquiries, a final technical
assessment prior to approval is made.
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4.3.5.9. All records relating to pre-acceptance at the site will be kept for a minimum of five years
at the FWM Site Office. Electronic copies will be held on site to ensure direct access to
those records for cross-reference and verification at the waste acceptance stage.
4.3.6. Waste Acceptance Arrangements
4.3.6.1. FWM will put in place a fully documented incoming waste acceptance procedure (FWM
HAZ TS OCP – ACCEPTANCE contained in Appendix III) at the Installation, the primary
purpose of which is confirm that the characteristics of the incoming waste matches the
information provided at the pre-acceptance stage.
4.3.6.2. The waste is delivered by haulier lorries and on arrival, the lorry will be weighed and
issued with waste acceptance paperwork and the following information will be recorded:
• weight;
• date of arrival on-site;
• time;
• original producers’ details (or unique identifier); and
• unique reference number.
4.3.6.3. Waste will only be accepted when there is sufficient capacity within the Installation and a
clear defined method of recovery or disposal has been determined.
4.3.6.4. All documents are checked by the Technical Department prior to the waste being
accepted.
4.3.6.5. Each delivery is visually checked prior to acceptance to ensure that the waste has been
classified, labelled and transported correctly and containment vessels are in good
condition with no signs of leakage or loss of integrity.
4.3.6.6. Non-conforming waste is described as any waste that:

• the Installation is not authorised to accept;
• is not recorded on the accompanying waste documentation; or
• would not be expected, for any other reason, to be present.
4.3.6.7. Waste delivered to the Installation must be accompanied by a written description of the
waste describing its composition and information specifying the original waste producer
and process where required.
4.3.6.8. FWM has developed a procedure containing clear and unambiguous criteria for the
rejection of wastes, together with a written procedure for tracking and reporting such
non-conformance. This is contained in Section 6 of the FWM HAZ TS OCP – ACCEPTANCE
procedure contained in Appendix III.
4.3.6.9. Any non-conforming waste observed will be removed off site and sent back to the
supplier as soon as practically possible, however, such waste will only be stored in the
Non-Conforming Waste Quarantine Bay for a maximum of 5 working days.
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4.3.6.10. There are two quarantine areas shown on the Site Layout Plan (Drawing ECL.010.02.01-
02) which has been submitted as part of this application. Non-conforming wastes will be
stored within the main building on impermeable concrete in Bay 5 whilst the Quarantine
Area required for the Fire Prevention Plan is named “Hot Load Quarantine” and is stored
on impermeable concrete in the external yard.
4.3.6.11. The supplier will be contacted without delay to inform them of the non-conforming
waste and identify measures that can be implemented to prevent recurrence. NRW will
also be informed as soon as practicable in the event of waste being rejected.
4.3.6.12. Back-up copies of electronic records will be maintained off site at FWM Head Office at
Forward House on East Moors Road in Cardiff.
4.3.7. Waste Handling, Storage and Processing
4.3.7.1. On arrival into site, vehicles will be required to report to the weighbridge office for waste
acceptance checks to be undertaken. Following weighing and initial checks, wastes will be
offloaded into the reception area labelled ‘Inbound Waste Reception’ for full acceptance
inspection and sampling. Waste will not be deposited if there is inadequate space and the
waste will not be stored in this designated bay longer than 5 working days.
4.3.7.2. Once the load has been accepted, the vehicle will be directed by an FWM Site Operative
to unload into the dedicated covered unprocessed waste bays according to the Proposed
Waste Codes and Storage Arrangements Document contained in Appendix I and
corresponding Site Layout Plan (ECL.010.02.01-02) which has been submitted as part of
this application. The process design and layout results in the streamlining of operations
and therefore, no double handling of waste will be required.
4.3.7.3. Waste storage arrangements are also described within the Installation’s Fire Prevention
Plan (Document Reference ECL.010.02.01/FPP Issue 1) and illustrated on the Site Layout
Plan (ECL.010.02.01-02) and Fire Prevention and Mitigation Plan (ECL.010.02.01-04)
contained in the FPP.
4.3.7.4. The storage areas chosen are located away from sensitive receptors where possible and
all storage areas are within the secured perimeter covered by security fencing and Closed
Circuit Television (“CCTV”).
4.3.7.5. Waste storage bays will be marked and signed with regard to quantity and waste types.
The total maximum storage capacity of the site will be stated clearly within the FPP and
EMS.
4.3.7.6. Aerosols will be stored within a dedicated covered caged bay.
4.3.7.7. All containers will be labelled clearly with the date of arrival, relevant hazard codes as per
the Classification, Labelling and Packaging (“CLP”) Regulations, chemical identity and
composition and the unique reference number linked to the Waste Tracking System.
FWM personnel will ensure labels are not obscured during handling or storage.
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4.3.7.8. The logging within the waste tracking system will prevent hazardous and non-hazardous
wastes from being mixed as designated areas, such as hazardous and non-hazardous
waste electrical and electronic equipment (“WEEE”) storage areas, will be in place at the
Installation.
4.3.7.9. Waste treatment at the Installation will be limited to crushing of empty hazardous waste
containers as described in Section 4.3.4.
4.3.7.10. All other waste to be accepted will be stored in the designated bays prior to sufficient
quantity on site ready for dispatch to Approved Waste Contractors for recovery,
recycling, re-processing or disposal as described in the FWM HAZ TS OCP – OUTBOUND
WASTES procedure contained in Appendix III.
4.3.8. Waste Dispatch
4.3.8.1. All waste received at the Installation will be removed from the Installation for recovery or
disposal within 6 months of receipt.
4.3.8.2. The majority of wastes will remain in their original packaging, such as drums or IBCs and
will be removed from site when the quantity is sufficient to be removed from site by
haulage lorry for reprocessing at an approved and appropriately licenced waste Facility or
Installation.
4.3.8.3. Liquid materials subject to bulking will be removed from the Installation by road tanker.
The FWM HAZ TS OCP – LIQUID BULKING procedure contained in Appendix III will be
followed. This procedure includes controls to prevent adverse or unexpected reactions
and releases from transfers. Tankers will not be used as reaction vessels.
4.3.8.4. Worst case scenario testing will take place prior to transfer from container to bulk tanker
and records kept.
4.3.8.5. This transfer activity will be undertaken in Bay 6 one Intermediate Bulk Container (“IBC”)
at a time to ensure control of the transfer at all times and prior to arrival of the tanker, all
inbound waste will be moved to the correct designated bay.
4.3.8.6. Prior to undertaking the bulking activity, the bulking activity will be simulated in
laboratory conditions by experienced FWM personnel following approval by the Senior
Chemist. This simulation will enable any evolved gases and causes of odour to be
identified. In the unlikely event that any adverse reactions are observed, an alternative
discharge or disposal route will be found.
4.3.8.7. Removal of waste materials from the Installation will be documented in accordance with
Duty of Care requirements. All waste materials will be weighed prior to these being
removed from the site. This will be achieved by the vehicles being weighed prior to
loading and then prior to departure carrying such waste over the weighbridge.
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4.3.9. Records
4.3.9.1. A waste tracking system will be implemented which will hold all the information
generated during the pre-acceptance, acceptance, storage, treatment and removal off
site. This system is described in Section 5 of the FWM HAZ TS OCP – ACCEPTANCE
procedure contained in Appendix III.
4.3.9.2. Records are made and kept up to date on an ongoing basis to reflect deliveries, on-site
treatment and despatches. The tracking system operates as a waste inventory control
system and includes:
• date of arrival on-site;
• producers details;
• all previous holders;
• a unique reference number;
• pre-acceptance and acceptance analysis results;
• load/package type and size;
• intended treatment/disposal route;
• the nature and quantity of all wastes held on site (this includes all hazards);
• the physical location of the wastes in relation to the site layout plan;
• where the waste is in the designated disposal route; and
• identification of site staff who have taken any decisions regarding the
acceptance or rejection of waste streams and the recovery or disposal options.
4.3.9.3. The reporting system can provide reports on the following:

• the total quantity of waste present on site at any one time;
• a breakdown of the waste quantities being stored pending on-site treatment,
classified by treatment route;
• breakdown of waste quantities on site for storage pending onward transfer;
• breakdown of waste quantities by hazard classification;
• the physical locations of the waste in relation to the site layout plan. This will
include a record of any movements to different locations on site, however, this
would not be normal practice;
• a comparison of the quantity of waste stored on site against the total permitted
to be stored; and
• a comparison of the time the waste has been stored on site against the
permitted limit.
4.3.9.4. All records are held in hard copy and electronically within the office/laboratory building
located away from hazardous waste storage areas. A backup copy is maintained and
stored off site at FWM’s Head Office at Forward House in East Moors Road, Cardiff. All
digital records will be held for a maximum of 5 years.
4.4. Proposed Infrastructure and Drainage Arrangements
4.4.1. The entire Installation benefits from concrete hardstanding and is located within a secure
compound, completely enclosed by a block wall, metal palisade fencing and a lockable
main entrance gate which is locked out of hours.
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4.4.2. FWM hold a contract with a specialist security company who maintain the site’s CCTV
surveillance. The CCTV control panel is located within the Installation’s office building and
is monitored throughout the day. Senior management also have access to the CCTV
footage. Nominated personnel will be available to attend site out of hours if needed.
4.4.3. The drainage arrangements at the Installation are illustrated on the Drainage
Arrangements Plan (ECL.010.02.01-05) which has been submitted as part of this
application.
4.4.4. Rainwater runoff from the building guttering and downpipes will be channelled to three
storm drains shown on the Drainage Arrangements Plan. The flow is directed into the foul
sewer drainage network. Sewerage from the welfare facilities in the laboratory/office
building also connects into this foul sewer drainage network.
4.4.5. Any surface run off from the external yard area will be directed via the site manhole
drains into the foul sewer drainage network.
4.4.6. An emergency spill procedure will be implemented to respond to any spillages. This
procedure will be contained within the Installation’s EMS. This is described in more detail
in Section 5.
4.4.7. FWM will implement a regime of visual site condition checks to be undertaken weekly to
ensure that the infrastructure is maintained in good condition. The site condition
inspection checks will be included within the EMS and will cover:
• condition and integrity of the impermeable concrete hardstanding;
• condition and integrity of the site buildings, fences and gates;
• condition and integrity of drainage arrangements;
• condition and operation of site security measures, e.g. CCTV; and
• condition and integrity of storage bays and bunding.
4.4.8. The results of these checks and details of any remedial action and maintenance that may
be required in order to ensure good condition will be recorded on check sheets and
stored within the ‘Facility Checks’ file.
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5. EMISSIONS
5.1. Point Source Emissions to Air – Proposed Arrangements
5.1.1. There will be no point source emissions to air.
5.2. Point Source Emissions to Surface Water – Proposed Arrangements
5.2.1. There will be no point source emissions to surface water. Only clean surface runoff will be
discharged to storm manholes which in turn connect into the foul sewer drainage
network.
5.3. Point Source Emissions to Sewer – Proposed Arrangements
5.3.1. There will be no point source emissions to sewer associated with the proposed activities.
Only clean surface runoff will be discharged to foul sewer as part of the proposed
activities, in addition to the effluent from the on-site welfare facilities.
5.4. Point Source Emissions to Land – Current Arrangements
5.4.1. There will be no emissions to land.
5.5. Fugitive Emissions to Air
5.5.1. The potential sources of fugitive emissions to air from the proposed operations include:
• movement of transport vehicles into and out of site;
• storage of the waste materials; and
• loading of waste.
5.5.2. There will be no tipping of loose waste material. All waste will be containerised.
Therefore, the risk of fugitive emissions to air is considered to be low.
5.6. Fugitive Emissions to Surface Water, Sewer and Groundwater
5.6.1. The operational areas are surfaced with impermeable concrete and the Installation
boundary is enclosed by a containment concrete bund wall to the north, east and west.
5.6.2. Fugitive releases to the groundwater will be prevented by conducting all operations,
including the unloading of deliveries, storage of waste materials, processing (crushing)
and handling in areas sealed with an impervious barrier to prevent a pathway for
migration to ground and groundwater.
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5.6.3. All storage vessels will be inspected on arrival at the site as part of the acceptance
procedure to ensure that they are in good condition with no obvious signs of leakage or
loss of integrity. Any evidence of the above will result in the waste not being accepted at
the Installation. The inspections will be repeated daily and any evidence of damage,
deterioration or leakage will be recorded and faults repaired or contents transferred to
another container.
5.6.4. All external storage concrete block bays will be covered by steel supported corrugated
sheeting and will benefit from an impermeable rollover policeman. Although the bays will
be covered, sleeping policeman/kerbing will ensure that any rainwater runoff will be
prevented from entering the drainage network.
5.6.5. Sufficient secondary containment bunding will provide 25% of the total capacity of all
containers such as IBCs/drums stored in each waste bay.
5.6.6. The bay block walls, sleeping policeman/kerbing and barriers will be in place to prevent
the risk of vehicle collision with storage vessels.
5.6.7. Any residual liquid resulting from the crushing of empty hazardous containers will be
directed to a bunded IBC ready for disposal to an appropriately licenced Facility.
5.6.8. No fuel oil will be stored at the Installation. Site vehicles will be refuelled at FWM’s
adjacent site at East Moors Waste Transfer Station (Permit Ref: EPR/AB3099FT). The
transfer of fuel oil will be covered by the existing EMS procedure at the Facility.
Additionally, all chemicals, such as lubrication oils associated with the maintenance of
plant and machinery will also be stored at FWM’s other facility on East Moors Road.
5.6.9. Plant and equipment will be subject to regular maintenance and servicing as per the
Installation’s PPMR contained in Section 7 of the application submission. This will ensure
they are in good working to reduce the likelihood of fuel leakage at the Installation.
5.6.10. Regular site inspections will be undertaken to observe any spillages and to guarantee the
continued integrity of bunding and impermeable concrete surfacing. If remedial action is
required, this will be undertaken immediately.
5.6.11. Any spillages at the Installation will be subject to the Installation’s robust EMS which will
contain FWM’s spill management procedure. This will prevent any potentially polluting
materials from entering the Installation’s drainage network. Any spillage of hazardous
waste will be recorded in the Site Diary and NRW informed if the spillage is greater than
200 litres.
5.6.12. All employees will be suitably trained in all aspects of the EMS including spill response,
such as the deployment of absorbent mats and drain covers. Spill kits will be strategically
located and contents regularly inspected and maintained.
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6. GENERAL REQUIREMENTS
6.1. Emissions Management
6.1.1. The Environmental Risk Assessment (“ERA”) (Document Reference ECL.010.02.01/ERA)

has demonstrated that emissions of substances not controlled by emission limits (i.e.
fugitive emissions) are not considered to be significant, consequently, an Emissions
Management Plan is not required as part of this application.
6.2. Odour Management
6.2.1. FWM are not proposing to accept any waste which is likely to be odorous in nature.
Furthermore, the ERA has demonstrated that odour emissions are not considered to be
significant. Consequently, an Odour Management Plan is not required as part of this
application.
6.3. Noise Management
6.3.1. The Installation is located in a predominantly industrial setting and the only processing
activity proposed is related to the crushing of empty waste containers. The ERA has
demonstrated that noise emissions are not considered to be significant. Consequently, a
Noise Management Plan is not required as part of this application.
6.4. Pest Management
6.4.1. Due to the nature of waste to be accepted, the risk of the attraction of pests, such as
rodents and flies, is deemed not to be significant as detailed in the ERA. Consequently, a
Pest Management Plan is not required as part of this application.
6.5. Fire Management
6.5.1. As per the requirements of NRW’s ‘Fire Prevention and Mitigation Plan Guidance – Waste
Management’ (Version 2.0, August 2017), a Fire Prevention Plan is required for Operators
that store any amount of combustible waste material including (but not limited to);
• plastics;
• rags and textiles;
• WEEE, such as fridges, computers and televisions containing combustible
materials such as plastic; and
• batteries within End of Life Vehicles (“ELVs”).
6.5.2. The Fire Prevention Plan (ECL.010.02.01/FPP) has been prepared and is included in
Section 8 as part of this application submission.
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6.5.3. The Fire Prevention Plan will form part of FMW’s EMS and will be reviewed and updated
annually or if any of the following occur:
• a fire event at the site;
• a change or review of legislation;
• if the site is instructed to do so by NRW; or
• if there are changes to the listed contractors contained within the document.
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7. APPLICATION SITE CONDITION REPORT
7.1. An Application Site Condition Report (“ASCR”) has been prepared to form part of the
Environmental Permit application. The ASCR (Document Reference ECL.010.02.01/ASCR)
is contained within Section 4 of this application submission.
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8. MONITORING
8.1. Monitoring of Emissions to Air
8.1.1. There are no point source (i.e. process contributions) emissions to air proposed as part of
this application. Consequently, no monitoring of emissions to air is proposed.
8.2. Monitoring of Groundwater
8.2.1. Fugitive releases to the groundwater will be prevented by conducting all operations,
including the unloading of deliveries, storage of waste materials, processing and handling
in areas sealed with an impervious barrier to prevent a pathway for migration to ground
or groundwater. Consequently, no monitoring of groundwater is proposed.
8.3. Monitoring of Surface Water
8.3.1. There will be no point source (i.e. process contribution) to surface water. Only clean
surface water runoff (rainwater) will be discharged via the storm manhole drains which in
turn connect to the foul sewer drainage network. Therefore, no monitoring of surface
water is proposed.
8.4. Monitoring of Foul Water
8.4.1. There will be no point source (i.e. process contributions) to foul water. Only effluent from
the site’s welfare facilities and clean rainwater from site surfacing will drain via the foul
drainage network. Consequently, no monitoring of foul water is proposed.
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9. RESOURCE EFFICIENCY AND CLIMATE CHANGE
9.1. Energy Efficiency Measures
9.1.1. A number of energy efficiency measures will be implemented at the FWM Installation,
such as:
• ensuring regularly inspection and maintenance of equipment and plant to
achieve optimum efficiency. For example, frequent lubrication of equipment to
avoid high friction losses. This will be contained within the PPMR as part of the
EMS;
• optimising start-up time, power down time and equipment sequencing;
• optimising operational planning to streamline equipment and plant use;
• energy efficient light-emitting diode (“LED”) lighting to be installed within the
main building;
• all lights and equipment will be turned off when not in use; and
• employees will be trained in the importance of energy management and basic
energy saving practices.
9.1.2. Energy use will be monitored monthly to produce an energy balance record and any
opportunities for energy efficiency improvement will be addressed as part of the EMS.
9.2. Energy Consumption
9.2.1. It is estimated that 30,000 kWh per annum of electricity will be consumed for general
power on site, such as lighting, for the operation of equipment and for use within the
main building, office and laboratory.
9.2.2. Table 2 below provides the basic energy data in accordance with BAT 1 of Section 2.7.2.
of SGN 5.06.
Table 2: Energy Consumption

Energy Use on Site Estimated Primary CO2 Released Per
Source Annual Quantity Annual Annum (tonnes)
(MW) Energy (MW)
Electricity Lighting/Workshop 30 72 12
Note to Table:
• Conversion factor for delivered energy to primary = 2.4; and
• CO2 conversion factors used from EA H1 Global Warming Potential Guidance Online – Electricity = 0.166
tonnes/MWh, Gas oil (diesel) = 0.25 tonnes per MWh.
9.3. Climate Change Agreement
9.3.1. The FWM site is not subject to a Climate Change Agreement (“CCA”). The basic energy
requirements, in addition to the sector specific energy requirements set out in the
relevant technical guidance, have been adopted as outlined in Section 9.1 above.
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9.4. Raw Material Justification
9.4.1. Site vehicles will be refuelled at FWM’s adjacent East Moors Road Waste Transfer Station.
No storage of fuel oil is proposed at the Installation.
9.4.2. Small quantities of lubricants, Ad Blue and adhesives will also be stored at FWM’s
adjacent East Moors Road Waste Transfer Station and used as and when required. No
chemicals will be stored at the proposed Installation.
9.4.3. The Installation’s EMS will include a procedure for the annual review of new
developments in raw materials and for the implementation of any suitable ones with an
improved environmental profile.
9.4.4. A procedure will be incorporated into the site’s EMS describing the quality assurance
procedures for controlling the impurity content of the raw materials. If required, long-
term studies will be undertaken into any less polluting options and material substitutions
will be identified and then implemented accordingly.
9.5. Waste Minimisation
9.5.1. The proposed activities to be undertaken at FWM are based on the application of the
waste hierarchy and in particular, waste avoidance. All waste materials will be delivered
to the Installation with the aim of dispatching to appropriately licenced Facilities or
Installations for reprocessing, recycling or recovery, where possible.
9.5.2. FWM also commit to the reuse of non-hazardous containers following cleaning and
reconditioning where technically and economically possible. Wood pallets used during
the transportation of waste materials will be reused on site or sent to the Forward Waste
East Moors Road Transfer Station for reuse.
9.5.3. For each waste stream, the following will be monitored and recorded as part of the
Waste Tracking System;
• the physical and chemical composition of waste;
• its hazard characteristics; and
• handling precautions and substances with which it cannot be mixed.
9.5.4. Using the information recorded as part of the waste tracking system, a waste
minimisation audit will be undertaken 12 months after the Environmental Permit has
been issued. This will allow FWM to set a baseline against which improvement targets
can be set and for the availability of viable alternative routes other than disposal to be
explored.
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10. COMPLIANCE WITH BAT CONCLUSIONS
10.1. Overview
10.1.1. It is considered that the techniques that will be in use at the proposed Installation will
constitute Best Available Techniques (“BAT”) and will be appropriate and proportionate
for the scale of the activities at the Installation and the risks that are posed to the
environment by these activities.
10.1.2. The BAT Requirements for the proposed Installation have been taken the BREF for Waste
Treatment (October 2018) and the EA’s IPPC S5.06 ‘Recovery and disposal of hazardous
and non-hazardous waste’ (Issue 5, May 2013)
10.1.3. Where appropriate, reference has also been made to NRW’s ‘How to comply with your
environmental permit’ (Version 8, October 2014).
10.1.4. A demonstration of compliance with applicable BAT is provided in Tables 3 and 4.
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Table 3: Waste Treatment BREF- General BAT Conclusions
BAT
Section of
Ref BAT Requirement
EPTR Document
No.
Overall Environmental Performance
In order to improve the overall environmental performance, BAT is to implement and adhere to an EMS that incorporates all of the following
features:
I. commitment of the management, including senior management;
II. definition, by the management, of an environmental policy that includes the continuous improvement of the environmental
performance of the installation;
III. planning and establishing the necessary procedures, objectives and targets, in conjunction with financial planning and investment;
IV. implementation of procedures;
V. checking performance and taking corrective action; Section 3 -
VI. review, by senior management, of the EMS and its continuing suitability, adequacy and effectiveness; Management
1 VII. following the development of cleaner technologies; Techniques &
VIII. consideration for the environmental impacts from the eventual decommissioning of the plant at the stage of designing a new plant, and Section 6 –
throughout its operating life; General Requirements
IX. application of sectoral benchmarking on a regular basis;
X. waste stream management (see BAT 2);
XI. an inventory of waste water and waste gas streams (see BAT 3); - n/a
XII. residues management plan (see description in Section 6.6.5); - n/a
XIII. accident management plan (see description in Section 6.6.5);
XIV. odour management plan (see BAT 12); - n/a
XV. noise and vibration management plan (see BAT 17).- n/a.
In order to improve the overall environmental performance of the plant, BAT is to use all of the techniques given below:
a) set up and implement waste characterisation and pre-acceptance procedures;
b) set up and implement waste acceptance procedures;
c) set up and implement a waste tracking system and inventory; Section 4 –
2
d) set up and implement an output quality management system; Operating Techniques
e) ensure waste segregation;
f) ensure waste compatibility prior to mixing or blending of waste; and
g) sort incoming solid waste.
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Table 3: Waste Treatment BREF- General BAT Conclusions (Cont.)
BAT
Section of
Ref BAT Requirement
EPTR Document
No.
Overall Environmental Performance
In order to reduce the environmental risk associated with the storage of waste, BAT is to use all of the techniques given below.
a) optimised storage location; Section 4.3. –
4 b) adequate storage capacity; Proposed Waste
c) safe storage operation; and Activities
d) separate area for storage and handling of packaged hazardous waste.
Section 4.3.7
In order to reduce the environmental risk associated with the handling and transfer of waste, BAT is to set up and implement handling and
5 Waste Handling,
transfer procedures.
Storage and Processing
Monitoring
Section 6.2. –
10 BAT is to periodically monitor odour emissions.
Odour Management
Section 9.2. –
Energy Consumption
Section 9.4. –
BAT is to monitor annual consumption of water, energy and raw materials as well as the annual generation of residues and waste water, with a
11 Raw Material
frequency of at least once per year.
Justification
Section 9.5. –
Waste Minimisation
Emissions to Air
In order to prevent or, where that is not practicable, to reduce odour emissions, BAT is to set up, implement and regularly review an odour
12 Section 6.2. –
management plan, as part of the EMS.
Odour Management
13 In order to prevent or, where that is not practicable, to reduce odour emissions, BAT is to use one or a combination of the techniques listed.
Section 6.1. –Emissions
In order to prevent, or where that is not practicable, to reduce diffuse emissions to air, in particular of dust, organic compounds and odour, BAT Management
14
is to use an appropriate combination of the techniques listed. Section 5.5. Fugitive
Emissions to Air
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BAT Section of
Ref BAT Requirement EPTR Document
No.
Noise and Vibrations
In order to prevent or, where that is not practicable, to reduce noise and vibration emissions, BAT is to set up, implement and regularly review a
noise and vibration management plan, as part of the EMS, that includes all of the following elements:
I. a protocol containing appropriate actions and timelines;
17 II. a protocol for conducting noise and vibration monitoring;
III. a protocol for response to identified noise and vibration events, e.g. complaints; and
IV. a noise and vibration reduction programme designed to identify the source(s), to measure/estimate noise and vibration exposure, to
characterise the contributions of the sources and to implement prevention and/or reduction measures. Section 6.3. – Noise
In order to prevent, or where that is not practicable, to reduce noise and vibration emissions, BAT is to use one or a combination of the Management
techniques given below.
(a) appropriate location of equipment and buildings;
18 (b) operational measures;
(c) low noise equipment;
(d) noise and vibration control equipment; and
(e) noise attenuation.
Emissions from Accidents and Incidents
In order to prevent or limit the environmental consequences of accidents and incidents, BAT is to use all of the techniques given below, as part of
the accident management plan. Section 3.4.2. –
21 (a) protection measures; Implementation and
(b) management of incidental/accidental emissions; and Operation
(c) incident/accident registration and assessment system.
Material Efficiency
Section 9.4. –
22 In order to use materials efficiently, BAT is to substitute materials with waste. Raw Material
Justification
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BAT
Section of
Ref BAT Requirement
EPTR Document
No.
Energy Efficiency
In order to use energy efficiently, BAT is to use both the techniques given below.
Section 9.1. –
23 (a) energy efficiency plan; and
Energy Efficiency
(b) energy balance record
Reuse of Packaging
Section 9.5 –
24 In order to reduce the quantity of waste sent for disposal, BAT is to maximise the reuse of packaging, as part of the residues management plan.
Waste Minimisation
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Table 4: IPPC S5.06 Guidance Document - Techniques for Pollution Control: BAT Requirements
Ref Section of
BAT Requirement
No. EPTR Document
IPPCS5.06, 2.1 In Process Controls - Section 2.1.1, Pre-Acceptance Procedures to Assess Waste
From the waste disposal enquiry, the Operator should obtain information in writing relating to:
• The type of process producing the waste;
• The specific process from which the waste derives;
• The quantity of waste;
1
• Chemical analysis of the waste (individual constituents and as a minimum their percentage compositions);
• The form the waste takes (solid, liquid, sludge etc.);
• Hazards associated with the waste; and
• Sample storage and preservation techniques.
Unless a sample and analysis has already been completed by a third party and the Operator has a sufficient written information from them, then
2 the Operator should in every case obtain representative sample(s) of the waste from the production process/current holder and compare it
against the written description to ensure it is consistent.
Other than for pure product chemicals or laboratory smalls, the chemical analysis should relate to an actual analysis and not simply be based on
3 product data sheets or an extrapolation of information on product data sheets. For example, taking the concentrations as specified and applying Section 4.3.5. –
a dilution factor is not acceptable. Waste Pre-Acceptance
Arrangements
Wastes should not be accepted at the installation without a clear method or defined treatment and disposal route being determined in advance
4
and costed before the waste is accepted at the installation.
The Operator should ensure that the sample is representative of the waste and has been obtained by a person who is technically competent to
5
undertake the sampling process.
The type of information that would demonstrate the reliability of the sample includes:
• location of sample point, for example, effluent tank;
• capacity of vessel sampled (for samples from drums an additional parameter would be the total number of drums);
6 • method of sampling, e.g. sampling tap (mid flow), “top” sample;
• number of samples and degree of consolidation;
• operating conditions at time e.g. normal operation, shut-down, maintenance and/or cleaning; and
• preservation techniques.
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Table 4: IPPC S5.06 Guidance Document - Techniques for Pollution Control: BAT Requirements (Cont.)
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IPPCS5.06, Section 2.1.1, Pre-Acceptance Procedures to Assess Waste
7 Samples should be clearly labelled and any hazard identified.
8 Sample tracking systems within the installation should be established and be auditable.
9 Analysis should be carried out by a laboratory with robust quality assurance and quality control methods and record keeping.
Analysis required will vary depending upon the nature of the waste, the process to be used and what is known about the waste already. Results
of analysis should be kept within the tracking system. These details should include:
• check on constituents declared by waste producer/holder to ensure Permit compliance, treatment plant specification and final disposal;
• all hazardous characteristics;
10
• physical appearance;
• colour;
• pH;
• presence, strength and description of odour assessment (note COSHH implications). Section 4.3.5. – Waste
Installations accepting waste oil should have the facility to hold and test loads for PCBs or a surrogate test for chlorine at a level of detection to Pre-Acceptance
13 Arrangements
assess compliance with the requirements of the Waste Oils Directive.
Following characterisation of the waste, a technical assessment should be made of its suitability for treatment or storage to ensure Permit
14
conditions are being met.
There must be a clear distinction between sales and technical staff roles and responsibilities. If non-technical sales staff are involved in waste
15 disposal enquiries, then a final technical assessment prior to approval should be made. It is this final technical checking that should be used to
avoid build-up of accumulation of waste.
All records relating to pre-acceptance should be maintained at the installation for cross-reference and verification at the waste acceptance stage.
16
These records should be kept for a minimum of 3 years.
For laboratory smalls, whether or not the installation Operator packs them on behalf of the producer, a full list of laboratory smalls should be
17
created and transported with the waste.
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IPPCS5.06, Section 2.1.2, Acceptance Procedure When Waste Arrives At The Installation
Load Arrival
On arrival loads should:
• be weighed, unless alternative reliable volumetric systems linked to specific gravity data are available; Section 4.3.6. –Waste
1 • not be accepted into site unless sufficient storage capacity exists and site is adequately manned to receive waste; Acceptance
• have all documents checked and approved, and any discrepancies resolved before the waste is accepted; and Arrangements
• have any labelling that does not relate to the contents of the drum removed before acceptance on site.
Section 3.1. – Technical
2 Hazardous wastes should only be received under the supervision of a suitably qualified person (HNC qualified chemist or higher).
Competence
Load Inspection
Visual inspection. Where possible, confirmatory checks should be undertaken before offloading where safety is not compromised. Inspection
3
must in any event be carried out immediately upon offloading at the installation.
Check every container to confirm quantities against accompanying paperwork. All containers should be clearly labelled and should be equipped Section 4.3.6. –
4 with well-fitting lids, caps and valves secure and in pace. Any damaged, corroded or unlabelled drums should be put into a quarantine area and Waste Acceptance
dealt with appropriately. Following inspection, the waste should then be unloaded into a dedicated sampling/reception area. Arrangements
At this stage, the waste tracking system unique reference number should be applied to each container. Each container should be also labelled
5
with the date of arrival on-site and primary hazard code.
Section 4.3.7. –
7 The inspection, unloading and sampling areas should be marked on a plan and have suitably sealed drainage systems. Waste Handling,
Sampling – Checking - Testing of Wastes - Storage
Other than pure product chemicals and laboratory smalls, no wastes should be accepted at the installation without sampling, checking and Section 4.3.6. –
testing being carried out. Reliance solely on the written information supplied is not acceptable, and physical verification and analytical Waste Acceptance
8
confirmation are required. All wastes, whether for on-site treatment or simply storage, must be sampled and undergo verification and Arrangements
compliance testing. Section 4.3.9. - Records
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Sampling – Checking - Testing of Wastes - Storage
The Operator should ensure that waste delivered to the installation is accompanied by a written description of the waste describing:
• the physical and chemical composition;
9 • hazard characteristics and handling precautions;
• compatibility issues; and
• information specifying the original waste producer and process.
On-site verification and compliance testing should take place to confirm:
• the identity of the waste; Section 4.3.6. –
10 • the description of the waste Waste Acceptance
• consistency with pre-acceptance information and proposed treatment method; and Arrangements &
• compliance with permit. Section 4.3.9. - Records
The Operator should have clear and unambiguous criteria for the rejection of waste, together with a written procedure for tracking and reporting
11 such non-conformance. This should include notification to the customer/waste producer and the Regulator. Written/computerised records
should form part of the waste tracking system information.
Documentation provided by the driver, written results of acceptance analysis, details of offloading point or off-site transfer location should be
12
added to the tracking system documentation.
13 A record of sampling regime for each load and justification for the selection of this option should be maintained at the installation.
14 Wastes must not be deposited within a reception area without adequate space.
Wastes in containers should be unloaded into a dedicated reception area pending acceptance sampling. Such storage should be for a maximum Section 4.3.7. –
period of 5 days. During this period there should be no bulking up or mixing of drums or decanting the contents into bulk storage. Wastes should Waste Handling,
15
be stored within this reception area according to compatibility in line with HSE Guidance Note. Appropriate storage must be achieved Storage and Processing
immediately upon offloading.
Section 4.3.6. –
Waste Acceptance
Should the inspection or analysis indicate that the wastes fail to meet the acceptance criteria (including damaged or unlabelled drums), and then
Arrangements
16 such loads should be stored in a dedicated quarantine area and dealt with appropriately. Such storage should be more a maximum of five
Section 4.3.7. –
working days. Written procedures should be in place for dealing with wastes held in quarantine, together with a maximum storage volume.
Waste Handling,
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Should the inspection or analysis indicate that the wastes fail to meet the acceptance criteria (including damaged or unlabelled drums), and
16 then such loads should be stored in a dedicated quarantine area and dealt with appropriately. Such storage should be more a maximum of five
working days. Written procedures should be in place for dealing with wastes held in quarantine, together with a maximum storage volume.
Section 4.3.6. -Waste
17 If the cause of failure to meet acceptance criteria is due to incompatibility, wastes should be segregated immediately to remove the hazard. Acceptance
The installation should have a designated sampling point or reception area. These should be in close but safe proximity to the Arrangements
20 laboratory/checking facility and the sampling point should be visible (or covered by CCTV), if sampling is not directly supervised by, for example, Section 4.3.7. Waste
laboratory staff. Handling, Storage and
Processing
The offloading, sampling point/reception and quarantine areas should have impervious surface with self-contained drainage, to prevent any
21 spillage entering the storage systems or escaping off-site. Attention should be given to ensuring that incompatible substances do not come into
contact resulting from spills from sampling, for example, within a sump serving the sampling point. Absorbents should be made available.
Sampling of Drummed Waste
The contents can only be identified with certainty if every container is sampled. Acceptance should involve sampling every container. However, Section 4.3.6. - Waste
26 analysis of composite samples is acceptable with such a sampling regime. A representative sample must be obtained by taking a core sample to Acceptance
the base of the container. Operators should ensure that lids, bungs and valves are replaced immediately after sampling. Arrangements
Drum Labelling
For drummed waste, controls should ensure each drum is given a unique able to facilitate a record of:
• the location of each drum;
27 • the duration of storage; Section 2.3.9. - Records
• the chemical identity of the drums contents; and
• the hazard classification for each drum.
Section 4.3.7. –
28 Drums should be handled and stored so that the label is readily visible. Waste Handling,
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Acceptance of Laboratory Smalls
The procedure for accepting laboratory smalls should be essentially identical to that for drummed waste. They differ from normal waste inputs
29
to site in that they are in a pure concentrated form.
In situations where the Operator has undertaken the identification and packaging on behalf of the customer, then the onsite verification can be
restricted to opening the drums to check that the containers remain undamaged. In such cases the load must be accompanied by Section 4.3.6. – Waste
documentation confirming the checking and packing. In situations where the drum has been packed by the customer, then full checking and Acceptance
30 verification should be undertaken. Checking packaging and segregation adequately should include emptying of the drum as soon as possible Arrangements
and in any event at facilities that are operated 24 hours a day within 24 hours. At sites not operated around the clock, checking must be
undertaken before the end of the working day. Repackaging the waste must be undertaken as soon as the necessary checks have been
undertaken.
Waste Rejection Procedures
Lab smalls must not be accepted at a facility where this is insufficient suitably qualified personnel to process these wastes within the above Section 3.1. – Technical
31
timescales. Competence
If on opening a drum, it is found that it contains incompatible substances, or that the substances have not been packaged adequately, then the
32
rum should be sorted and repacked immediately and the non-conformance procedure followed.
Sorting and repackaging of laboratory smalls should take place in a dedicated area/store. Once wastes sorted according to hazard classification
33 with due consideration for any potential incompatibility problems and repackaged, then these drums should not be stored within the dedicated
laboratory smalls area but should be removed to the appropriate storage area.
Section 4.3.6. – Waste
The operator should have clear and unambiguous criteria for the rejection of wastes, together with a written procedure for tracking and
Acceptance
reporting such non-conformance. This should include notification to the customer/waste producer and the Environment Agency.
Arrangements
Written/computerised records should form part of the waste tracking system information. The operator should also have a clear and
34 unambiguous policy for the subsequent storage and disposal of such rejected waste. This policy should achieve the following:
• identifies the hazards posed by the rejected wastes;
• labels rejected wastes with all information necessary to allow proper storage and segregation arrangements to be put in place; and
• segregates and stores rejected wastes safely pending removal.
Records
The waste tracking system should hold all the information generated during pre-acceptance, acceptance, storage, treatment and removal off-
35 site. Records should be made and kept up to date on on-going basis to reflect deliveries, on-site treatment and despatches. The tracking system Section 4.3.9. – Records
should operate as a waste inventory/stock control system and include requirements listed.
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Records
All records relating to pre-acceptance checks should be maintained and kept readily available at the installation for cross-reference and
36
verification at the waste acceptance stage.
The system adopted should be capable of reporting on all of the following:
• total quantity of waste present on-site at any one time, in appropriate units;
• breakdown of waste quantities being stored pending on-site treatment, classified by treatment route;
• indication of where the waste is located on site relative to the site plan; Section 4.3.9. – Records
37
• comparison of the quantity on site against total permitted;
• comparison of time the waste has been on-site against permitted limit.
These records should be held in a designated area, as agreed with the Agency, well removed from hazardous activities to ensure their
accessibility during any emergency.
38 Back-up copies of computer records should be maintained off-site.
General
Section 4.3.6. Waste
Wastes should not be accepted at the installation without a clear defined method of recovery or disposal being determined and costed and
39 Acceptance
ensuring there is sufficient capacity being available. These checks should be performed before the waste acceptance stage is reached.
Arrangements
The Operator should ensure that the installation personnel who may be involved in the sampling, checking and analysis procedures are suitably Section 3.1. – Technical
40
qualified (HNC qualified chemist or higher) and adequately trained, and that the training is updated on a regular basis. Competence
41 Analysis should be carried out by a laboratory with suitably accredited test methods.
Samples should be retained on-site for a minimum of two days after the waste has been treated or removed off-site including all residues from Section 4.3.5. –
42
its treatment. Waste Pre-Acceptance
Once analysis has confirmed that the waste is acceptable, the Operator should only then create a batch for treatment or a load for off-site Arrangements &
43
removal. Section 4.3.6. –
There must be a clear distinction between sales and technical staff roles and responsibilities. If non-technical sales staff are involved in waste Waste Acceptance
44 enquiries then a final technical assessment prior to approval should be made. It is this final technical checking that should be used to avoid Arrangements
build-up of accumulations of wastes and to ensure that sufficient capacity exists.
37
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BAT
Section of
Ref BAT Requirement
EPTR Document
No.
IPPCS5.06, Section 2.1.3, Waste Storage
Offloading/Discharge of Waste
The Operator should have in place a system to ensure that the correct discharge point or storage area is used. The options for this include:
Section 4.3.2. –
• ticket systems;
Waste Storage
1 • supervision by site staff and if relevant CCTV;
Section 4.3.9 –
• keys; and Records
• colour-coded points/hoses or fittings of a specific size.
Section 4.3.6. – Waste
Acceptance
Offloading and quarantine points should have an impervious surface with self-contained drainage, to prevent any spillages entering the storage Arrangements
2
systems or escaping off-site. Section 4.4. – Proposed
Infrastructure and
Drainage Arrangements
3 Damaged hoses and connections must not be used.
Section 4.3.8. –
Only couplings of the correct size for the connection should be used and the coupling should be able to withstand the maximum shut valve
4 Waste Dispatch
pressure of the transfer pump.
Record Keeping
5 The Operator should have an internal tracking system which should satisfy the objectives and minimum standards given. Section 4.3.9. – Records
General Storage Requirements
Storage areas are often the most visible aspects of the installation. Storage areas should be located away from watercourses and sensitive
6 perimeters, for example, those which may be adjacent to public rights of way, housing or schools, and within the security-protected area of the
installation to prevent vandalism.
Section 4.3.7. –
7 Storage areas should be located to eliminate or minimise the double handling of wastes within the installation.
Waste Handling, Storage
8 Storage areas should be clearly marked and signed with regard to the quantity and hazardous characteristics of the wastes stored therein.
and Processing
The total maximum storage capacity of the site should be clearly and unambiguously stated in writing, accompanied with details of the method
9 used to calculate the volumes held against this maximum and set out in the site plan. The stated maximum capacity of storage areas should not
be exceeded and the site plan updated to reflect any changes before they are implemented.
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Section 4.3.7. –
All containers should be clearly labelled with the date of arrival, relevant hazard code(s), chemical identity and composition of the waste and a
10 Waste Handling, Storage
unique reference number or code enabling identification through stock control and cross-reference to pre-acceptance and acceptance records.
and Processing
Storage area drainage infrastructure should ensure that all contaminated run-off is contained, that drainage from incompatible wastes cannot
11
come into contact with each other and that fire cannot spread between storage/treatment areas via the drainage system.
Procedures must be in place for the regular inspection and maintenance of storage areas, including drums, vessels, pavements and bunds. Section 4.4. –
Inspections should pay particular attention to signs of damage, deterioration and leakage. Records should be kept detailing action taken. Faults Proposed Infrastructure
12 must be repaired as soon as practicable. If containment capacity or capability of bund, sump or pavement is compromised, (unless effecting a and Drainage
repair is more expedient and working with wastes in close proximity does not compromise safety), then waste must be immediately removed
Arrangements
until the repair is completed.
Section 5.6. – Fugitive
There should be daily inspection of the condition of containers and pallets and written records should be kept of these inspections. If a Emissions to Surface
13 container is found to be damaged, leaking or in a state of deterioration, it should immediately be over-drummed or the contents transferred to Water, Sewer and
another container or processed. Groundwater
15 There should be vehicular, for example, forklift, and pedestrian access at all times to the whole of the storage area.
16 All spillages of hazardous wastes should be logged, where spillages >200 litre then additionally the Regulator should be informed.
Activities that create a clear fire risk should not be carried out within the storage area, even if it is not formally classified as hazardous.
Fire Prevention Plan –
17 Examples include grinding, welding or brazing of metalwork, smoking, parking of normal road vehicles except while unloading, charging of the
ECL.010.02.01/FPP
batteries of fork lift trucks.
Turnover
Section 4.3.7. –
Storage within the reception area should be for a maximum of five working days. Following receipt, wastes should be treated or removed off-
18 Waste Handling, Storage
site as soon as possible. The total storage time will depend upon the characteristics of a particular site and the waste types being stored.
and Processing
Storage of Drummed Waste and other Containerised Wastes such as IBCs
Storage under cover for drummed waste has the advantage of reducing the amount of potentially contaminated water that may be produced in
Section 5.6. –
the event of any spillage and extending the useful life of the container. It is preferable that wastes are stored under cover. This should also
Fugitive Emissions to
19 apply to any container that is held in storage pending sampling and emptied containers. Covered areas must have adequate provision for
Surface Water, Sewer
ventilation by means of wall or roof vents or construction of the area, for example, open barn. Any such warehousing should meet the
and Groundwater
requirements of HSG71 (see Ref 4).
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Storage of Drummed Waste and other Containerised Wastes such as IBCs
20 Containers should be stored in such a manner that leaks and spillages could not escape over bunds/edge of the sealed drainage area. Section 5.6. Fugitive
21 Containers should be stored with well-fitting lids, caps and valves, secured and in place Emissions to Surface
Storage areas for containers holding substances that are known to be sensitive to heat and light or reactive with water or moisture should be Water, Sewer and
22 Groundwater
under cover and protected from water, heat and direct sunlight
Storage areas for containers holding flammable or highly flammable wastes should meet the requirements of HSG 51, HSG71 and HSG76 (see Section 4.3.2. –
23
Ref 4). Waste Storage
Aged Stock
It is important to avoid accumulations of waste, which may in turn lead to deterioration in the container resulting in spillage or, in extreme Fire Prevention Plan
24
cases, the deformation of the container to such an extent that it cannot be moved. ECL.010.02.01/FPP
Segregation
In addition to the requirements of this document, the segregation of wastes should meet the requirements of HSG71 and be justified by risk Section 4.3.2. –
25
assessment. Waste Storage
HSG 71 provides no guidance on the use of fire walls to achieve separation or segregation of different types of waste in outdoor storage. Fire
walls which are impervious to liquid, at least 2m high, and capable of withstanding an intense fire on one side without collapse, can be used to Fire Prevention Plan
26
reduce the 3m separation required for some combinations of materials marked as ‘keep apart’. No more than two sides of a storage area ECL.010.02.01/FPP
should be provided with fire walls, because it would prevent good ventilation.
Storage of Aerosols
Section 4.3.7. –
27 Storage of aerosols should take place under cover in closed containers or cages. Aerosols should not be stored in open containers. Waste Handling,
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Storage of Laboratory Smalls
Written procedures for the segregation and packing of laboratory smalls should be produced identifying:
• how the hazards associated with each package are identified;
• how the risks of adverse reactions occurring between individual packages are assessed, and by whom;
Section 4.3.6. –
• the level of competence, qualification and training required by those undertaking this assessment;
28 Waste Pre-Acceptance
• how incompatible substances (i.e. those that could react to generate heat, fire or hazardous reaction products) are prevented from Arrangements
being stored within the same drum;
• how the wastes are to be packed and stored; and
• how the wastes are to be recovered or disposed.
29 Incompatible substances should not be stored within the same drum.
Section 4.3.6. –
Sorting and repackaging of laboratory smalls should take place in a dedicated area/store. Once the wastes have been sorted according to Waste Acceptance
30 hazard classification, with due consideration for any potential incompatibility problems, and repacked, then these drums should not be stored Arrangements
within the dedicated laboratory smalls area but should be removed to the appropriate storage area.
Compatibility Testing
In order to prevent any adverse or unexpected reactions and releases before transfer involving the following activities, testing should take
place prior to transfer:
• tanker discharge to bulk storage;
31 • tank-to-tank transfer;
• transfer from container to bulk tank;
• bulking into drums/IBCs; and
Section 4.3.8 –
• bulking of solid waste into drums or skips.
Waste Dispatch
Any evolved gases and cause of odour should be identified. If any adverse reaction is observed, an alternative discharge or disposal route
32
should be found.
Transfer from Tanker, Drums and Other Containers in Bulk Storage
Due consideration should be taken of the implications of scale-up from laboratory compatibility testing to bulk transfer and the Guidance is
33
given in HSG143.
34 Wastes in containers should be transferred into storage vessels by dip pipe to minimise splash, fume and odour.
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Transfer from Tanker, Drums and Other Containers in Bulk Storage (Cont.)
Transfer/discharge should only take place after compatibility testing has been completed and then only with the sanction of an appropriate
35 manager. Approval should specify which batch/load of material is to be transferred, the receiving storage vessel, equipment required, including
spillage control and recovery equipment, and any special provisions relevant to that batch/load.
36 During bulking to tankers, vapour balance lines connected to appropriate abatement equipment should be used.
Tankers must not be used as reaction vessels. Blending by bulking into tankers should only take place following a risk assessment and once
37
suitable verification and compatibility testing has been carried out. Section 4.3.8 – Waste
If flammable chemicals are being transferred, particular caution has to be taken to avoid the generation of static electricity, with the Dispatch
38 subsequent risk of ignition. Guidance on the safe use and handling of flammable liquids is provided by the HSE and is contained within HSG140.
There may be other regulatory requirements to consider such as the Dangerous Substances and Explosive Atmospheres Regulations.
A representative sample of the receiving tank/vessel/container should be mixed in a proportional ratio with a sample of incoming waste stream
39 that is proposed to add to the tank/vessel/container. The two samples should take account of the “worst case” scenario of likely constituents.
The particular test parameters will be driven by the wastes being bulked. Records of testing should be kept including the reactions listed.
Bulk Storage Vessels
Bulk storage vessels should be located on an impervious surface that is resistant to material being stored, with sealed construction joints within
44
a bunded area with a capacity of at least 110% of the largest vessel or 25% of the total tankage volume, whichever is greater.
Vessels supporting structures, pipes, hoses and connections should be resistant to the substance (and mix of substances) being stored. There
should be a routine programmed inspection of tanks, mixing and reaction vessels including periodic thickness testing. In the event of damage or
45
significant deterioration, the contents should be transferred to appropriate storage. Inspections carried out by expert staff and written records Section 5.6. –Fugitive
maintained of inspection and remedial action taken. Emissions to Surface
Vessels should not be used beyond the specified design life or used in a manner or for substances that they were not designed. Vessels should Water, Sewer and
46
be inspected at regular intervals, with written records kept to prove that they remain fit for purpose. See HSE Guidance Note PM75. Groundwater
As a general rule, no open topped tanks, vessels or pits should be used for storage or treatment of hazardous or liquid wastes. Exceptions
47
would require justification in the permit application.
48 No uncontrolled venting to atmosphere should be allowed, and all vents should be linked to suitable scrubbing and abatement systems. Vapour
balance lines should be connected to suitable abatement systems.
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No. EPTR Document
Bulk Storage Vessels (Cont.)
Tank and vessel optimum design should be considered in each case, taking into account waste type, storage time, overall tank design and
49
mixing system to prevent sludge accumulation and to ease desludging. Storage and treatment vessels should be regularly desludged.
Tanks and vessels should be equipped with suitable abatement systems and level meters with both audible and visual high level alarms. These
50
systems should be sufficiently robust and regularly maintained to prevent foaming and sludge build up affecting the reliability of the gauges. Section 5.6. –Fugitive
51 Storage vessels holding flammable or highly flammable wastes should meet the requirements of HSG51, HSG716 and HSG176. Emissions to Surface
Water, Sewer and
All connections between vessels must be capable of being closed via suitable valves. Overflow pipes should be directed to a contained drainage
52 Groundwater
system, which may be the relevant bunded area or to another vessel provided suitable control measures are in place.
54 Plant and equipment taken out of use should be decontaminated and removed.
55 Pipework should preferably be routed above ground; if below ground it should be contained within suitable inspection channels.
Tank and Process Pipework Labelling
All vessels should be clearly signed as to their contents and capacity and should have a unique identifier. Tanks should be appropriately
58
labelled.
59 Labelling should differentiate between wastewater and raw process water, combustible liquid and combustible vapour and direction of flow. Section 4.3.7. –
Waste Handling,
61 A suitable pipework coding system should be used, for example, RAL European Standard colour coding.
All valves should be tagged with a unique identifier shown on the process and instrumentation diagram. All connections should be correctly
62
sized and maintained in an undamaged state.
Other Storage Requirements
Waste or raw materials in non-waterproof packaging should be kept under cover. Section 5.6. –Fugitive
Emissions to Surface
63
Water, Sewer and
Groundwater
43
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Container Movement
Drums and other mobile containers should only be moved between different locations (or loaded for removal off-site) in accordance with Section 4.3.9. –
64
written procedures. The waste tracking system should be amended to record these changes. Records
IPPCS5.06, Section 2.1.13 Drum Washing, Crushing, Shredding and Cutting
Empty containers that are in sound condition and free from residual waste should be sent for recondition and re-use. Those drums that are not
1
able to be re-used should be cleaned to facilitate recycling or recovery by other means.
BAT for pre-acceptance criteria, waste characterisation and process control as outlined in earlier BAT should be followed to prevent
2
incompatible reactions from wash waters or residues.
Drums containing flammable and highly flammable wastes and volatile substances that cannot be recovered should be subject to crushing Section 4.3.4. –
3
unless the residues have been removed and the drum cleaned. Waste Treatment
Processing of containers should only be undertaken following written instruction, such as which containers to be processed and type of
4
container to hold residues.
Emissions to air should be controlled with drum crushing and shredding plant fitted with extractive vent system linked to abatement and
5
system should be interlocked so that the plant cannot operate unless the abatement system is working.
BAT techniques for emissions to water include: Section 5.6. –
• keep skips for the storage of crushed/cut drums covered; Fugitive Emissions to
6
• sealed system e.g. chute for containment of residues; and Surface Water, Sewer
• sealed drainage. and Groundwater
BAT for fugitive emissions to air are outlined in Section 2.2.4. of the Guidance Document. Section 5.5. –
7 Fugitive Emissions to
Air
Necessary measures for accident prevention are outlined in Section 2.8 of the Guidance Document. Section 3.4.2. –
8 Implementation and
Operation
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No. EPTR Document
IPPCS5.06, Section 2.2.4, Fugitive Emissions to Air
Dust - The following general techniques should be employed where appropriate:
• covering of skips and vessels
• avoidance of outdoor or uncovered stockpiles (where possible)
• where dust creation is unavoidable, use of sprays, binders, stockpile management techniques, windbreaks and so on
• regular wheel and road cleaning (avoiding transfer of pollution to water and wind blow)
Section 5.5. –Fugitive
1 • closed conveyors, pneumatic or screw conveying (noting the higher energy needs), minimising drops. Filters on the conveyors to Emissions to Air
clean the transport air prior to release
• regular housekeeping
• enclosed silos (for storage of bulk powder materials) vented to fabric filters. The recycling of collected material should be considered
under Section 2.6; and
• enclosed containers or sealed bags used for smaller quantities of fine materials.
For information on odour, see Section 2.2.6. Section 6.2. –Odour
3
Management
IPPCS5.06, Section 2.2.5, Fugitive Emissions to Surface Water, Sewer and Groundwater
For surfacing:
• design appropriate surfacing and containment or drainage facilities for all operational areas, taking into consideration collection Section 4.4. –Proposed
capacities, surface thicknesses, strength/reinforcement; falls, materials of construction, permeability, resistance to chemical attack, Infrastructure and
and inspection and maintenance procedures; Drainage
• have an inspection and maintenance programme for impervious surfaces and containment facilities; and Arrangements
3
• unless the risk is negligible, have improvement plans in place where operational areas have not been equipped with: Section 5.6. – Fugitive
o an impervious surface Emissions to Surface
o spill containment kerbs Water, Foul and
o sealed construction joints Groundwater
o connection to a sealed drainage system.
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IPPCS5.06, Section 2.2.5, Fugitive Emissions to Surface Water, Sewer and Groundwater
All above-ground tanks containing liquids whose spillage could be harmful to the environment should be bunded. Bunds should:
• be impermeable and resistant to the stored materials;
• have no outlet (that is, no drains or taps) and drain to a blind collection point;
Section 4.4. –Proposed
• have pipework routed within bunded areas with no penetration of contained surfaces;
Infrastructure and
• be designed to catch leaks from tanks or fittings; Drainage
• have a capacity greater than 110 percent of the largest tank or 25 percent of the total tankage, whichever is the larger; Arrangements
4
• be subject to regular visual inspection and any contents pumped out or otherwise removed Section 5.6. – Fugitive
• under manual control after checking for contamination; Emissions to Surface
Water, Foul and
• where not frequently inspected, be fitted with a high-level probe and an alarm, as appropriate; Groundwater
• where possible, locate tanker connection points within the bund, otherwise provide adequate containment;
• be subject to programmed engineering inspection (normally visual, but extending to water testing where structural integrity is in
doubt).
IPPCS5.06, Section 2.3., Management
Effective operational and maintenance systems should be employed on all aspects of the process whose failure could impact on the
environment, in particular there should be:
• documented procedures to control operations that may have an adverse impact on the environment;
Section 3.4.2. –
• a defined procedure for identifying, reviewing and prioritising items of plant for which a preventative maintenance regime is
appropriate;
Operation
• documented procedures for monitoring emissions or impacts;
• a preventative maintenance programme covering all plant, whose failure could lead to impact on the environment, including regular
inspection of major ‘non-productive’ items such as tanks, pipework, retaining walls, bunds ducts and filters.
The maintenance system should include auditing of performance against requirements arising from the above and reporting the result of audits Section 3.4.3. –
2
to top management. Check
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IPPCS5.06, Section 2.3., Management
Competence and Training
Training systems, covering the following items, should be in place for all relevant staff which cover:
• awareness of the regulatory implications of the Permit for the activity and their work activities;
3 • awareness of all potential environmental effects from operation under normal and abnormal circumstances
• awareness of the need to report deviation from the Permit; and
Section 3.1 – Technical
• prevention of accidental emissions and action to be taken when accidental emissions occur.
Competence
The skills and competencies necessary for key posts should be documented and records of training needs and training received for these posts Section 3.2. Overview
4
maintained. of EMS
5 The key posts should include contractors and those purchasing equipment and materials;
The potential environmental risks posed by the work of contractors should be assessed and instructions provided to contractors about
6
protecting the environment while working on site.
7 Where industry standards or codes of practice for training exist (e.g. WAMITAB) they should be complied with.
Accidents/Non Conformances
There should be an accident plan which:
8 • identifies the likelihood and consequence of accidents; and
• identifies actions to prevent accidents and mitigate any consequences.
There should be written procedures for handling, investigating, communicating and reporting actual or potential non-compliance with Section 3.4.2. –
operating procedures or emission limits
There should be written procedures for handling, investigating, communicating and reporting environmental complaints and implementation of Operation
10
appropriate actions.
There should be written procedures for investigating incidents, (and near misses) including identifying suitable corrective action and following
11
up.
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IPPCS5.06, Section 2.3., Management (Cont.)
Organisation
The company should adopt an environmental policy and programme which:
• includes a commitment to continual improvement and prevention of pollution; Section 3.3. -
13
• includes a commitment to comply with relevant legislation and other requirements to which the organisation subscribes; and Environmental Policy
• identifies, sets, monitors and reviews environmental objectives and key performance indicators independently of the Permit.
The company should have demonstrable procedures (e.g. written procedures) which incorporate environmental considerations into the
following areas:
• the control of processes and engineering change on the installation;
14
• design, construction and review of new facilities and other capital projects (including provision of decommissioning) Section 3.4.1. – Plan
• capital approval; and Section 3.4.2. –
• purchasing policy. Implementation and
The company should conduct audits, at least annually, to check that all activities are being carried out in conformity with the above Operation
15
requirements. Preferably, these should be independent.
The company should report annually on environmental performance, objectives and targets, and future planned improvements. Preferably,
16
these should be published environmental statements.
The company should operate a formal Environmental Management System. Preferably, this should be registered or certified EMS/ISO 140001 Section 3.2. –
17
system (issued and audited by an accredited certification body). Overview of EMS
The company should have a clear and logical system for keeping records of, amongst others:
• policies;
• roles and responsibilities;
18 • targets; Section 3.4.4. – Check
• procedures;
• results of audits;
• results of reviews.
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IPPCS5.06, Section 2.4., Raw Materials
1 The Operator should maintain a list of raw materials and their properties as noted above.
The Operator should have procedures for the regular review of new developments in raw materials and for the implementation of any suitable
2 Section 9.4 –
ones with an improved environmental profile.
Raw Material
3 The Operator should have quality-assurance procedures for controlling the impurity content of raw materials.
Justification
The Operator should complete any longer-term studies needed into the less polluting options and should make any material substitutions
4
identified.
IPPCS5.06, Section 2.6., Waste Recovery or Disposal
Waste production should be avoided wherever possible. Any waste that is produced should be recovered, unless it is technically or
1
economically impractical to do so.
Where waste must be disposed of, the Operator should provide a detailed assessment identifying the best environmental options for waste Section 9.5. –
2
disposal – unless the Regulator agrees that this is unnecessary. Waste Minimisation
The filter cake arising from the treatment of acidic and alkali solutions and metal precipitation can contain percentage levels of metals such as
3
zinc and copper. Dry solids content should not be less than 15% w/w to facilitate handling.
Contaminated Containers
Most drums and IBC’s are designed, manufactured and marked to enable reconditioning/refurbishment. As such, 250l drums, 800l and 1000l
5
IBCs should be cleaned and reconditioned to enable re-use where technically and economically possible.
Containers that cannot be re-used where there is no reconditioning market and which have been cleaned can be released into the secondary Section 9.5. –
6 Waste Minimisation
materials market.
7 Recovered Oil where it cannot be recycled, utilisation as secondary fuel oil may be acceptable.
IPPCS5.06, Section 2.7., Energy
Basic Energy Requirements (1)
The Operator should provide the energy consumption information, shown in the table on page 86 of IPPC S5.06 Sector Guidance Note, in terms
1
of delivered energy and also, in the case of electricity, converted to primary energy consumption.
Section 9.1. –
The Operator should provide the following Specific Energy Consumption (SEC) information. Define and calculate the SEC of the activity (or
Energy Efficiency
2 activities) based on primary energy consumption for the products or raw material inputs that most closely match the main purpose or
production capacity of the installation. Provide a comparison of SEC against any relevant benchmarks available for the sector.
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IPPCS5.06, Section 2.7., Energy
Basic Energy Requirements (1) (Cont.)
The Operator should provide associated environmental emissions. This is dealt with in the Operator’s response to the emissions inventory using Section 9.1. –
3
the H1 software tool. Energy Efficiency
Basic Energy Requirements (2)
Operating, maintenance and housekeeping measures should be in place in the following areas, where relevant:
• operation of motors and drives;
1 • lubrication to avoid high-friction losses;
• boiler operation and maintenance e.g. optimising excess air; and
• other maintenance relevant to the activities within the installation.
Basic low cost physical techniques should be in place to avoid gross inefficiencies. These should include insulation, containment methods (such Section 9.1. –
2 as seals and self-closing doors) and avoidance of unnecessary discharge of heated water or air (fitting simple control systems such as timers and Energy Efficiency
sensors). Section 9.2. –
3 Energy efficient building services should be in place. Energy Consumption
4 Energy management techniques should be in place, in particular, the need for monitoring of energy flows and targeting of areas for reductions.
An energy efficiency plan should be provided that:
5 • Identifies all techniques relevant to the installation, estimates of CO2 savings that would be achieved by each measure over its lifetime
and in the case that the activities are not covered by CCA or DPA, provides information on the equivalent annual costs of
implementation of the technique, the costs per tonne CO2 saved and the priority for implementation.
Further Energy Efficiency Requirements
The following techniques should be implemented where they are judged to be BAT based on a cost/benefit appraisal according to the
1
methodology provided in Appendix 4 of the Guidance Note H2 Energy Efficiency for IPPC
The listed energy supply techniques should be considered, such as use of combined heat and power, generation of energy from waste or use of
2 Section 9.2. –
less polluting fuels.
Energy Consumption
The Operator should provide justification that the proposed or current situation represents BAT:
3 • the choice of fuel impacts upon emissions other than carbon dioxide, e.g. sulphur dioxide;
• the potential for practical energy recovery from waste conflicts with energy efficiency requirements.
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IPPCS5.06, Section 2.8., Accidents
1 A formal structured accident management plan (“AMP”) should be in place.
The AMP should include: A – Identification of hazards to the environment posed by the installation using a methodology akin to a Hazop study.
Areas to consider include, but should not be limited to, the following:
• arrangements for the receipt, and checking of incoming wastes, including rejection and quarantine;
• arrangements for the storage, segregation and separation of differing waste types;
• procedures for the internal transfers, including “bulking up” of waste materials;
• transfer of substances (e.g. filling or emptying vessels);
• overfilling of vessels;
• emissions from plant or equipment (e.g. leaking from joints, over-pressurisation of vessels, blocked drains);
2
• failure of containment (e.g. physical failure or overfilling of bunds or drainage sumps);
• failure to contain fire waters;
• wrong connections made in drains or other systems;
• incompatible substances allowed to come into contact; Section 3.4.2. –
Implementation and
• unexpected reactions or runaway reactions;
Operation
• failure of main services (e.g. power, steam, cooling water);
• operator error; and
• vandalism.
B – assessment of the risks. The hazards having been identified, the process of assessing the risks should address six basic questions:
1. How likely is the particular event to occur?
2. What substances are released and how much of each?
3 3. Where do the released substances end up?
4. What are the consequences?
5. What are the overall risks?
6. What can prevent or reduce the risk?
The depth and type of assessment will depend on the characteristics of the installation and its location. The main factors to take into account
4 include the scale and nature of hazards, the risks to receptors, the nature of the installation and complexity of activities and the relative
difficulty in deciding and justifying the adequacy of the risk-control technique.
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IPPCS5.06, Section 2.8, Accidents
C - Identification of the techniques necessary to reduce the risks. The listed techniques are relevant to most installations:
• there should be an up to date inventory of substances, present or likely to be present, which could have environmental
consequences if they escape.
• up to date site plan showing the precise location of wastes having specific hazard characteristics with clear identification of the
perimeters of the various designated storage areas and their maximum storage capacity;
• procedures for checking and handling raw materials and wastes to ensure compatibility with other substances;
• storage arrangements for raw materials, products and wastes should be designed and operated to minimise risks to the
environment;
• automatic process controls backed up by manual supervision to minimise the frequency of emergency situations and to maintain
control;
• physical protection should be in place where appropriate;
• appropriate secondary containment;
Section 3.4.2. –
5 • techniques and procedures should be in place to prevent overfilling of tanks; Implementation and
• security systems to prevent unauthorised access; Operation
• formal systems for logging and recording all incidents etc.;
• procedures for responding to and learning from incidents etc.;
• roles and responsibilities to personnel involved in incident management;
• guidance available on how each accident scenarios might be best managed;
• procedures should be in place to avoid incidents occurring as a result of poor communication during maintenance periods;
• safe shutdown should be in place;
• communication channels with emergency services and other relevant authorities should be established and available for use in the
event of an incident. Procedures should be in place to include assessment of harm.
• appropriate control technique should be in place to limit the consequences of an accident, such as fire walls etc.
• personnel training requirements should be identified and training provided;
• the systems for the prevention of fugitive emissions are generally relevant (Section 2.2.4 and Section 2.2.5);
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• duplicate or standby plant should be provided where necessary, with maintenance and testing to the same standards as the main
plant;
• spill contingency procedures should be in place to minimise accidental release and then to prevent their entry into water;
• process waters, potentially contaminated site drainage waters, emergency firewater, chemically-contaminated waters and spillages
should be contained and, where necessary, routed to the effluent system and treated before emission to controlled waters or
sewer. Sufficient storage should be provided to ensure that this can be achieved. Any emergency firewater collection system
should take account of the additional firewater flows and fire-fighting foams, and emergency storage lagoons may be needed to
prevent contaminated firewater reaching controlled waters;
• spillage prevention controls must be in place during the transfer of substances (for example, transfer of bulk liquid waste from
tanker to storage vessels).
o The weakest link and subsequently the main source of spillage during transfer from the vehicle to storage arises from the
transfer hoses. This is due to either:
o “tanker drive-off” - a vehicle pulling away whilst still coupled (systems should be in place to prevent this);
Section 3.4.2. –
o or because the hose couplings have become damaged or are incompatible. Although the spillages tend to be relatively
small, measures should be taken to ensure that the couplings are the correct fit and system. This will prevent the coupling
Operation
loosening or becoming detached, and in turn will also be helped by the installation providing and maintaining its own
hoses;
o A more serious event would occur if the coupling were unable to withstand the maximum shut valve pressure of the
transfer pump;
o Although the volume lost during routine operations due to ill-fitting or damaged hoses may be relatively small, persistent
spillage may have a cumulative effect on the surface of the area, which in the long term may damage the surface and lead
to a fugitive emission;
o spillages of this nature may also be a source of odour (see Section 2.2.6 on page 72) and represent poor “housekeeping”
practice, requiring constant attention and cleaning. Protection of the transfer hose may not be necessary where a gravity
feed system is in place. It will however still be important to maintain a sound coupling at each end of the transfer hose;
and
o a more acute accident situation may arise due to the failure of plant or equipment. This may include the failure of a pump
seal or the blockage of a filter pot commonly used at transfer points. The prevention of these situations should be
addressed by the provision of routine maintenance.
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o A further type of acute incident is associated with the failure of the seal on the road tanker. The prevention of such an
incident is outside the control of the Operator of the installation (though not necessarily beyond that of the company that
operates the installation). Some provision made within the installation for emergency storage for leaking vehicles.
o in addition to accidents connected with some failure in the transfer equipment, measures should be taken to ensure that
the correct waste is discharged to the correct transfer point and that the waste is then transferred to the correct storage
point. In order to prevent an unauthorised discharge, a lockable isolating valve should be fitted to loading connection. It
should be kept locked during periods when there is no supervision of the unloading points.
o drainage from discharge points can be connected or transferred to relevant storage for wastes that have been sampled
and checked.
• unloading/movement of drums and containers: Section 3.4.2. –
5 (cont.) o typically drums and containers are delivered on wooden pallets and the pallets are unloaded by forklift. The drums are Implementation and
usually secured together often by shrink-wrap. All pallets should be sound and undamaged and forklift drivers should be Operation
trained in the handling of palletised goods.
o any damaged pallets should be replaced on arrival and not transferred into storage. Transfer of damaged pallets may lead
to other pallets being stored on top, resulting in further damage and possible collapse of the stack
o adequate space should be provided within drum storage areas and drivers should be adequately trained to minimise
forklift truck damage to the integrity of drums.
• accumulations of liquids in bunds, sumps, etc., should be dealt with promptly.
• such accumulations requiring removal should be analysed to ensure the correct disposal route, for example, pH, COD, heavy metals
and other known contaminants from the spillage.
IPPCS5.06, Section 2.9, Noise
The Operator should employ basic good practice measures for the control of noise, including adequate maintenance of any parts of plant or
1 equipment whose deterioration may give rise to increases in noise (for example, bearings, air handling plant, the building fabric, and specific
noise attenuation kit associated with plant or machinery). Section 6.3. –
The Operator should employ such other noise control techniques necessary to ensure that the noise from the installation does not give rise Noise Management
2 to reasonable cause for annoyance, in the view of the Regulator. In particular, the Operator should justify where Rating Levels (LAeq, T)
from the installation exceed the numerical value of the Background Sound Level (LA90, T).
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IPPCS5.06, Section 2.9, Noise
Further justification will be required should the resulting field rating level (LAR,TR) exceed 50 dB by day and a facade rating level exceed
3
45 dB by night, with day being defined as 07:00 to 23:00 and night 23:00 to 07:00.
In some circumstances “creeping background” (i.e. creeping ambient) may be an issue. Where this has been identified in pre-application
4 discussions or in previous discussions with the local authority, the Operator should employ such noise control techniques as are Section 6.3. –
considered appropriate to minimise problems to an acceptable level with the BAT criteria. Noise Management
Noise surveys, measurements, investigations (e.g. on sound power levels of individual items of plant) or modelling may be necessary for
5 either new or for existing installations, depending upon the potential for noise problems. Where appropriate, the Operator should have a
noise management plan as part of its management system.
IPPCS5.06, Section 2.10 Monitoring
Monitoring should generally be undertaken during all phases of operation (i.e. commissioning, start up, normal operation and shutting Section 8 – Monitoring
1
down) unless the Regulator agrees that it is inappropriate. Section 5.6. –
Monitoring and Reporting of Air Emissions Fugitive Emissions to
Where appropriate, periodic visual and olfactory assessment of releases should be undertaken to ensure that all final releases to air Surface Water, Sewer and
6 Groundwater
should be essentially colourless, free from persistent trailing mist or fume and free from droplets.
Monitoring and Reporting of Waste Emissions
For waste emissions, the following should be monitored and recorded:
• the physical and chemical composition of waste; Section 9.5. –
10
• its hazard characteristics; and Waste Minimisation
• handling precautions and substances with which it cannot be mixed.
Environmental Monitoring (beyond the installation)
The Operator should consider the need for environmental monitoring to assess the effects of emissions to controlled water, groundwater, Section 6 –
1
air or land, or emissions of noise or odour. General Requirements
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IPPCS5.06, Section 2.10 Monitoring (Cont.)

Monitoring of Emissions to Air
Environmental Risk
5 Daily visual monitoring to air for smoke, dust, litter, plumes and daily olfactory odour monitoring Assessment
ECL.010.02.01/ERA
Monitoring of Process Variables
Some process variables may affect the environment and these should be identified and monitored as appropriate – resource use: Section 9.2. –
1
energy consumption. Energy Consumption
IPPCS5.06, Section 2.11 Closure
Operations during the life of the IPPC Permit should not lead to any deterioration of the site if the requirements of the other sections
of this and the specific-sector notes are adhered to. Should any instances arise which have, or might have, impacted on the state of
1 the site, the Operator should record them along with any further investigation or ameliorating work carried out. This will ensure that
there is a coherent record of the state of the site throughout the period of the IPPC Permit. This is as important for the protection of
the Operator as it is for the protection of the environment. Any changes to this record should be submitted to the Regulator. Section 3.4.1. – Plan
Care should be taken at the design stage to minimise risks during decommissioning. For existing installations, where potential
2
problems are identified, a programme of improvements should be put in place to a timescale agreed with the Regulator.
A site closure plan should be maintained to demonstrate that, in its current state, the installation can be decommissioned to avoid
3
any pollution risk and return the site of operation to a satisfactory state. The plan should be kept updated as material changes occur.
IPCC S5.06, Section 4.2. The Waste Management Licensing Regulations
In relation to activities involving the disposal or recovery of waste, the Regulators are required to discharge their functions in
1
accordance with the relevant objectives as set out in Schedule 4 of the Waste Management Licensing Regulations 1994.
Objectives are as follows: Section 4.3.7. Waste
• Ensuring the waste is recovered or disposed of without endangering human health and without using process or methods Handling, Storage and
2 which could harm the environment and in particular without risk to water, air, soil, plants or animals or causing nuisance Processing
through noise or odours or adversely affecting the countryside or places of special interest;
• Implementing, as far as material, any plan made under the plan-making provisions
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IPCC S5.06, Section 4.2. The Waste Management Licensing Regulations (Cont.)
Operators should identify any development plans made by the local planning authority, including any waste local plan and Waste Strategy
3 Section 2.2. – Planning
2000 commenting on the extent to which the proposals accord with the contents of any such plan.
IPCC S5.06, Section 4.3. The Habitats Regulations
Operators should provide an initial assessment of whether the installation is likely to have a significant effect on any European site in the
UK (either alone or in combination with other relevant plans or projects) and, if so, an initial assessment of the implications of the
1 installation for any such site. The application of BAT is likely to have gone some way towards addressing the potential impact of the
installation on European sites and putting into place techniques to avoid any significant effects. The Operator should provide a description
of how the BAT assessment has specifically taken these matters into account, bearing in mind the conservation objectives of any such site.
European sites are defined in Regulation 10 of the Habitats Regulations to include Special Areas of Conservation (SACs); sites of
Environmental Risk
community importance (sites that have been selected as candidate SACs by member states and adopted by the European Commission, but
2 Assessment
which are not yet formally classified); and Special Protection Areas (SPAs). It is also Government policy (set out in PPG 9 on nature
ECL.010.02.01/ERA
conservation) that potential SPAs and candidate SACs should be considered to be European sites for the purposes of Regulation 10.
The Regulator will need to consider the Operator's initial assessment. If it concludes that the installation is likely to have a significant
effect on a European site, then the Regulator will need to carry out an “appropriate assessment” of the implications of the installation in
4 view of that site's conservation objectives. The Regulations impose a duty on the Regulator to carry out these assessments, so it cannot
rely on the Operator's initial assessments. Therefore the Regulator must be provided with any relevant information upon which the
Operator’s assessment is based.
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APPENDIX I
PROPOSED WASTE CODES AND
STORAGE ARRANGEMENTS DOCUMENT

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COMBUSTIBLE-C
NON COMBUSTIBLE-N
CODE AND DESCRIPTION POSSIBLY COMBUSTIBLE P WASTE TYPE STORAGE LOCATION
02 01 Wastes from agriculture, horticulture, aquaculture, forestry, hunting and fishing,food preparation and processing
02 01 08* M Agrochemical waste containing dangerous substances C MISC 8 & 10
02 01 09 Agrochemical waste other than those mentioned in 02 01 08 C MISC 8 & 10
02 02 Wastes from the preparation and processing of meat, fish and other foods of animal origin
02 02 03 Materials unsuitable for consumption or processing C MISC 8 & 10
02 03 Wastes from fruit, vegetables, cereals, edible oils, cocoa, coffee, tea and tobacco preparation and processing; conserve production; yeast and yeast
extract production, molasses preparation and fermentation
02 03 02 Wastes from preserving agents P MISC 8 & 10
02 03 03 Wastes from solvent extraction P MISC 8 & 10
02 03 05 Sludges from on-site effluent treatment C SLUDGE 8 & 10
02 05 Wastes from the dairy products industry

02 06 Wastes from the baking and confectionery industry

02 06 02 Wastes from preserving agents P MISC 8 & 10
02 07 Wastes from the production of alcoholic and non-alcoholic beverages (except coffee, tea and cocoa)
02 07 02 Wastes from spirits distillation C MISC 8 & 10
02 07 03 Wastes from chemical treatment C MISC 8 & 10
03 02 Wastes from wood preservation

03 02 01* A Non-halogenated organic wood preservatives N LIQUID 1 TO 4
03 02 02* A Organochlorinated wood preservatives N LIQUID 1 TO 4
03 02 03* A Organometallic wood preservatives N LIQUID 1 TO 4
03 02 04* A Inorganic wood preservatives N LIQUID 1 TO 4
03 02 05* M Other wood preservatives containing dangerous substances N LIQUID 1 TO 4
03 02 99 Wood preservatives not otherwise specified N LIQUID 1 TO 4
03 03 Wastes from pulp, paper and cardboard production and processing

03 03 02 Green liquor sludge (from recovery of cooking liquor) C SLUDGE 8 & 10
03 03 05 De-inking sludges from paper recycling C SLUDGE 8 & 10
03 03 11 Sludges from on-site effluent treatment other than those mentioned in 03 03 10 C SLUDGE 8 & 10
04 01 Wastes from the leather, fur and textile industries

04 01 03* M Degreasing wastes containing solvents without a liquid phase C SLUDGE 8 & 10
04 01 04 Tanning liquor containing chromium N LIQUID 1 TO 4
04 01 05 Tanning liquor free of chromium P LIQUID 8 & 10
04 01 06 Sludges, in particular from on-site effluent treatment containing chromium P SLUDGE 8 & 10
04 01 07 Sludges, in particular from on-site effluent treatment free of chromium C SLUDGE 8 & 10
04 01 08 Waste tanned leather (blue sheetings, shavings, cuttings, buffing dust) containing chromium C SOLID 8 & 10
04 02 Wastes from the textile industry

04 02 09 Wastes from composite materials (impregnated textile, elastomer, plastomer) C SOLID 8 & 10
04 02 10 Organic matter from natural products (for example grease, wax) C SOLID 8 & 10
04 02 14* M Wastes from finishing containing organic solvents C MISC 8 & 10
04 02 15 Wastes from finishing other than those mentioned in 04 02 14 C MISC 8 & 10
04 02 16* M Dyestuffs and pigments containing dangerous substances C LIQUID 8 & 10
04 02 17 Dyestuffs and pigments other than those mentioned in 04 02 16 C LIQUID 8 & 10
04 02 19* M Sludges from on-site effluent treatment containing dangerous substances C LIQUID 8 & 10
04 02 20 Sludges from on-site effluent treatment other than those mentioned in C SLUDGE 8 & 10
06 01 wastes from the manufacture, formulation, supply and use (MFSU) of acids
06 01 01* sulphuric acid and sulphurous acid N LIQUID 1 TO 4
06 01 02* hydrochloric acid N LIQUID 1 TO 4
06 01 03* hydrofluoric acid N LIQUID 1 TO 4
06 01 04* phosphoric and phosphorous acid N LIQUID 1 TO 4
06 01 05* nitric acid and nitrous acid N LIQUID 1 TO 4
06 01 06* other acids N LIQUID 1 TO 4
06 02 wastes from the MFSU of bases

06 02 01* calcium hydroxide N LIQUID / SOLID 1 TO 4
06 02 03* ammonium hydroxide N LIQUID / SOLID 1 TO 4
06 02 04* sodium and potassium hydroxide N LIQUID / SOLID 1 TO 4
06 02 05* other bases N LIQUID / SOLID 1 TO 4
06 03 wastes from the MFSU of salts and their solutions and metallic oxides
06 03 11* solid salts and solutions containing cyanides N SOLID 1 TO 4
06 03 13* solid salts and solutions containing heavy metals N SOLID 1 TO 4
06 03 14 solid salts and solutions other than those mentioned in 06 03 11 and 06 03 13 N SOLID 1 TO 4
06 03 15* metallic oxides containing heavy metals N LIQUID / SOLID 1 TO 4
06 03 16 metallic oxides other than those mentioned in 06 03 15 N LIQUID / SOLID 1 TO 4
06 04 metal-containing wastes other than those mentioned in 06 03

06 04 03* wastes containing arsenic N MISC 1 TO 4
06 04 04* wastes containing mercury N MISC 1 TO 4
06 04 05* wastes containing other heavy metals N MISC 1 TO 4
06 05 sludges from on-site effluent treatment

06 05 02* sludges from on-site effluent treatment containing hazardous substances N SLUDGE 1 TO 4
06 05 03 sludges from on-site effluent treatment other than those mentioned in 06 05 02 N SLUDGE 1 TO 4
06 08 wastes from the MFSU of silicon and silicon derivatives

06 08 02* wastes containing hazardous chlorosilanes N LIQUID / SOLID 1 TO 4
06 09 wastes from the MSFU of phosphorous chemicals and phosphorous chemical processes
06 09 02 phosphorous slag N SOLID 1 TO 4
06 09 03* calcium-based reaction wastes containing or contaminated with hazardous substances N LIQUID / SOLID 1 TO 4
06 10 wastes from the MFSU of nitrogen chemicals, nitrogen chemical processes and fertiliser manufacture
06 10 02* wastes containing hazardous substances P MISC 8 & 10
06 11 wastes from the manufacture of inorganic pigments and opacificiers

06 11 01 calcium-based reaction wastes from titanium dioxide production N MISC 1 TO 4
06 13 wastes from inorganic chemical processes not otherwise specified

06 13 01 inorganic plant protection products, wood-preserving agents and other biocides. N LIQUID 1 TO 4
07 01 wastes from the manufacture, formulation, supply and use (MFSU) of basic organic chemicals
07 01 01 aqueous washing liquids and mother liquors N LIQUID 1 TO 4
07 01 03 organic halogenated solvents, washing liquids and mother liquors P LIQUID 8 & 10
07 01 04 other organic solvents, washing liquids and mother liquors P LIQUID 8 & 10
07 01 07 halogenated still bottoms and reaction residues N SOLID 1 TO 4
07 01 08 other still bottoms and reaction residues N SOLID 1 TO 4
07 01 09 halogenated filter cakes and spent absorbents N FILTER CAKE 1 TO 4
07 01 10 other filter cakes and spent absorbents N FILTER CAKE 1 TO 4
07 01 11 sludges from on-site effluent treatment containing hazardous substances P SLUDGE 8 & 10
07 01 12 sludges from on-site effluent treatment other than those mentioned in 07 01 11 P SLUDGE 8 & 10
07 02 wastes from the MFSU of plastics, synthetic rubber and man-made fibres
07 02 01* aqueous washing liquids and mother liquors N LIQUID 1 TO 4
07 02 03* organic halogenated solvents, washing liquids and mother liquors P LIQUID 8 & 10
07 02 04* other organic solvents, washing liquids and mother liquors P LIQUID 8 & 10
07 02 07* halogenated still bottoms and reaction residues N SOLID 1 TO 4
07 02 08* other still bottoms and reaction residues N SOLID 1 TO 4
07 02 09* halogenated filter cakes and spent absorbents N FILTER CAKE 1 TO 4
07 02 10* other filter cakes and spent absorbents N FILTER CAKE 1 TO 4
07 02 11* sludges from on-site effluent treatment containing hazardous substances P SLUDGE 8 & 10
07 02 13 waste plastic C SOLID 8 & 10
07 02 14* wastes from additives containing hazardous substances P MISC 8 & 10
07 02 15 wastes from additives other than those mentioned in 07 02 14 P MISC 8 & 10
07 02 16* wastes containing hazardous silicones N MISC 1 TO 4
07 02 17 wastes containing silicones other than those mentioned in 07 02 16 N MISC 1 TO 4
07 03 wastes from the MFSU of organic dyes and pigments (except 06 11)
07 04 wastes from the MFSU of organic plant protection products (except 02 01 08 and 02 01 09), wood preserving agents (except 03 02) and other
biocides
07 04 13* solid wastes containing hazardous substances P SOLID 8 & 10
07 05 wastes from the MFSU of pharmaceuticals

07 05 13* solid wastes containing hazardous substances P SOLID 8 & 10
07 05 14 solid wastes other than those mentioned in 07 05 13 P SOLID 8 & 10
07 06 wastes from the MFSU of fats, grease, soaps, detergents, disinfectants and cosmetics
07 07 wastes from the MFSU of fine chemicals and chemical products not otherwise specified
07 07 11 *sludges from on-site effluent treatment containing hazardous substances P SLUDGE 8 & 10
08 01 wastes from MFSU and removal of paint and varnish

08 01 11* waste paint and varnish containing organic solvents or other hazardous substances C MISC 8 & 10
08 01 12 waste paint and varnish other than those mentioned in 08 01 11 C MISC 8 & 10
08 01 13* sludges from paint or varnish containing organic solvents or other hazardous substances C SLUDGE 8 & 10
08 01 14 sludges from paint or varnish other than those mentioned in 08 01 13 C SLUDGE 8 & 10
08 01 15* aqueous sludges containing paint or varnish containing organic solvents or other hazardous substances C SLUDGE 8 & 10
08 01 16 aqueous sludges containing paint or varnish other than those mentioned in 08 01 15 C SLUDGE 8 & 10
08 01 17* wastes from paint or varnish removal containing organic solvents or other hazardous substances C MISC 8 & 10
08 01 18 wastes from paint or varnish removal other than those mentioned in 08 01 17 N MISC 1 TO 4
08 01 19* aqueous suspensions containing paint or varnish containing organic solvents or other hazardous substances C LIQUID 8 & 10
08 01 20 aqueous suspensions containing paint or varnish other than those mentioned in 08 01 19 N LIQUID 1 TO 4
08 01 21* waste paint or varnish remover C MISC 8 & 10
08 02 wastes from MFSU of other coatings (including ceramic materials)

08 02 01 waste coating powders N SOLID 1 TO 4
08 02 02 aqueous sludges containing ceramic materials N SLUDGE 1 TO 4
08 02 03 aqueous suspensions containing ceramic materials N LIQUID 1 TO 4
08 03 wastes from MFSU of printing inks

08 03 07 aqueous sludges containing ink N SLUDGE 1 TO 4
08 03 08 aqueous liquid waste containing ink N LIQUID 1 TO 4
08 03 12* waste ink containing hazardous substances N LIQUID 1 TO 4
08 03 13 waste ink other than those mentioned in 08 03 12 N LIQUID 1 TO 4
08 03 14* ink sludges containing hazardous substances N SLUDGE 1 TO 4
08 03 15 ink sludges other than those mentioned in 08 03 14 N SLUDGE 1 TO 4
08 03 16* waste etching solutions N LIQUID 1 TO 4
08 03 17* waste printing toner containing hazardous substances N SOLID 1 TO 4
08 03 18 waste printing toner other than those mentioned in 08 03 17 N SOLID 1 TO 4
08 03 19* disperse oil P LIQUID 8 & 10
08 04 wastes from MFSU of adhesives and sealants (including waterproofing products)

08 04 09* waste adhesives and sealants containing organic solvents or other hazardous substances P MISC 8 & 10
08 04 10 waste adhesives and sealants other than those mentioned in 08 04 09 P MISC 8 & 10
08 04 11* adhesive and sealant sludges containing organic solvents or other hazardous substances P MISC 8 & 10
08 04 12 adhesive and sealant sludges other than those mentioned in 08 04 11 P SLUDGE 8 & 10
08 04 13* aqueous sludges containing adhesives or sealants containing organic solvents or other hazardous substances N SLUDGE 1 TO 4
08 04 14 aqueous sludges containing adhesives or sealants other than those mentioned in 08 04 13 N SLUDGE 1 TO 4
08 04 15* aqueous liquid waste containing adhesives or sealants containing organic solvents or other hazardous substances N LIQUID 1 TO 4
08 04 16 aqueous liquid waste containing adhesives or sealants other than those mentioned in 08 04 15 N LIQUID 1 TO 4
08 04 17* rosin oil C LIQUID 8 & 10
08 05 wastes not otherwise specified in 08

08 05 01* waste isocyanates P MISC 8 & 10
10 01 wastes from power stations and other combustion plants (except 19 )
10 01 04* oil fly ash and boiler dust C DUST 8 & 10
10 01 09* sulphuric acid N LIQUID 1 TO 4
10 01 13* fly ash from emulsified hydrocarbons used as fuel C DUST 8 & 10
10 01 14* bottom ash, slag and boiler dust from co-incineration containing hazardous substances N DUST 1 TO 4
10 01 16* fly ash from co-incineration containing hazardous substances N DUST 1 TO 4
10 01 18* wastes from gas cleaning containing hazardous substances N MISC 1 TO 4
10 01 22* aqueous sludges from boiler cleansing containing hazardous substances N SLUDGE 1 TO 4
10 01 25 wastes from fuel storage and preparation of coal-fired power plants N MISC 1 TO 4
10 01 26 wastes from cooling-water treatment N LIQUID 1 TO 4
10 08 wastes from other non-ferrous thermal metallurgy

10 08 08* salt slag from primary and secondary production P SOLID 8 & 10
10 08 10* dross and skimmings that are flammable or emit, upon contact with water, flammable gases in hazardous quantities P SOLID 8 & 10
10 08 12* tar-containing wastes from anode manufacture P SOLID 8 & 10
10 08 15* flue-gas dust containing hazardous substances P DUST 8 & 10
10 08 17* sludges and filter cakes from flue-gas treatment containing hazardous substances P SLUDGE 8 & 10
10 08 19* wastes from cooling-water treatment containing oil P LIQUID / SOLID 8 & 10
10 09 wastes from casting of ferrous pieces

10 09 11* other particulates containing hazardous substances P DUST 8 & 10
10 09 13* waste binders containing hazardous substances P SOLID 8 & 10
10 09 14 waste binders other than those mentioned in 10 09 13 P SOLID 8 & 10
10 09 15* waste crack-indicating agent containing hazardous substances P LIQUID 8 & 10
10 09 16 waste crack-indicating agent other than those mentioned in 10 09 15 P LIQUID 8 & 10
10 10 wastes from casting of non-ferrous pieces

10 10 11* other particulates containing hazardous substances P DUST 8 & 10
10 10 13* waste binders containing hazardous substances P SOLID 8 & 10
10 10 14 waste binders other than those mentioned in 10 10 13 P SOLID 8 & 10
10 10 15* waste crack-indicating agent containing hazardous substances P LIQUID 8 & 10
10 10 16 waste crack-indicating agent other than those mentioned in 10 10 15 P LIQUID 8 & 10
10 11 wastes from manufacture of glass and glass products

10 11 09* waste preparation mixture before thermal processing, containing hazardous substances N MISC 1 TO 4
10 11 11* waste glass in small particles and glass powder containing heavy metals (for example from cathode ray tubes) N DUST 1 TO 4
10 11 13* glass-polishing and -grinding sludge containing hazardous substances N SLUDGE 1 TO 4
10 11 15* solid wastes from flue-gas treatment containing hazardous substances N SOLID 1 TO 4
10 11 17* sludges and filter cakes from flue-gas treatment containing hazardous substances N SLUDGE 1 TO 4
10 11 19* solid wastes from on-site effluent treatment containing hazardous substances N SOLID 1 TO 4
10 12 wastes from manufacture of ceramic goods, bricks, tiles and construction products
10 12 01 waste preparation mixture before thermal processing N MISC 1 TO 4
10 12 03 particulates and dust N DUST 1 TO 4
10 12 08 waste ceramics, bricks, tiles and construction products (after thermal processing) N SOLID 1 TO 4
10 12 09* solid wastes from gas treatment containing hazardous substances N SOLID 1 TO 4
10 12 11* wastes from glazing containing heavy metals N SOLID 1 TO 4
10 12 13 sludge from on-site effluent treatment N SLUDGE 1 TO 4
10 13 wastes from manufacture of cement, lime and plaster and articles and products made from them
10 13 12* solid wastes from gas treatment containing hazardous substances N SOLID 1 TO 4
10 13 13 solid wastes from gas treatment other than those mentioned in 10 13 12 N SOLID 1 TO 4
10 14 waste from crematoria

10 14 01* waste from gas cleaning containing mercury P DUST 8 & 10
11 01 wastes from chemical surface treatment and coating of metals and other materials (for example galvanic processes, zinc coating processes, pickling
processes, etching, phosphating, alkaline degreasing, anodising)
11 01 05 pickling acids* N LIQUID 1 TO 4
11 01 06 acids not otherwise specified* N LIQUID 1 TO 4
11 01 07 pickling bases* N LIQUID 1 TO 4
11 01 08 phosphatising sludges N LIQUID 1 TO 4
11 01 09* sludges and filter cakes containing hazardous substances N SLUDGE 1 TO 4
11 01 10 sludges and filter cakes other than those mentioned in 11 01 09 N SLUDGE 1 TO 4
11 01 11* aqueous rinsing liquids containing hazardous substances N LIQUID 1 TO 4
11 01 12 aqueous rinsing liquids other than those mentioned in 11 01 11 N LIQUID 1 TO 4
11 01 13* degreasing wastes containing hazardous substances N LIQUID 1 TO 4
11 01 14 degreasing wastes other than those mentioned in 11 01 13 N LIQUID 1 TO 4
11 01 15* eluate and sludges from membrane systems or ion exchange systems containing hazardous substances N MISC 1 TO 4
11 01 16 saturated or spent ion exchange resins N SLUDGE 1 TO 4
11 01 98* other wastes containing hazardous substances N MISC 1 TO 4
11 02 wastes from non-ferrous hydrometallurgical processes

11 02 02* sludges from zinc hydrometallurgy (including jarosite, goethite) N SLUDGE 1 TO 4
11 02 03 wastes from the production of anodes for aqueous electrolytical processes N MISC 1 TO 4
11 02 05* wastes from copper hydrometallurgical processes containing hazardous substances N MISC 1 TO 4
11 02 06 wastes from copper hydrometallurgical processes other than those mentioned in 11 02 05 N MISC 1 TO 4
11 02 07* other wastes containing hazardous substances N MISC 1 TO 4
11 03 sludges and solids from tempering processes

11 03 01* wastes containing cyanide N MISC 1 TO 4
11 03 02* other waste N MISC 1 TO 4
11 05 wastes from hot galvanising processes

11 05 01 hard zinc N SOLID 1 TO 4
11 05 02 zinc ash N DUST 1 TO 4
11 05 03* solid wastes from gas treatment N SOLID 1 TO 4
11 05 04* spent flux N SOLID 1 TO 4
12 01 wastes from shaping and physical and mechanical surface treatment of metals and plastics
12 01 06* mineral-based machining oils containing halogens (except emulsions and solutions) C LIQUID 8 & 10
12 01 07* mineral-based machining oils free of halogens (except emulsions and solutions) C LIQUID 8 & 10
12 01 08* machining emulsions and solutions containing halogens C LIQUID 8 & 10
12 01 09* machining emulsions and solutions free of halogens C LIQUID 8 & 10
12 01 10* synthetic machining oils C LIQUID 8 & 10
12 01 12* spent waxes and fats C SOLID 8 & 10
12 01 13 welding wastes C SOLID 8 & 10
12 01 14* machining sludges containing hazardous substances P SLUDGE 8 & 10
12 01 15 machining sludges other than those mentioned in 12 01 14 P SLUDGE 8 & 10
12 01 16* waste blasting material containing hazardous substances P DUST 8 & 10
12 01 17 waste blasting material other than those mentioned in 12 01 16 P DUST 8 & 10
12 01 18* metal sludge (grinding, honing and lapping sludge) containing oil C SLUDGE 8 & 10
12 01 19* readily biodegradable machining oil C LIQUID 8 & 10
12 01 20* spent grinding bodies and grinding materials containing hazardous substances P DUST 8 & 10
12 01 21 spent grinding bodies and grinding materials other than those mentioned in 12 01 20 P DUST 8 & 10
13 01 waste hydraulic oils
13 01 01* hydraulic oils, containing PCBs C LIQUID 8 & 10
13 01 04* chlorinated emulsions C LIQUID 8 & 10
13 01 05* non-chlorinated emulsions C LIQUID 8 & 10
13 01 09* mineral-based chlorinated hydraulic oils C LIQUID 8 & 10
13 01 10* mineral based non-chlorinated hydraulic oils C LIQUID 8 & 10
13 01 11* synthetic hydraulic oils C LIQUID 8 & 10
13 01 12* readily biodegradable hydraulic oils C LIQUID 8 & 10
13 01 13* other hydraulic oils C LIQUID 8 & 10
13 02 waste engine, gear and lubricating oils

13 02 04* mineral-based chlorinated engine, gear and lubricating oils C LIQUID 8 & 10
13 02 05* mineral-based non-chlorinated engine, gear and lubricating oils C LIQUID 8 & 10
13 02 06* synthetic engine, gear and lubricating oils C LIQUID 8 & 10
13 02 07* readily biodegradable engine, gear and lubricating oils C LIQUID 8 & 10
13 02 08* other engine, gear and lubricating oils C LIQUID 8 & 10
13 03 waste insulating and heat transmission oils

13 03 01* insulating or heat transmission oils containing PCBs C LIQUID 8 & 10
13 03 06* mineral-based chlorinated insulating and heat transmission oils other than those mentioned in 13 03 01 C LIQUID 8 & 10
13 03 07* mineral-based non-chlorinated insulating and heat transmission oils C LIQUID 8 & 10
13 03 08* synthetic insulating and heat transmission oils C LIQUID 8 & 10
13 03 09* readily biodegradable insulating and heat transmission oils C LIQUID 8 & 10
13 03 10* other insulating and heat transmission oils C LIQUID 8 & 10
13 05 oil/water separator contents

13 05 01* solids from grit chambers and oil/water separators C SOLID 8 & 10
13 05 02* sludges from oil/water separators P SLUDGE 8 & 10
13 05 03* interceptor sludges P SLUDGE 8 & 10
13 05 06* oil from oil/water separators C LIQUID 8 & 10
13 05 07* oily water from oil/water separators P LIQUID 8 & 10
13 05 08* mixtures of wastes from grit chambers and oil/water separators P MISC 8 & 10
13 07 wastes of liquid fuels

13 07 01* fuel oil and diesel C LIQUID 8 & 10
13 07 03* other fuels (including mixtures) C LIQUID 8 & 10
13 08 oil wastes not otherwise specified

13 08 02* other emulsions P LIQUID 8 & 10
14 06 waste organic solvents, refrigerants and foam/aerosol propellants

14 06 01* chlorofluorocarbons, HCFC, HFC P SOLID 8 & 10
14 06 02* other halogenated solvents and solvent mixtures P LIQUID 8 & 10
14 06 03* other solvents and solvent mixtures P LIQUID 8 & 10
14 06 04* sludges or solid wastes containing halogenated solvents P SLUDGE 8 & 10
14 06 05* sludges or solid wastes containing other solvents P SLUDGE 8 & 10
15 01 packaging (including separately collected municipal packaging waste)

15 01 02 plastic packaging C EMPTY PACKAGING 7
15 01 04 metallic packaging P EMPTY PACKAGING 7
15 01 05 composite packaging Y EMPTY PACKAGING 7
15 01 10* packaging containing residues of or contaminated by hazardous substances C EMPTY PACKAGING 7
15 01 11* metallic packaging containing a hazardous solid porous matrix (for example asbestos), including empty pressure containers P EMPTY PACKAGING 7
15 02 absorbents, filter materials, wiping cloths and protective clothing
NON HAZ
15 02 02* absorbents, filter materials (including oil filters not otherwise specified), wiping cloths, protective clothing contaminated by hazardous substances ABSORBENTS /
C TEXTILES / FILTERS 8 & 10
HAZ ABSORBENTS /
15 02 03 absorbents, filter materials, wiping cloths and protective clothing other than those mentioned in 15 02 02
C TEXTILES / FILTERS 8 & 10
16 01 end-of-life vehicles from different means of transport (including off-road machinery) and wastes from dismantling of end-of-life vehicles and
vehicle maintenance (except 13, 14, 16 06 and 16 08)
16 01 07* oil filters C SOLID 8 & 10
16 01 08* components containing mercury P SOLID 8 & 10
16 01 09* components containing PCBs C SOLID 8 & 10
16 01 13* brake fluids C LIQUID 8 & 10
16 01 14* antifreeze fluids containing hazardous substances P LIQUID 8 & 10
16 01 15 antifreeze fluids other than those mentioned in 16 01 14 P LIQUID 8 & 10
16 01 21 *hazardous components other than those mentioned in 16 01 07 to 16 01 11 and 16 01 13 and 16 01 14 P SOLID 8 & 10
16 02 wastes from electrical and electronic equipment

16 02 09* transformers and capacitors containing PCBs C WEEE HAZ WEEE STORE
16 02 10* discarded equipment containing or contaminated by PCBs other than those mentioned in 16 02 09 C WEEE HAZ WEEE STORE
16 02 11* discarded equipment containing chlorofluorocarbons, HCFC, HFC C WEEE HAZ WEEE STORE
16 02 13* discarded equipment containing hazardous components other than those mentioned in 16 02 09 to 16 02 12 C WEEE HAZ WEEE STORE
16 02 14 discarded equipment other than those mentioned in 16 02 09 to 16 02 13 C WEEE NON HAZ WEEE STORE
16 02 15* hazardous components removed from discarded equipment C WEEE HAZ WEEE STORE
16 02 16 components removed from discarded equipment other than those mentioned in 16 02 15 C WEEE NON HAZ WEEE STORE
16 03 off-specification batches and unused products

16 03 03* inorganic wastes containing hazardous substances P MISC 8 & 10
16 03 04 inorganic wastes other than those mentioned in 16 03 03 P MISC 8 & 10
16 03 05* organic wastes containing hazardous substances P MISC 8 & 10
16 03 06 organic wastes other than those mentioned in 16 03 05 P MISC 8 & 10
16 03 07* metallic mercury N LIQUID 1 TO 4
16 05 gases in pressure containers and discarded chemicals

16 05 04* gases in pressure containers (including halons) containing hazardous substances P GAS 9
16 05 05 gases in pressure containers other than those mentioned in 16 05 04 P GAS 9
16 05 06* laboratory chemicals, consisting of or containing hazardous substances, including mixtures of laboratory chemicals P MISC 9
16 05 07* discarded inorganic chemicals consisting of or containing hazardous substances P MISC 9
16 05 08* discarded organic chemicals consisting of or containing hazardous substances P MISC 9
16 05 09 discarded chemicals other than those mentioned in 16 05 06, 16 05 07 or 16 05 08 P MISC 9
16 06 batteries and accumulators

16 06 01* lead batteries P BATTERY BATTERY STORE
16 06 02* Ni-Cd batteries P BATTERY BATTERY STORE
16 06 03* mercury-containing batteries P BATTERY BATTERY STORE
16 06 04 alkaline batteries (except 16 06 03) P BATTERY BATTERY STORE
16 06 05 other batteries and accumulators P BATTERY BATTERY STORE
16 06 06* separately collected electrolyte from batteries and accumulators P LIQUID / SOLID 8 & 10
16 07 wastes from transport tank, storage tank and barrel cleaning (except 05 and 13)
16 07 08* wastes containing oil C MISC 8 & 10
16 07 09* wastes containing other hazardous substances P MISC 8 & 10
16 08 spent catalysts
16 08 01 spent catalysts containing gold, silver, rhenium, rhodium, palladium, iridium or platinum (except 16 08 07) N SOLID 1 TO 4
16 08 02* spent catalysts containing hazardous transition metals or hazardous transition metal compounds C SOLID 8 & 10
16 08 03 spent catalysts containing transition metals or transition metal compounds not otherwise specified C SOLID 8 & 10
16 08 04 spent fluid catalytic cracking catalysts (except 16 08 07) N LIQUID 1 TO 4
16 08 05* spent catalysts containing phosphoric acid N LIQUID 1 TO 4
16 08 06* spent liquids used as catalysts N LIQUID 1 TO 4
16 08 07* spent catalysts contaminated with hazardous substances P LIQUID 8 & 10
16 09 oxidising substances
16 09 01* permanganates, for example potassium permanganate N LIQUID / SOLID OXIDISING SOLIDS / LIQUIDS STORES
16 09 02* chromates, for example potassium chromate, potassium or sodium dichromate N LIQUID / SOLID OXIDISING SOLIDS / LIQUIDS STORES
16 09 03* peroxides, for example hydrogen peroxide N LIQUID OXIDISING SOLIDS / LIQUIDS STORES
16 09 04* oxidising substances, not otherwise specified N LIQUID / SOLID OXIDISING SOLIDS / LIQUIDS STORES
16 10 aqueous liquid wastes destined for off-site treatment

16 10 01* aqueous liquid wastes containing hazardous substances N LIQUID 1 TO 4
16 10 02 aqueous liquid wastes other than those mentioned in 16 10 01 N LIQUID 1 TO 4
16 10 03* aqueous concentrates containing hazardous substances N LIQUID 1 TO 4
16 10 04 aqueous concentrates other than those mentioned in 16 10 03 N LIQUID 1 TO 4
17 06 insulation materials and asbestos-containing construction materials

17 06 01* insulation materials containing asbestos N SOLID 1 TO 4
17 06 03* other insulation materials consisting of or containing hazardous substances P SOLID 8 & 10
17 06 04 insulation materials other than those mentioned in 17 06 01 and 17 06 03 P SOLID 8 & 10
17 06 05* construction materials containing asbestos N SOLID 1 TO 4
17 09 other construction and demolition wastes

17 09 02* construction and demolition wastes containing PCB (for example PCB-containing sealants, PCB-containing resin-based floorings, PCB-containing
sealed glazing units, PCB-containing capacitors) C MISC 8 & 10
17 09 03* other construction and demolition wastes (including mixed wastes) containing hazardous substances P MISC 8 & 10
20 MUNICIPAL WASTES (HOUSEHOLD WASTE AND SIMILAR COMMERCIAL, INDUSTRIAL AND INSTITUTIONAL WASTES) INCLUDING SEPARATELY
COLLECTED FRACTIONS
20 01 separately collected fractions (except 15 01)
20 01 13* solvents C LIQUID 8 & 10
20 01 14* acids- N LIQUID / SOLID 1 TO 4
20 01 15* alkalines N LIQUID / SOLID 1 TO 4
20 01 17* photochemicals P LIQUID 8 & 10
20 01 19* pesticides C LIQUID / SOLID 8 & 10
20 01 21* fluorescent tubes and other mercury-containing waste N SOLID 1 TO 4
20 01 23* discarded equipment containing chlorofluorocarbons C SOLID 8 & 10
20 01 25 edible oil and fat C LIQUID 8 & 10
20 01 26* oil and fat other than those mentioned in 20 01 25 C LIQUID 8 & 10
20 01 27* paint, inks, adhesives and resins containing hazardous substances C MISC 8 & 10
20 01 28 paint, inks, adhesives and resins other than those mentioned in 20 01 27 P MISC 8 & 10
20 01 29* detergents containing hazardous substances P LIQUID 8 & 10
20 01 33* batteries and accumulators included in 16 06 01, 16 06 02 or 16 06 03 and unsorted batteries and accumulators containing these batteries C BATTERY BATTERY STORE
20 01 34 batteries and accumulators other than those mentioned in 20 01 33 C BATTERY BATTERY STORE
20 01 35* discarded electrical and electronic equipment other than those mentioned in 20 01 21 and 20 01 23 containing hazardous components C WEEE HAZ WEEE STORE
20 01 36 discarded electrical and electronic equipment other than those mentioned in 20 01 21, 20 01 23 and 20 01 35 C WEEE NON HAZ WEEE STORE
COMBUSTIBLE-C
NON COMBUSTIBLE-N STORED AT ANY ONE TIME
WASTE TYPE POSSIBLY COMBUSTIBLE-P CONTAINMENT / "STATE" DAILY TONNAGE (100% CAPACITY) Tonnes Weekly 481 t
LIQUID C/P IN CONTAINERS (IBC / DRUM) 5 16 Annual 25000 t
SOLID C/P IN CONTAINERS (IBC / DRUM) 5 10 Daily 96 t
LIQUID / SOLID C/P IN CONTAINERS (IBC / DRUM) 5 6 Types 17 t
Tonnes per Type 5.7 t avg
LIQUID N IN CONTAINERS (IBC / DRUM) 6.00 22.00
SOLID N IN CONTAINERS (IBC / DRUM) 6.00 22.00
LIQUID / SOLID N IN CONTAINERS (IBC / DRUM) 6.00 12.00 96.00 NOT COMBUSTIBLE
SLUDGE C/P IN CONTAINERS (IBC / DRUM) 7 6 50 COMBUSTIBLE - NOT CATEGORISED ELSEWHERE

DUST C/P IN CONTAINERS (IBC / DRUM) 6 6
SLUDGE N IN CONTAINERS (IBC / DRUM) 7.00 14.00
DUST N IN CONTAINERS (IBC / DRUM) 5.00 14.00
FILTER CAKE N IN CONTAINERS (IBC / DRUM) 5.00 12.00
IN CONTAINERS (IBC / DRUM) & ON

EMPTY PACKAGING HAZ C PALLETS / BULK CONTAINERS 5 8 98.8 all combustible
EMPTY PACKAGING NON HAZ C PALLETS / BULK CONTAINERS 5 8
CRUSHED CONTAINERS C FEL CONTAINER n/a 2
BATTERY P IN CONTAINERS 3 10
WEEE HAZ C IN CONTAINERS 3 8
WEEE NON HAZ C IN CONTAINERS 3 8
IN CONTAINERS (IBC / DRUM) CAGED
GAS C BAY 2 4.8
NON HAZ ABSORBENTS / TEXTILES / FILTERS C PALLETS / BULK CONTAINERS 6 2
HAZ ABSORBENTS / TEXTILES / FILTERS C PALLETS / BULK CONTAINERS 6 4
194.8
Excluding Bay 5, 6, & 11
APPENDIX II
ENVIRONMENTAL POLICY

April 2020
Version: Issue 1
APPENDIX III
WASTE PROCEDURES

April 2020
Version: Issue 1
Forward Waste Management East Moors Road Hazardous Waste Transfer Station
Issue 1.0 25/03/20 Created by – WL (Tech Manager) Approved by – ND (COO)
PRE-ACCEPTANCE PROCEDURE
Purpose
To ensure that waste legisalation, the requirements of SGN 5.06, and the Environmental Permit are
complied with to prevent the acceptance of unsuitable wastes for storage and / or onward
processing.
Scope
Forward Waste Management East Moors Rd Hazardous Waste Transfer Station.
Responsibility
Technical Manager
Senior Site Chemist
Site Chemist
Industrial Waste Analyst (Sales)
Records
ISYS
COS
MID (Material Identification Doc – Sampling)
Chan of Custody (internal or suppliers)
Waste Declaration Form
COS -> MID (If required for samples) + Chain of Custody (internal or suppliers) -> Waste Pre-
Acceptance Form
1. WASTE ENQUIRY INFORMATION
From the waste disposal enquiry or a subsequent site survey, the Operator (Sales Representative or
appointed Technical staff) will obtain information in writing in relation to:
• The type of process producing the waste.
• The specific process from which the waste derives.
• The quantity of waste.
• The form the waste takes (solid, liquid, sludge, etc).
• Hazards associated with the waste.
• Chemical analysis of the waste (individual constituents and as a minimum their
percentage compositions).
• Sample storage and preservation techniques.
• Assign Hazard Codes and Risk Phrases to the waste stream.
The Sales Representative and appointed Technical staff will assist the customer / Producer in the
provision of the information, but the customer will be required to confirm in writing that the
information is correct. The information may be obtained over a series of communications with the
customer and should give consideration to possible or residual contamination.
Indicative quotes may be given but the waste stream shall not be approved for acceptance to the
site until the full information has been received from the customer and assessed for acceptability
by the Technical Dept. The information gathered at this stage shall be recorded on the Waste
Declaration Form, COS and / or the Chain of Custody Form (samples). These forms will then be
stored either digitally on the Operations server or as a hard copy.
2. PRE-ACCEPTANCE INFORMATION AND SAMPLING
Information
In instances where the generic characteristics of the waste are known and where a sample would not
be required, the information will be detailed on the Waste Declaration Form by the Producer, with
the assistance of the IWA (Sales) and supported by existing classifications and / or MSDS.
The purpose of pre acceptance information / sampling is to provide information to determine the
appropriate management, storage and treatment route and to facilitate the safe handling of the
waste on site.
The following will be undertaken for each waste stream:

• Nominally empty containers – MSDS will be obtained.
• Solidified resins (fully cured and generally non hazardous in this state) – MSDS will be
obtained / state of material will be confirmed by Technical.
• Oily rags and contaminated PPE – Subject to technical assessment and contaminant.
• Pure / raw products*.
• Laboratory smalls – subject to technical assessment (see below for procedure).
• Aerosols (nil Isocyanate, toxic, corrosive etc) - subject to technical assessment
• Gas canisters (empty and fully discharged) – subject to technical assessment.
• Batteries (fully identifiable and intact. If not intact, correctly overpacked.
• WEEE (hazardous and non-hazardous) - subject to technical assessment.
• Bonded asbestos – subject to technical assessment.
• Oils, greases and oil based lubricants - MSDS will be obtained / state of material will be
confirmed by Technical
• Domestic type detergents and cleaning chemicals - MSDS will be obtained / state of
material will be confirmed by Technical
• Waste process chemicals such as acids and bases - MSDS will be obtained / state of
material will be confirmed by Technical
• Sealants and glues - MSDS will be obtained / state of material will be confirmed by
Technical
• Fuels and solvents - MSDS will be obtained / state of material will be confirmed by
Technical
• Filter cakes and sludges - subject to technical assessment
• Dusts - subject to technical assessment

• Paints - MSDS will be obtained / state of material will be confirmed by Technical
• Empty contaminated packaging - MSDS will be obtained / state of material will be
confirmed by Technical
* - a Pure product waste in this case is defined as a mixture or preparation that has been
manufactured to a defined recipe to produce a material with a specific function and consistent
properties.
A waste product can be produced by the following:

• out of date
• over production
• off specification
• contamination by a substance at levels which will not increase the hazardous properties
of the substance e.g. petrol contaminated with water.
• washings where a product has been washed out using water.
Where a sample is not taken the justification will be recorded on the Waste Declaration Form.
Sampling
In instances where a sample is required, unless a sample and analysis has already been completed by
a third party and this is within a 3 month window (variable wastes) and 6 months (non-variable
wastes) of the date of the enquiry, FWM should in every case obtain representative sample(s) of the
waste from the production process / current holder and compare it against the written description to
ensure that it is consistent.
Samples will be taken in accordance with Forward Waste Management sampling procedures.
Other than for pure-product chemicals or laboratory smalls, the chemical analysis should relate to an
accredited analysis and not based on product data sheets or an interpretation of information on
product data sheets.
In the first instance, samples of the waste should only be retrieved by the Producer under guidance
by IWA in conjunction with FWM Technical Dept.
Samples can also be obtained by one of the following:

• FWM Technical.
• Suitably qualified or experienced third party,
The information is recorded on the chain of custody form (FWM MID FORM). Where a sample is
taken by the customer, advice will be given regarding the completion of the chain of custody form.
The IWA (Sales) and/or Technical will assist the customer in the provision of the information.
The sample will be labelled with the appropriate hazard diamond(s) and the chain of custody form
(FWM MID FORM) will be completed to identify chemical concentration, hazards and transport
classification.
The samples and their accompanying documents will be stored in the locked interim cabinet and
passed onto Technical from there. The sample and documentation will be logged onto the sample
register and stored in the processing cabinet prior to establishing suitable candidates for onward
recycling /disposal. Once a suitable outlet is sourced a sample is despatched under limited
quantities via courier and logged on the sample register.
Only UKAS accredited laboratories will be used for off-site analysis, included but not limited to:
• WAC (Waste Acceptance Criteria)
• Basic Chemical Characterisation
• Testing criteria according to ADR
• EWC analysis and classification report using WM3 Guidance.
Analysis required will vary depending upon the nature of the waste, the process to be used and what
is known about the waste already. Results of analysis should be kept within the tracking system.
These details should include:
• check on constituents declared by waste producer/holder to ensure Permit compliance,
treatment plant specification and final disposal.
• all hazardous characteristics.
• physical appearance.
• colour.
• pH.
• presence, strength and description of odour assessment (note COSHH implications)
Further analysis may include other parameters relevant to the treatment method or waste stream
e.g.:
• presence of oxidants
• acidity and alkalinity
• COD
• ammonia
• flashpoint
• presence of sulphide
• presence of cyanide
• List I and List II substances
• other substances of environmental significance
Also, for example in the case of oil recovery:

• chlorine
• sulphur
• metals
• PCBs
The above analysis will be conducted in conjunction with both FWM Laboratory facilities and 3rd
party suppliers. The scope of the analysis will be determined by the Technical Dept.
The information necessary for verification at the waste acceptance stage is entered on the COS by
the IWA (Sales) and the Waste Declaration Form which is issued to the inspecting Site Chemist.
The following forms as a minimum shall be stored:
• COS (Cost of Sales form).
• Official or email Quote with evidence of customer declaration.
• Pre-acceptance analysis or MSDS (as required).
• Waste Declaration Form
• Waste Acceptance Form
The full technical assessment is carried out and approved, only by Technical Dept.
Lab Smalls
Where possible, in all instances FWM will endeavour to provide a full, compliant Technical service
supported by qualified Chemist and DGSA (Dangerous Goods Safety Advisor) for the correct
packaging of “lab smalls”. This will include:
• Initial documentation / listing of the materials.
• Creation of compliant segregation lists.
• Support on completion of Waste Declaration Forms.
• Supply of consumables – compliant drums / “overpacks” and packing media.
• Compliant transport labelling.
• Waste documentation and supporting inventory.
• Compliant physical packing of the materials for loading, transport and unloading.
For Lab Small packed by the Producer, the following information must be supplied by the Producer /
IWA (Sales) in conjunction with Technical Dept. (Technical Manager, Senior Site Chemist, Site
Chemist):
• The information required to complete Waste Declaration Form.
• What chemicals are prohibited by FWM permit (e.g. radioactive chemicals, Clinical
wastes, explosives,)
• How to identify the waste laboratory chemical.
• How to establish and record the hazards posed by the chemical.
• Supporting documentation required (e.g. manufacturers data, material safety data
sheets).
• Segregation guidance to avoid mixing of incompatible wastes in the same drum.
• How to physically pack the chemicals.
• The required information to accompany the waste.
• The preparation of the “overpacks” to ensure compliant loading, transport and unloading.
Any discrepancies will be documented and communicated via email to the Producer / IWA (Sales)
and the materials will not be progressed to booking / acceptance until the items have been fully
assessed and cleared / reworked and approved by Technical Dept.
3. Booking of inbound wastes into site
The outbound disposal / recycling route will be detailed on the Waste Acceptance Form. The defined
disposal / recycling route will be suitably approved via Control of Contractors criteria and all relevant
documentation recorded on the Approved Suppliers List.
When the waste is approved for acceptance, a booking will be created specifying when the waste
can be accepted at the site and will allow an appropriate time for the unloading, inspection and
sampling of the waste. A booking will be requested from Operations and confirmed by Technical
Dept. A Waste Booking Form will be completed and the booking will be entered, by Operations on
the operational software system (ISYS).
Wastes will be appropriately designated for storage by waste type and hazardous / non-hazardous
classification in segregated bays (Toxic, corrosive, basic etc.). These storage locations will be detailed
on the Waste Booking Form. All records will be retained for a minimum of 3 years and will be stored
on both hard copy and digitally.
Servers are backed up on a weekly basis.

Forward Waste Management Hazardous Waste Transfer Station
ACCEPTANCE, STORAGE AND HANDLING PROCEDURE

Purpose
To ensure that waste legislation, the requirements of SGN 5.06, and the Environmental Permit are
complied with to prevent the acceptance of unsuitable wastes for storage and / or onward
processing.
Scope
Forward Waste Management Ltd, East Moors Rd Hazardous Waste Transfer Station.
Responsibility
Technical Manager
Senior Site Chemist
Site Chemist
Industrial Waste Analyst (Sales)
Records
ISYS
Insert Internal Chain of Custody form
COS
MID (Material Identification Doc – Sampling)
Waste Declaration Form (to be created)
Waste Booking Form
Waste Acceptance Form – includes: Load inspection, paperwork compliant, location of waste,
sampling regime.
Waste tracking system
COS -> MID (If required for samples) + Chain of Custody (if required for samples) -> Waste
Declaration Form -> Waste Booking Form -> Waste Acceptance form
1. Load Arrival
On arrival, all loads will:

• be weighed, unless alternative reliable volumetric systems linked to specific gravity data
are available
• not be accepted into site unless there is a sufficient storage capacity and the site is
adequately manned to receive waste.
• have all documents checked and approved, and any discrepancies resolved before the
waste is accepted.
• have any labelling that does not relate to the contents of the drum removed before
acceptance for unloading is approved.
• Have pre-acceptance confirmation of a costed and approved onward disposal /
recycling route.
• All wastes (hazardous / non-hazardous) should only be received under the supervision
of a suitably qualified person. (HNC qualified chemist or above).
The procedural management of acceptance of incoming waste is undertaken by a suitably qualified

Site Chemist / Senior Site Chemist. The acceptance of waste comprises four stages:
• Checking of paperwork,
• 1st stage inspection from the ground before unloading,
• Inspection of the delivery after unloading
• Sampling, verification and testing
On arrival at the site, the driver of the delivery vehicle will be required to provide the load delivery
paperwork which will include part or all of the following:
• Delivery note
• Consignment note – mandatory for Hazardous waste
• Duty of Care transfer note – mandatory for all wastes
• Batch list
2. Load inspection and Receipt
On arrival, the vehicle will be required to be weighed in and the tare, gross and nett weights
recorded on a weight ticket.
The accompanying waste documentation (Waste Transfer Note, Consignment Note etc) will be
compared to the Waste Booking Form for the to ensure that the description and quantities of the
waste delivered is consistent with the waste booked.
The process will be undertaken by a Site Chemist or another trained person. If the documentation is
not consistent with the details on the Waste Booking Form, a non-conformance will be raised in
accordance with - 6. Non Conformance Procedure.
Before off-loading the vehicle, a 1st stage inspection supervised by the Site Chemist will be
conducted. The Site Chemist will ensure that the any relevant health and safety instructions are
followed and that the load is visually inspected from the ground to determine the condition of the
load.
Checks will include, for packaged waste - stability, compatibility, condition of containers, seepages
and odour to the extent that can be observed from the ground. Any waste that is determined unfit
for transport or presenting a risk to the site shall be dealt with on site in accordance with - 6. Non
Conformance Procedure and appropriately packed in line with ADR / CDG.
Once the 1st stage checks are completed, the waste will be offloaded into the bunded reception area
where it is inspected and sampled (inspection, unloading and sampling area is designated on the site
plan as “Inbound waste reception”).
Non-hazardous items will be identified and these will be placed into a separate row / area within the
reception area.
Each container will be inspected to ensure that it is in a fully sound condition, correctly orientated,
with all lids capped and valves closed and that there is no critical damage present. Each waste
container will then be verified against the description provided on the paperwork (WTN, CN and
Waste Booking Form) and sampled where necessary. The technical information / analysis data will
be compared (where applicable) to the specification detailed in the Waste Declaration Form.
Inbound wastes will not be stored in the waste reception area for longer than 3 hours prior to
commencement of sampling and ongoing storage – such storage will be for a maximum of 5 days.
Waste will not be offloaded into the reception area unless sufficient space is available to safely and
appropriately assess such loads. Inbound waste booking will be controlled in full by the Technical
Dept.
3. Sampling
Every waste container will be suitably sampled and a core sample obtained. For compatible liquids
of the same “product” or “line” a composite sample will be suitable.
The Chemist will ensure that all lids or caps etc are closed after a sample is obtained.
The sample analysis will be compared to the pre-acceptance documentation to ensure the waste is
consistent with preliminary assessments. Any non-conforming containers will be documented in line
with 6. Non-Conformance Procedure.
Samples will be retained for a minimum of 2 days after the waste and its residues have left site.
The sampling regime for each load is recorded on the Waste Acceptance Form.
4. Storage
The accompanying paperwork will detail the relevant reference number (FWMID) for each “product”
or “line” and this will be applied to each container via a label detailing
• The unique FWMID number
• The arrival date
• Primary hazard (eg Class 3 – Flammable Liquid / Non hazardous).
• Location of storage (eg Bay number)
• Chemical identity
• EWC Code
•
Each container should be stored so that the label is easily accessible.
Any non-hazardous, clean and uncontaminated packaging such as cardboard / LDPE / film / paper /
wood etc will be transferred to EMR1 baling facility.
Load documentation will be compiled and retained in hard copy and digitally in server location
The location of each item will be recorded in the Waste Acceptance Form and within the waste
tracking system.
Each container will be segregated and stored in the appropriate bay, assigned by its combustibility
and its hazard class and will remain segregated until assigned to an outbound load for off-site
processing. All liquids will be stored on bunded platforms.
Non-hazardous wastes will be segregated and stored in the appropriate bays or storage vessels e.g.
WEEE non hazardous skip.
5. Waste Tracking System
The Waste Tracking system will hold the records relating to:
• Date of arrival on-site of wastes.
• Producers details.
• All previous holders.
• The unique reference number (FWMID).
• The EWC code.
• Pre acceptance and acceptance analysis and assessment results.
• Package type and size.
• Intended treatment/disposal route.
• Record accurately the nature and quantity of wastes held on site, including all hazards
and identification of primary hazards.
• Where the waste is physically located in relation to a site plan.
• Where the waste is, in the designated disposal route.
• Identification of staff who have taken any decisions regarding acceptance or rejection of
waste streams and have decided upon recovery / disposal options.
All hard copy documents will be retained for a minimum of 5 years. These will be stored in the site
office.
All digital records will be stored at the Office facility located at Forward House, East Moors Road and
will be retained on the company server which is backed up on a weekly basis.
6. Non-conformance Procedure
If at any point in the process chain a waste stream / waste container is found to be non-compliant to
either site permitted requirements or to the original producer declaration / pre-acceptance
assessment, it shall be determined as a non-conformance.
The waste will be routed to the appropriate quarantine area on site and labelled / stored.
If appropriate, the Site Chemist will store non-conforming items in the area of the site appropriate to
the waste (eg by Hazard Class). If, In the event that the nature or condition of the waste is such that
it cannot be quarantined safely with other waste, it will be placed and separated in the quarantine
facility on a dedicated bund and such storage should be for a maximum of five working days.
As soon as practicable after the waste has been quarantined, the appropriate Sales Representative /
Customer Account Manager shall be contacted and arrangements made to either:
• retest the waste stream to validate acceptability to site if differing from the original
producer declaration / pre-acceptance assessment; or
• reject the waste from site.
In the case of retesting waste, should the analysis required be outside of the scope of the sited
laboratory, the appropriate accredited laboratory shall be provided with an acceptable sample
without delay and the necessary chain of custody protocol followed. If it becomes apparent due to
laboratory turn-around times that the 5 day maximum period cannot be met, the regulator will be
contacted without delay to seek approval to extend the time period. This action will be recorded in
the site diary. If the extension request is denied the waste must be rejected from site within the 5-
day storage limit.
Once the non-conformance is concluded, the relevant Sales Representative / Customer Account
Manager will be contacted to resolve any cost implications or a return of the waste to the
Producer.All actions and conclusions will be recorded on the Non-Conformance Form and any
service-related issues recorded.
Specifically, for Lab Smalls

If on opening a drum it is found that it contains incompatible substances, or that the substances
have not been packaged adequately, then the drum will be non-conformed and documented in line
with 6. Non-Conformance Procedure. The drum will be placed in the quarantine area to be sorted
and repacked immediately by a suitably qualified Chemist and the non-conformance procedure
followed.
Sorting and repackaging of laboratory smalls should take place in a dedicated area (quarantine area).
Once the wastes have been sorted according to hazard classification, with due consideration for any
potential incompatibility problems, and repacked, then these drums should be removed to the
appropriate storage area, defined by the appropriate hazard class.
Specifically, for crushing of steel empty tins

Empty steel tins (previously containing paint, solvents, glues etc) will be assessed for crushing
suitability by the Chemist / Senior Site Chemist. Excess residues will be transferred to a UN
Approved 205lt drum and stored in the bunded area within the FPP area for flammable liquids.
Once assessed, the suitable tins will be placed in the tin crushing area and assigned for crushing.
Once crushed, they will be transferred to the FEL for storage and bulking prior to removal from site.
Bulk liquid wastes (via road tanker / portable tank etc) are not permitted for acceptance and
discharge.
LIQUID BULKING PROCEDURE

Purpose
To ensure that Waste Legislation, the requirements of SGN 5.06, and the Environmental Permit are
complied with to prevent the removal, loading or delivery of unsuitable wastes for onward
processing.
Scope
Responsibility
Technical Manager
Senior Site Chemist
Site Chemist
Records
ISYS
Waste Tracking System
Generic Bulking Procedure
1. The appropriate road tanker will be arranged and booked to attend site and remove liquids
from identified containers on an agreed date.
2. The nominated and labelled batch containers will be arranged in the reception area on the
day of collection prior to the arrival of the tanker.
3. Each container will be checked against the batch list and confirmed.
4. On arrival, the road tanker Operator / Driver will weigh in and attend the Site Office and
report to the Site Chemist / Senior Site Chemist for approval to enter the Bulking Zone. They
will provide a tank cleaning certificate when applicable.
5. The vehicle will safely reverse into the Bulking bay, only under the direction of a banksman.
6. The vehicle will halt in the correct position, apply braking and switch off the main engine.
Chocks will be placed in order to prevent accidental movement of the vehicle during loading.
7. The Operator / Driver will don the appropriate PPE and connect the suitable pipework and
valve assemblies to the rear inlet valve of the barrel.
8. The earthing system will be engaged and checked.
9. The nominated and labelled batch containers will be presented one pallet / IBC at a time to
the designated and bunded area for the Operator / Driver to insert pipework and remove
the liquid via vacuum barrel operation. Any containers not bearing a Batch Label will not be
presented for loading and will be placed in the quarantine area for assessment by the Site
Chemist / Senior Site Chemist.
10. During the operation the sample valve will be used to obtain samples for temperature
assessment. FOR ACID / ALKALI BULKING THE pH MUST ALSO BE MONITORED.
11. Once batch container/s have been emptied. The empty container/s will be returned to the
Reception Area.
12. The process will be repeated until the full composite load is transferred to the road barrel.
13. The Driver / Operator will vent and purge pipework and return it to the storage points on
the vehicle. All valves will be closed and checked, the earthing system will be dis-engaged.
14. Wheel chocks will be removed and the vehicle will mobilise to the weighbridge for a second
weight.
15. Paperwork will be completed by all parties and copies retained by the Site Chemist / Senior
Site Chemist.
Oils
Drums / IBC`s containing oils will be identified using FWMID numbers and analysed via GC to
determine their properties and appropriately assessed for compatibility in preparation for bulking
via road tanker.
An appropriate sized core sample will be obtained from each source and a composite sample
created from all nominated containers. The composite sample should be homogenous, free from
solids and water, it should not exhibit any form of reaction (such as evolved gases, temperature
changes, polymerisation or viscosity change, separation or precipitation of solids, odour etc) and
not consist of separation phases.
Any source containing incompatible or unsuitable material will be removed from the potential
composite assessment and identified and labelled accordingly.
Once a successful composite sample has been created, this will be signed of by the Senior Chemist
and updated on the Waste Tracking System. The source drums / IBC`s will be labelled with a Batch
Label and arranged for collection by an approved supplier for bulking and onward treatment /
disposal. The source drums / IBC`s will be updated on the Waste Tracking System upon collection to
remove them from the live stock.
Loading via road barrel of the nominated batch will be conducted as per “Generic liquid bulking
procedure”.
Oils will be transported as “not classified as dangerous by road”
Chlorinated oil
Drums / IBC`s containing Chlorinated oils will be identified using FWMID numbers and analysed via
GC to determine their properties (such as Chlorine content) and appropriately assessed for
compatibility in preparation for bulking via road tanker.
changes, polymerisation or viscosity change, separation or precipitation of solids, odour etc) and not
consist of separation phases.
disposal. Due to the nature of Chlorinated oils this may remain in drums / IBC`s for consigning from
site.
procedure” detailed above
.
Chlorinated oils will be transported under UN 3077 PGIII Environmentally Hazardous Substance,
Liquid.
Oily water
Drums / IBC`s containing oily waters will be identified using FWMID numbers and analysed via GC /
XRF to determine their properties and appropriately assessed for compatibility in preparation for
bulking via road tanker.
disposal.
procedure”.
Oils will be transported as “not classified as dangerous by road”

Aqueous non-hazardous liquids
Drums / IBC`s containing aqueous non-hazardous liquids will be identified using FWMID numbers
and analysed via XRF / bench test to determine their properties and appropriately assessed for
solids, it should not exhibit any form of reaction (such as evolved gases, temperature changes,
polymerisation or viscosity change, separation or precipitation of solids, odour etc) and not consist
of separation phases.
procedure”.
Aqueous non-hazardous liquids will be transported as “not classified as dangerous by road”
Corrosive Acidic Liquids
Drums / IBC`s containing corrosive acidic liquids will be identified using FWMID numbers and
analysed via XRF / bench test to determine their properties and appropriately assessed for
of separation phases. The pH will be monitored and balanced.
procedure”.
Corrosive acidic liquids will be transported under their specific UN number and proper shipping
name if the acid type is known (Hydrochloric / Phosphoric acid etc).
If the acid is non-specific, then a generic UN number and proper shipping name will be used and the
packing group assigned from the known percentage concentration of the components.
Corrosive Basic (alkali) Liquids
Drums / IBC`s containing corrosive basic liquids will be identified using FWMID numbers and
analysed via XRF / bench test to determine their properties and appropriately assessed for
of separation phases. The pH will be monitored and balanced.
procedure”.
Corrosive basic liquids will be transported under their specific UN number and proper shipping name
if the base type is known (Sodium Hydroxide etc).
If the base is non-specific, then a generic UN number and proper shipping name will be used and the
packing group assigned from the known percentage concentration of the components.
Flammable solvent liquids
Drums / IBC`s containing flammable liquids will be identified using FWMID numbers and analysed via
GC to determine their properties (such as Chlorine content and will have their Flash Point
determined) and appropriately assessed for compatibility in preparation for bulking via road tanker.
Only materials of Packing Group II (flash point >23 degrees C and boiling point > 35 degrees C) and III
(flash point >23 degrees - <65 degrees C and boiling point > 35 degrees C) are permitted for bulking.
Materials of Packing Group I (boiling point <35 degrees C) will not be permitted for bulking.
Weather conditions will be taken into account for the bulking of any flammable liquids.
Once a successful composite sample has been created, this will be signed off by the Senior Chemist
Label and arranged for collection by an approved supplier for bulking and onward treatment/
disposal.
Due to the nature of flammable liquids this may remain in drums / IBC`s for consigning from site.
procedure”.
Due to the complexity of the components, flammable liquids will be transported under UN 1993
Flammable Liquid N.OS and the Packing Group assigned from the flash point testing in line with ADR
principles of classification.
OUTBOUND WASTE PROCEDURES

Purpose
To ensure that Waste Legislation, the requirements of SGN 5.06, and the Environmental Permit are
complied with to prevent the removal, loading or delivery of unsuitable wastes for onward
processing.
Scope
Responsibility
Technical Manager
Senior Site Chemist
Site Chemist
Records
ISYS
Waste Acceptance Form – includes : Load inspection, paperwork compliant, location of waste,
sampling regime.
Waste Tracking System
1. Overview
Prior to any wastes being received for acceptance and storage on site, compliant and commercially
viable options for onward processing, recycling or disposal will be sourced.
Full technical information and any samples required will be obtained in advance via the OCP PRE
ACCEPTANCE / ACCEPTANCE procedures.
Potential Suppliers will be engaged to determine suitable and environmentally reputable consignees
that can provide stable, consistent and commercially proficient acceptance routes for all outbound
wastes.
Once a suitable Supplier has been established and all necessary Approve Supplier procedures (ISO
9001) are met, the potential site will be approved for delivery of wastes.
Where applicable, samples will be provided to Suppliers and / or a site visit will be arranged for the
Supplier to assess potential wastes for receipt.
In order to maximise stock efficiency, Suppliers will be selected by compliance, capability, availability
for stock, location and commercial viability.
Where possible, a contractual agreement will be made including terms for agreed delivery slots
within a set time period.
Control of all aspects of outbound movements of wastes and for any materials being removed from
site:
1. Identifying wastes / materials suitable for removal.
2. Further analysis to identify chemical components etc.
3. Liaising with Suppliers (Consignees).
4. Assigning waste to outbound loads.
5. Arranging delivery slots and requesting transport bookings.
6. Creation of transport documents and labels.
7. Overseeing the movement / relocation of stock assigned to outbound loads.
8. Inspection and labelling of stock assigned to outbound loads.
9. Overseeing the loading of stock assigned to outbound loads.
10. Completion of paperwork.
11. Updating of operational software.
12. Updating of the Waste Tracking System.
13. Management of any non-conformances raised.
This will be solely managed by the Technical Dept (Senior Site Chemist / Site Chemist / Technical
Manager DGSA).
2. Procedure
Wastes will be located via the Waste Tracking System and assigned to an outbound “Load”. During
this process, required documentation (consignment note) and labelling (transport labelling) will be
raised.
Suitable transport will be organised, and the collection added to the operational software with all
relevant purchase orders and data entry completed,
Selected wastes will be assembled in the Waste Reception Area, immediately prior to loading to
allow for:
1. Container inspection – assuring package is suitable for transport by road and all required
closures are secured.
2. To remove FWM container labelling to facilitate stock changes on the Waste Tracking
System.
3. To adhere suitable ADR transport labelling as required.
4. Carry out any load stabilisation such as shrink-wrapping or pallet configurations.
Any non-conformances raised will be documented and managed via the non-conformance procedure.
Wastes will then be loaded onto the vehicle and relevant documents completed. The vehicle will
then be weighed and recorded.
Operational software and Waste Tracking System will be updated accordingly.

3. Assigning wastes to outbound loads.
Waste will be assigned to Suppliers using (but not limited to) the following criteria:
Class 3 (Flammable Liquids) / Class 4.1 (Flammable Solids)
Clean, liquid, flammable solvent-based waste which can be recovered or recycled will be routed to
appropriate recovery facilities for reclamation and recycling into new products.
Heavily contaminated, liquid / solid solvent-based wastes which cannot be recovered or recycled will
be routed to appropriate reprocessing facilities for use as secondary fuels or kiln fuels.
Class 8 (Corrosive Acidic) Liquids / solids
Clean, liquid aqueous acids will be routed to appropriate physico-chemical treatment facilities for
recovery and re-use where possible.
Heavily contaminated liquid aqueous / solid acid wastes will be routed to appropriate physico-
chemical treatment facilities for treatment such as metal recovery and/or neutralisation.
Class 8 (Corrosive Basic) Liquids / solids
Clean, liquid aqueous basic materials will be routed to appropriate physico-chemical treatment
facilities for recovery and re-use where possible.
Heavily contaminated liquid aqueous / solid basic materials will be routed to appropriate physico-
chemical treatment facilities for treatment such as metal recovery and/or neutralisation.
Class 9 (Misc) Liquids / solids (primarily Environmentally Hazardous)
Wastes such as (but not limited to) :

• Drummed or overpacked env haz glues / mastiks etc.
• Articles contaminated with env haz glues / mastiks etc/oils / Chlorinated oils.
• Chlorinated oil liquids.
• Drummed or overpacked hardeners etc.
These will be routed based on potential for reprocessing and / or blending via an Approved Supplier.
Misc Hazardous wastes
Wastes such as:

• Waste non-hazardous packaging / pallets etc prior to reprocessing at EMR1 Non haz TS.
• Waste hazardous packaging – crushed / non-crushed.
• WEEE wastes.
• Oils – (these will be segregated from other wastes within the bay).
• Solid / liquid wastes deemed non-hazardous by WM3.
• Aerosols.
• Sludges.
• Dusts.
• Contaminated textiles will be directed to EMR1 for baling and storage.
These will be routed based on potential for reprocessing and / or blending via an Approved Supplier.
Class 5 & 6.1 (Toxic) Liquids / solids
Wastes such as (but not limited to):

• Pesticides / insecticides.
• Toxic liquids from industries such as surface metal finishing, photographic etc.
• Non specific toxic liquids / solids.
These will be routed based on potential for reprocessing via an Approved Supplier.
Aerosols
Storage area for used / spent or full aerosol containers in vented closed containers. Stored prior to
delivery to an Approved Supplier for recycling.
EXAMPLE WASTE TRACKING SYSTEM - PAGE 1
TRANS DATE OF
FWMID PRODUCER PACKAGE TYPE AND SIZE PRODUCT CODE SAMPLE REF UN NUMBER CLASS PG WASTE DESC CHEMICAL IDENTITY HAZARDS EWC CODE ARRIVAL PREM CODE
PREVIOUS PRE-ACCEPTANCE / ANALYSIS STORAGE OUTBOUND

HOLDER RESULTS (INSERT LINK) OUTBOUND ROUTE QTY ACCEPTED LOCATION (BAY) STATUS NOTES COUNTERSIGN
OUTBOUND OUTBOUND COST EMR2 MARGIN INTERNAL SALE SALE VALUE TO EMR2 SALES PREVIOUS 3rd PARTY PREVIOUS MARGIN
OUTBOUND UNIT WEIGHT (T) TO EMR2 (%) VALUE PRODUCER MARGIN (£) MARGIN (£) COST PER UNIT PER UNIT
APPENDIX IV
SOLUTEX CAN COMPACTOR 206
MACHINERY SPECIFICATION

April 2020
Version: Issue 1
Pneumatic Can crusher for cans up
to 30 litre capacity. Semi-automatic
Can Compactor 206

cycle. Fitted with safety interlock.
HIG HL I G HT S
ATEX II 3GD
Economic unit ideal for paint tins
ATEX Approved II 3GD
Easy to use
Ideal for small workshops, car

bodyshops etc
Supplied ready to use,
Simply connect to compressed air

supply.
CO NT ACT U S
For more information on any of our

products or services please contact
Reduce
us :
waste
[email protected]
+44 (0) 1691 622225
Specification
Compaction force 1600 kgs at 8 bar

Compaction cycle Semi-automatic
Cycle time 25 secs
Compaction chamber size 370 x 350 x 580 mm high
Overall dimensions 500 x 450 x 1780 mm high
Weight 100 kgs
Power Pneumatic
www.solutex.co.uk
2020

PAN-010144 - ECL.010.02.01EPTR Issue 1

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PAN-010144 - ECL.010.02.01EPTR Issue 1

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APPLICATION FOR AN ENVIRONMENTAL

PERMIT UNDER THE ENVIRONMENTAL

ENVIRONMENTAL PERMITTING TECHNICAL

FORWARD WASTE MANAGEMENT

LL, HU14 3HH

ECL Ref: ECL.010.02.01/EPTR

7. APPLICATION SITE CONDITION REPORT 22

9. RESOURCE EFFICIENCY AND CLIMATE CHANGE 24

10. COMPLIANCE WITH BAT CONCLUSIONS 26

APPENDIX I PROPOSED WASTE CODES AND STORAGE ARRANGEMENTS

Figure 1: Illustration of the Solutex Can Crusher 11

Table 1: Proposed Schedule 1 Activities 2

1.2. Installation Location

1.3. The Applicant

2.1. Installation Activities

Table 1: Proposed Schedule 1 Activities

2.2.1. A Certificate of Lawful Use or Development (Planning Reference 92/01306/R) was

3.1. Technical Competence

3.2. Overview of Environmental Management System

3.2.4. FWM will establish a documented EMS which:

3.3. Environmental Policy

3.4.1.1. The planning element of the EMS will include:

3.4.1.2. The outcomes of the above are:

3.4.2. Implementation and Operation (Do)

3.4.2.1. This element will include:

3.4.4.1. This element includes:

3.4.4.2. The outcomes of the above will be:

3.4.5.1. This element will include:

3.4.5.2. The outcomes of the above will be:

4.2. Technical Standards

4.3. Proposed Waste Activities

4.3.1. Waste Codes to be Accepted at the Installation

4.3.2. Waste Storage

4.3.4. Waste Treatment

4.3.5. Waste Pre-Acceptance Arrangements

4.3.6. Waste Acceptance Arrangements

4.3.6.6. Non-conforming waste is described as any waste that:

4.3.7. Waste Handling, Storage and Processing

4.3.7.6. Aerosols will be stored within a dedicated covered caged bay.

4.3.8. Waste Dispatch

4.3.9.3. The reporting system can provide reports on the following:

4.4. Proposed Infrastructure and Drainage Arrangements

5.1. Point Source Emissions to Air – Proposed Arrangements

5.1.1. There will be no point source emissions to air.

5.2. Point Source Emissions to Surface Water – Proposed Arrangements

5.3. Point Source Emissions to Sewer – Proposed Arrangements

5.4. Point Source Emissions to Land – Current Arrangements

5.4.1. There will be no emissions to land.

5.5. Fugitive Emissions to Air

5.6. Fugitive Emissions to Surface Water, Sewer and Groundwater

6.1. Emissions Management

6.1.1. The Environmental Risk Assessment (“ERA”) (Document Reference ECL.010.02.01/ERA)

6.2. Odour Management

6.3. Noise Management

6.4. Pest Management

6.5. Fire Management

8.1. Monitoring of Emissions to Air

8.2. Monitoring of Groundwater

8.3. Monitoring of Surface Water