5. General management appropriate measures
General management appropriate measures and the process they apply to.
1. The following measures apply to all processes and operations. You must have an up to date, written management system. The level of detail you need will be related to the size of your operation, site location and complexity. Your management system must aim to improve the overall environmental performance of the site.
2. You must have management commitment, including from senior managers (where applicable) to develop an environmental policy that is defined by senior managers (where applicable). This policy must include the continuous improvement of the facility’s environmental performance, so you can identify pollution risks and minimise them through appropriate measures and make best and most efficient use of resources.
Your management system must also incorporate the features that follow.
3. You plan and establish the resources, procedures, objectives and targets needed for environmental performance alongside your financial planning and investment.
4. You implement your environmental performance procedures, paying particular attention to:
- staff structure and relevant responsibilities
- staff recruitment, training, awareness and competence
- communication (for example, of performance measures and targets)
- employee involvement
- documentation
- effective process control
- maintenance programmes
- emergency preparedness and response
- making sure you comply with environmental legislation
5. You check environmental performance and take corrective or preventative action (or both), paying particular attention to:
- monitoring and measurement
- investigating and learning from incidents, near misses and mistakes including those of other organisations
- records maintenance
- independent (where practicable) internal or external auditing of the management system to confirm it has been properly implemented and maintained
6. Senior managers and or operators must periodically review the management system to check it is still suitable, adequate and effective.
7. You review the development of cleaner technologies and their applicability to site operations. The Environment Agency would expect you to consider cleaner technologies:
- as a result of substantiated pollution incidents
- when reviewing management systems
- when planning investment decisions, for example new items of plant
8. When designing new plant, you must assess the environmental impacts from the plant’s operating life and eventual decommissioning. You must make sure that new plant is authorised by your environmental permit.
9. You must have a written procedure for proposing, considering and approving changes to procedures or infrastructure related to storing or treating waste or pollution control. This is so you can track and control the process of change.
10. You consider the risks a changing climate presents to your operations and have appropriate contingency plans in place to assess and manage future risks.
11. You compare your facility’s performance against relevant sector guidance and standards on a regular basis, known as ‘sectoral benchmarking’.
12. You document and implement appropriate waste stream management.
13. You have and maintain a site condition report for installations. For waste facilities the Environment Agency recommends that you carry out a site condition assessment during the life of the site. You would need to carry out this assessment on surrender. Please read the guidance Environmental permitting: H5 site condition report.
14. You have and maintain:
- an inventory of waste water, waste gas streams or fugitive emissions
- a product and residues management plan
- an accident management plan
- a site infrastructure plan
- an odour management plan
- a bioaerosol risk assessment and management plan
- a fire prevention plan, if required
- a noise and vibration management plan, if required
- a pest management plan, if required
- a dust, mud and litter management plan (emissions management plan) if required
- a leak detection and repair plan, if required
By ‘inventory’ we mean a complete and detailed list of all waste water and waste gases produced, handled and treated by your process or plant. Where possible, for example from channelled emissions points (point-sources), your inventory must quantify characteristics such as:
- substance concentration
- load value and variability of each waste water and waste gas stream
The following measures apply to all processes and operations.
1. You must have a schedule of inspection, maintenance and monitoring programmes for all plant and equipment (including the impermeable surfacing and drainage systems).
2. You must inspect, maintain and monitor plant, equipment and infrastructure in accordance with manufacturer or design guidelines.
3. Where manufacturers’ guidelines are not available, or where you have modified them, you must provide evidence that there are sound reasons for not following these guidelines, and that you have a robust alternative.
4. You must be able to produce proof of all inspection and maintenance through records of maintenance and inspection when requested.
5. If the site is more complex (AD, IVC and MBT plants) you must do a Hazard and Operability Study (HAZOP) or a similar study or risk assessment.
6. You must consider stocking or holding a list of critical spare parts and chemicals. You must be able to procure and install spares without undue delay.
7. You must have a programme of review and consider design improvements which take into account future de-commissioning (for existing plants). These improvements may include:
- improving or replacing underground tanks and pipework – or proposing an inspection regime
- installing secondary containment or instigating a suitable monitoring programme depending on the risks identified and the sensitivity of the potential receptors
- inspecting, draining and cleaning out vessels and pipework (especially before decommission and before dismantling)
- inspecting and reviewing lagoons to make sure there is no leakage or damage – you must consider the life of the facility and any future decommissioning and clean up
- reviewing insulation – this should be easy to dismantle without producing dust or causing a hazard to staff and local receptors
- using recyclable materials, taking into account operational or other environmental objectives
The following measures apply to all processes and operations.
1. Your site must always be operated or monitored (or both) by an adequate number of staff who have appropriate qualifications or training (or both) and competence.
2. If you operate a 24-hour process, for example an in vessel or AD facility you must have:
- remote or telemetric systems in place to make sure an alarm would be raised in the event of an incident during unmanned hours
- appropriate personnel on call to deal with such incidents
3. You must adequately explain these procedures in your management system and make sure they are implemented.
4. The design, installation and maintenance of infrastructure, plant and equipment must be carried out by competent people, including using CQA where appropriate.
5. You must have appropriately qualified managers for your waste activity who are members of a government-approved technical competence scheme.
The following measures apply to all processes and operations.
1. As part of your written management system you must have a plan for dealing with incidents or accidents that could result in pollution, including near misses.
2. Your accident management plan must identify the hazards, risk and mitigation measures that will protect the environment in the event of an accident or event.
3. Particular areas to consider may include:
- waste types and reactions of mixed waste
- transferring substances, for example filling (including overfilling) or emptying of vessels and containers, over pressure of vessels and pipework, blocked drains
- preventing incompatible substances coming into contact with each other
- failure of plant and equipment, for example storage tanks and pipework, or blocked drains
- failure of containment, for example bund failure or drainage sumps overfilling
- making the wrong connections in drains or other systems
- failure to contain firefighting water
- failure of abatement systems
- hazardous atmospheres in confined spaces
- failure of main services, for example power, steam or cooling water
- checking the composition of effluents before their emission
- vandalism and arson
- operator error
- accessibility of control equipment in emergency situations
- extreme weather conditions, for example flooding or very high winds
- having a contingency arrangement to divert waste feedstock when your ability to spread outputs to land, or inject gas to grid, is limited
4. You must assess the risk of accidents and their possible consequences. To help you do this you can either use:
- the Environment Agency’s risk assessment guidance
- a HAZOP or a similar detailed assessment that identifies hazards through possible deviations from the design intention
5. Risk is the combination of the likelihood that a hazard will occur and the severity of the impact resulting from that hazard. Having identified the hazards, you can assess the risks by addressing 6 questions:
- how likely is it that the accident will happen?
- what may be emitted and how much?
- where will the emission go – what are the pathways and receptors?
- what are the consequences?
- what is the overall significance of the risk?
- what can you do to prevent or reduce the risk?
6. The depth and type of accident risk assessment you carry out will depend on the complexity of your facility and its location. The main factors to take into account are the:
- scale and nature of the accident hazard presented by the facility and its activities
- risks to areas of population and the environment (the receptors)
7. Through your accident management plan, you must also identify the roles and responsibilities of the staff involved in managing accidents. You must provide them with clear guidance on how to manage each accident scenario, for example as a result of a spillage of a potentially polluting liquid.
8. You must have a suitably trained facility employee available at all times who will act as an emergency co-ordinator and will take responsibility for implementing the accident management plan.
9. You must train your employees so they can perform their duties effectively and safely and know how to respond to an emergency.
10. You must also:
- establish how you will communicate with relevant authorities, emergency services and neighbours (as appropriate) before, during and after an accident
- implement emergency procedures, including for safe plant shutdown and site evacuation
- implement post-accident procedures that include doing an assessment of the harm an accident caused (or may have caused) and actions you will take to prevent further accidents
- consider the impact of accidents on the function and integrity of plant and equipment
- have contingency plans to relocate or remove waste from the facility and suspend incoming waste
- test the accident management plan by carrying out emergency drills and exercises
11. Following a flooding event you must inspect and assess the integrity of affected plant and equipment, in particular infrastructure that may have been in contact with floodwater or groundwater. Tank inspections should include non-destructive testing methods to verify their integrity.
12. Storage and drainage lagoons must have adequate storage capacity to make sure structural integrity is not compromised during extreme weather events.
The following measures apply to all processes and operations.
1. You must have a drainage plan and in the event of an emergency this must be available to emergency services. The drainage plan should clearly identify clean and dirty or foul drainage.
2. You must make sure that in an emergency you can contain on site:
- process waters
- contaminated site drainage waters
- emergency firefighting water
- chemically contaminated waters
- spillages of chemicals
3. You must put spill contingency procedures in place to minimise the risk of an accidental emission of raw materials, products, and waste materials, and to prevent their entry into water, land and air.
4. Your drainage and collection system must take account of additional firefighting water flows or firefighting foams. You may need emergency storage to prevent contaminated firefighting water reaching a receiving water body.
5. You must consider and reduce the risk of accidental emissions from:
- loss of containment – all polluting matter
- vents
- safety relief valves – making sure these are checked and maintained (preventing sticking and over feeding, see site capacity in section 4)
- bursting discs and seals
- tank wall penetrations
- storage containers
6. Liquids or fire water held in the buffer storage must be removed from site.
The following measures apply to all processes and operations.
1. You must have security measures in place (including staff) to prevent:
- entry by vandals and intruders
- damage to the equipment
- theft
- fly-tipping
- arson
2. Facilities must use one or a combination of the following measures:
- security guards
- total enclosure (usually with fences)
- controlled entry points
- adequate lighting
- warning signs
- 24 hour surveillance such as CCTV
The following measures apply to all processes and operations.
1. You must have a fire prevention plan that meets the requirements of the Environment Agency’s fire prevention plan guidance. The plan should include:
- preventing the uncontrolled decomposition and self-heating of stored waste by managing and monitoring temperature and moisture
- implementing written systems to prevent unsafe situations during site operations, repair and maintenance
- having a ‘permit to work’ system in place for maintenance and repairs, such as hot work on plant and equipment, and where the risk of unsafe conditions could occur
- having appropriate systems in place for fire and explosion prevention, detection and suppression or extinction – you must document these measures in your accident management plan or fire prevention plan, if required, to comply with your permit conditions
2. You must prevent the build-up of loose combustible material (including dust and waste) particularly around treatment plant, equipment and other potential sources of ignition.
3. You must:
- make sure that all the measurement and control devices you would need in an emergency are easy to access and operate in an emergency situation
- maintain plant in a good state through a preventive maintenance programme and a control and testing programme
- use techniques such as suitable barriers to prevent moving vehicles damaging equipment
- put procedures in place to avoid incidents due to poor communication between operating staff – during shift changes, periods of cover by temporary staff and following maintenance or other engineering work
- where relevant, use equipment and protective systems designed for use in potentially explosive atmospheres
4. You must be mindful of alarm fatigue and make sure all alarms are appropriately set and promptly responded to.
5. You must make sure that critical safety equipment, for example sprinklers, pressure relief valves and flares are maintained and kept in good working order.
6. Workers on site must be protected and monitored in line with the Health and Safety Executive (HSE) guidelines and regulations.
7. You must carry out all assessments in line with your facility’s occupational exposure process and health and safety guidelines.
Fire prevention – composting plants only
8. The following measures only apply to composting plants including when storing oversize (tail ends) material from composting and maturing composted material.
You must:
- size your treatment and maturation piles (windrows) to make sure that passive heat convection is not inhibited – you must prevent persistent high temperatures and over-heating
- monitor temperatures daily during sanitisation and stabilisation
- monitor the temperature of all waste on site in storage, including oversized and screened material weekly
- make sure that you obtain a representative core temperature and that temperature probes are long enough to monitor the core temperature
- make sure you optimise moisture levels
- make sure there is enough space between windrows for turning so material can cool down and for safe access in the event of a fire
- have sufficient water, leachate or liquor available on site to give adequate moisture to your composting waste
Fire prevention and explosion – AD plants only
9. The following measures only apply to AD plants.
All AD facilities must comply with The Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR). More information is available from HSE. All AD plants must undertake a DSEAR risk assessment. This is not only for facility staff but for those attending the site in an emergency.
If a DSEAR risk assessment has identified potential explosion hazards you must make sure the design and planning of your plant includes appropriate structural, technical and organisational fire protection measures.
10. You must install protective measures on your site and implement procedures such as:
- a permit to work system
- using specialised personal protective equipment (PPE)
- health and safety protection signage
- using ATEX-rated equipment
11. Organisational protective measures include regular maintenance of the plant, systems and components.
12. You must follow national guidelines and standards on fire protection when designing and planning your site.
13. You must consider whether the Control of Major Accident Hazard (COMAH) Regulations 2015 apply to your activities, for example, the quantity of flammable gas (biogas) in combination with any other dangerous substances stored on site.
14. You must risk assess your site in line with BS EN 62305-2 to determine the lightning protection level. Where you have assessed that lightning protection measures are not necessary, you must make an assessment against transient over voltage, complying with BS7671. Where lightening condition systems are in place, they must comply with BS 62305 (part 1 to 4). A competent person must validate the system.
15. You should share your accident management and fire prevention plans, and liaise, with your local fire and rescue service.
16. You must maintain plant control in an emergency using one or a combination of the following measures:
- alarms
- process trips and interlocks
- automatic systems based on microprocessor control and valve control
- tank level readings such as ultrasonic gauges, high level warnings, process interlocks and process parameters
- using a flare to manage biogas in AD systems
The following measures apply to all processes and operations.
1. Your accident plan must clearly state what actions are taken to extinguish fires on site and operators must be trained in these procedures.
2. Your facility must have access to water supplies to extinguish fires. In remote locations where water supplies are not available you must seek advice from your local fire service.
3. In the event of a fire on site, your accident plan must consider how you will prevent firefighting run-off leaving site. Where possible you should have the capability to collect, contain and store firefighting water run-off.
4. You must isolate drainage systems from flammable waste storage areas to prevent fire spreading along the drainage system by solvents or other flammable hydrocarbons.
The following measures apply to all processes and operations.
1. You must:
- keep an up to date record of all accidents, incidents, near misses, changes to procedures, abnormal events, and the findings of maintenance inspections
- carry out investigations into accidents, incidents, near misses and abnormal events and record the steps taken to prevent their reoccurrence
- maintain an inventory of substances, which are present (or likely to be) and which could have environmental consequences if they escape
- record and hold a critical plant and equipment asset register, including a register of equipment installed in explosive atmospheres (ATEX-rated equipment)
2. You must notify the Environment Agency without delay if you detect any of the following events and they are causing, or may cause, significant pollution:
- a malfunction
- a breakdown or failure
- an accident
- an emission of a substance not controlled by an emissions limit
- a breach of an emissions limit
The following measures apply to all processes and operations.
1. You must have and implement a contingency plan which makes sure that you:
- comply with all your permit rules and operating procedures during maintenance or shutdown, or critical failure at your site or elsewhere
- do not exceed limits in your permit and you continue to apply appropriate measures for waste storage, handling and treatment
- stop accepting waste unless you have a clearly defined method of recovery or disposal, and enough permitted storage capacity when land bank availability is limited, for example, during exceptional weather events such as prolonged rain or snowfall, deep frosts and severe drought
- plan for any restrictions that will affect the spreading of digestate or compost to land, for example, nitrate vulnerable zones (NVZ) closed periods
2. You must have the following information in your contingency plan:
- a description of each waste and material and the correct LoW code for each waste (inputs and outputs)
- details of permitted waste facilities that could accept and manage your waste if site holding capacity will be exceeded – you must obtain a copy of the site permit to make sure it can accept your waste type
- the capacity (volume) of all contingency options and the length of time for which it would be available or needed
- potential environmental and health and safety risks and hazards of all contingency options (for example, odour and emission generation, or leachate production from longer-term storage)
- any legal restrictions or constraints for each contingency option
3. You must identify your contingency options for use over the short term (1 to 2 weeks), medium term (4 to 6 weeks) and the long term (up to 6 months).
4. Your management procedures and contingency plan must also:
- identify known or predictable malfunctions associated with your technology and the procedures, spare parts, tools and expertise needed to deal with them
- make sure you have the spare parts, tools, and competent staff needed before you start maintenance
- record where you can get critical spare parts from and how long it would take to obtain them if you cannot hold them on site
- have a defined procedure to identify, review and prioritise items of plant which need a preventative regime
- include all equipment or plant whose failure could directly or indirectly lead to an impact on the environment or human health
- identify non productive or redundant items such as tanks, pipework, retaining walls, bunds, reusable waste containers, ducts, filters and security systems
5. You must make your feedstock suppliers and customers aware of your contingency plan, and of the circumstances in which you would stop accepting waste from them.
6. You must consider whether the sites or companies you rely on in your contingency plan:
- can take the waste at short notice
- are authorised to do so in the quantities and types likely to be needed in addition to carrying out their existing activities – if in doubt contact your local Environment Agency office for advice
7. You must not include unauthorised capacity in your contingency plan. If your contingency plan includes using temporary storage for additional waste on your site, then you must make sure your site is authorised for this storage and the appropriate infrastructure is in place.
8. Your management system must include procedures for auditing your performance against all the contingency measures detailed above and for reporting the audit results to the site manager.
9. If you produce an end of waste material at your facility, your contingency planning must consider storage capacity for end of waste products and materials that fail the end of waste specification.
Contingency plans – AD plants only
This additional measure only applies to AD plants.
10. You must stop accepting waste or reduce feeding rates unless you have a clearly defined method of gas management when national grid capacity is restricted.
The following measures apply to all processes and operations.
1. The term commissioning means to bring an item of plant or equipment into working condition. You must notify the Environment Agency before you start commissioning. You must consider communicating with local communities during the commissioning phase, to comply with your management system and odour management plan.
2. You must consider the arrangements for commissioning your plant at the design stage. You must have a commissioning plan in place before you start commissioning to minimise the risks of pollution and harm to human health and the environment. The level of detail can be based on the complexity of, and risks associated with, the process.
3. You must define the suite of indices you will use to determine and monitor process performance and efficiency.
4. You must review and refine the relevant monitoring parameters during the facility’s operation as part of an on-going process of system optimisation.
5. You must test and validate all systems and components of your plant and building(s) against operational requirements identified at the design stage. This must include, for example, the air extraction and abatement system and containment structures.
6. You must have completion certificates (for each commissioning phase) in place, signed by an appropriately qualified person.
7. Commissioning must be carried out to relevant industry standards where they are available, or follow manufacturers’ guidelines. As a minimum, the commissioning plan must include summaries of:
- commissioning phases (and sequences) including milestones and timeframes (for example pre, cold, hot commissioning)
- procedures and mechanical tests at each phase including relevant industry test standard (or otherwise), for example manufacturers’ guidelines
Mechanical tests could include, for example:
- tests for leaks
- pressure tests of piping and equipment
- purging or inerting requirements
- pressure and vacuum safety relief where required
- temperature
- flow and pressure control
- mixing
- air flow ventilation
- extraction
8. Your commissioning plan must also include the:
- scope of performance tests, for example, acceptance criteria, measurement requirements, sampling requirements, reference to analytical procedures, chemical and biological analysis
- identification of potential releases to the environment of displaced and generated emissions and measure to mitigate these, for example, lean burn flares
- scope of responsibilities of the person(s) related to the test procedures, including the sign-off process
- qualifications of the responsible person(s) involved
- process for dealing with failed tests and problems that you may encounter
- health and safety precautions and protective measures employed
Plant commissioning – AD plants only
The following measures only apply to AD plants.
9. When commissioning AD plants that have mixing systems installed, you must test the mixing system is effective. You should document the methodology in the commissioning plan.
10. You can only seed and commission AD plants using waste after the Environment Agency has issued your environmental permit. The permit must contain the relevant LoW code and description for the seeding material.
11. You must allow enough time for the Environment Agency to issue your permit when planning the start of your commissioning and any tariff guarantee date. Sending correct and exact information with your application means that the Environment Agency can issue your permit more quickly.
12. You should source the biomass (inoculum) used in seeding a digester that matches the type of feedstock the facility is designed to process. This will provide a more stable substrate.
The following measures apply to all processes and operations.
1. You must consider plant decommissioning or ceasing activities (mothballing) at the design stage.
2. You must have plans that minimise risks during the time decommissioning or mothballing takes place. This includes removing or replacing individual items of plant throughout the life of the facility.
3. Before you decommission plant you must notify the Environment Agency and provide a copy of your decommissioning plan.
4. Once decommissioning is complete you must provide a written report to the Environment Agency verifying that you have carried out activities in line with your plan.
5. If you bring plant back into service after a period of dormancy you must follow the commissioning requirements set out in this document or be directed by a suitably qualified person.
6. You must have a decommissioning plan to demonstrate that:
- plant can be decommissioned without causing pollution
- the site will be returned to a satisfactory condition, for example in line with your site condition report
7. The decommissioning plan must include details of (but not limited to):
- removing or flushing out pipelines and vessels where appropriate and completely emptying any potentially harmful contents
- drawings showing all the underground pipes and vessels
- the method and resources needed for clearing lagoons
- how you will dismantle buildings and other structures in a way that protects surface water and groundwater at construction and demolition sites
- the soil testing needed to understand the degree of any pollution caused by the site activities, and information on what remediation is needed to return the site to a satisfactory state as defined by the initial site report
- the measures proposed, once activities have ceased, to avoid any pollution risk and to return the site to a satisfactory state (including, where appropriate, those covering the design and construction of the plant)
- how you will clear any residues, waste, and any contamination resulting from the waste treatment activities
Decommissioning and mothballing – AD plants
The following measures only apply to AD plants.
8. Decommissioning plant and equipment, where there are potentially explosive atmospheres, is a specialist activity. You must make sure you have written procedures in place and follow it to support the safe removal or closure of plant on site.
9. You must make sure that equipment permanently taken out of use is decontaminated and removed from the site.
10. You must have a procedure and follow it for inspecting, maintaining and validating the recommissioning of plant and equipment following periods of dormancy.