2. General management appropriate measures

These are the appropriate measures for the environmental management of a regulated facility with an environmental permit to store and treat ELVs.

2.1. Management system

1. You must have and follow an up to date, written management system. It must incorporate the following features.

You must have:

  • management commitment, including from senior managers
  • an environmental policy that is approved by senior managers and includes the continuous improvement of the facility’s environmental performance

You must plan and establish the resources, procedures, objectives, and targets needed for environmental performance alongside your financial planning and investment.

You must implement 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
  • the management of change (including legislative changes and ELV or components classification changes)
  • emergency preparedness and response
  • making sure you comply with environmental legislation

You must check environmental performance and take corrective action paying particular attention to:

  • 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

Senior managers must review the management system to check it is still suitable, adequate, and effective.

You must review the development of cleaner technologies and their applicability to site operations.

When installing new or upgraded equipment, you must assess the environmental impacts from its operating life and eventual decommissioning.

You must consider the risks a changing climate poses to your operations. You have appropriate plans in place to assess and manage future risks.

You must compare your site’s performance against relevant sector guidance and standards on a regular basis.

You must have and maintain the following documentation:

If required, you have and maintain the following documentation:

2.2. Staff competence

1. Your site must be operated at all times by an adequate number of staff with appropriate qualifications and competence.

2. The design, installation and maintenance of infrastructure, site and equipment must be carried out by competent people.

3. You must have appropriately qualified managers for your ELV activity who are either:

4. Non-supervisory staff must be reliable and technically skilled. Their skills may be based on experience and relevant training.

2.3. Accident management plan

1. As part of your management system you must have a plan for dealing with any incidents or accidents that could result in pollution.

2. The accident management plan must identify and assess the risks the facility poses to human health and the environment.

3. Areas to consider include:

  • ELV types and the risks that they pose
  • robust ELV acceptance procedures to avoid receiving unwanted items, such as gas cylinders
  • abatement systems failure for example, interceptors
  • equipment failure (for example, over-pressure of vessels and pipework, blocked drains)
  • containment failure (for example, bund failure, or drainage sumps overfilling)
  • damaged lithium-ion (Li-ion) batteries and any part of the electrical circuit in electric end of life vehicles (EELVs)
  • failing to contain firefighting water
  • making the wrong connections in drains or other systems
  • making sure that interceptors are functioning correctly
  • vandalism and arson
  • extreme weather conditions for example, flooding or very high winds

Assessing the risks

4. You must assess the risk of accidents and their possible consequences by carrying out a risk assessment.

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?

5. You must identify any fire risks that may be caused, for example by:

  • arson or vandalism
  • self-combustion, for example within oily rags and overalls
  • equipment failure and electrical faults
  • naked lights and discarded smoking materials
  • use of improper tools
  • hot works (for example welding or cutting), industrial heaters and hot exhausts
  • reactions between incompatible materials
  • neighbouring site activities
  • sparks from forklift trucks and machinery
  • hot loads deposited at the site for example, vehicles involved in collisions resulting in thermal runaway of batteries
  • damaged Li-ion batteries
  • batteries left connected in ELVs causing an electrical short circuit
  • batteries (storage, processing, and handling)

This list is not exhaustive and you must have a fire prevention plan that identifies the risks at your site and meets the requirements of our fire prevention plan guidance.

6. The depth and type of accident risk assessment you carry out will depend on the characteristics of the site and its location. The main factors to consider are the:

  • scale and nature of the accident hazard presented by the activities
  • risks to areas of population and the environment (the receptors)
  • complexity of the activities and how difficult it is to decide and justify adequate risk control techniques

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.

8. You must appoint one facility employee as an emergency co-ordinator who will take lead responsibility for implementing the plan. You must train your employees so they can perform their duties effectively and safely and know how to respond to an emergency.

9. You must also:

  • establish how you will communicate with relevant authorities, emergency services and neighbours (as appropriate) both before, during and after an accident
  • have appropriate emergency procedures, including for safe shutdown and site evacuation
  • have post-accident procedures that include assessing the harm that may have been caused by an accident and the remediation actions you will take
  • depending on scale, test the plan by carrying out emergency drills and exercises

2.4. Accident prevention measures

1. You must take the following measures, where appropriate, to prevent events that may lead to an accident.

Segregating ELVs

2. You must keep apart incompatible ELVs or components. Examples could include but are not limited to:

  • keeping depolluted and un-depolluted ELVs separate
  • keeping ELVs for as short a duration as possible before depollution
  • disconnecting and removing batteries as soon as is practicable upon receipt of the ELV
  • storing lead acid batteries separately to nickel metal hydride and Li-ion batteries
  • segregating flammable gas cylinders in cages away from other activities

Preventing accidental emissions

3. You must make sure you contain the following (where appropriate) or route to a sealed drainage system (where necessary):

  • site drainage waters
  • emergency firefighting water
  • oil, fuel, or chemical contaminated waters
  • spillages of oils, fuels, and chemicals

Clean surface waters should be kept separated from contaminated surface water.

4. You must be able to contain surges and storm water flows. You must provide enough buffer storage capacity to make sure you can achieve this. You can define this capacity using a risk-based approach, for example, by considering the:

  • nature of the pollutants
  • effects on downstream wastewater treatment
  • sensitivity of the receiving environment

5. You can only discharge wastewater from this buffer storage after you have taken appropriate measures to control, treat, or reuse the water.

6. You must have spill contingency procedures to minimise the risk of an accidental emission of raw materials, products, and waste materials, and to prevent their entry into water.

7. Your emergency firefighting water collection system must take account of additional firefighting water flows, firefighting foams, and other firefighting media. You may need emergency storage lagoons to prevent contaminated firefighting water reaching a receiving water body. This should be considered as part of your fire prevention plan.

8. You must consider and, if appropriate, plan for the possibility that you need to contain or abate accidental emissions from:

  • overflows
  • vents
  • safety relief valves

If this is not advisable on safety grounds, you must focus on reducing the probability of the emission.

Security measures

9. You must have security measures in place to prevent:

  • entry by vandals and intruders
  • damage to equipment
  • theft
  • fly-tipping
  • arson

10. Facilities must use an appropriate 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

Fire prevention

11. There are 3 fire prevention objectives. You must:

  • minimise the likelihood of a fire happening
  • aim for a fire to be extinguished within 4 hours
  • minimise the spread of fire within the site and to neighbouring sites

You must have a fire prevention plan that meets the requirements of our fire prevention plan guidance.

Other accident prevention measures

12. You must maintain control in an emergency using one or a combination of the following measures:

  • alarms
  • process trips and interlocks
  • manual interventions

13. You must:

  • make sure all the monitoring, measurement, and control devices you would need in an emergency are easy to access and operate in an emergency
  • maintain the equipment so it is in a good state of repair through a preventive maintenance programme and a control and testing programme
  • use techniques such as suitable barriers to prevent moving vehicles damaging equipment
  • have procedures in place to avoid incidents due to poor communication between operating staff during shift changes, or following maintenance or other engineering work
  • where relevant, use equipment and protective systems designed for use in potentially explosive atmospheres

Record keeping and procedures

14. 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 chemicals, which are present (or likely to be) and which could have environmental consequences if they escape – many apparently innocuous substances (for example, AdBlu) can damage the environment if they escape
  • have procedures for checking and segregating ELVs to make sure they are compatible with other substances they may accidentally come into contact with
  • make sure that any documents that may be needed in the event of an incident are accessible

2.5. Contingency plan and procedures

1. You must have and implement a contingency plan and management procedures to make certain you comply with all your permit conditions and operating procedures during maintenance or shutdown at your site.

2. Your contingency plan must also contain provisions and procedures to make sure that you:

  • do not exceed storage limits in your permit and you continue to apply appropriate measures for storing and handling ELVs
  • stop accepting ELVs unless you have a clearly defined method of recovery or disposal and enough permitted storage capacity
  • as far as possible, know in advance about any planned shutdowns at ELV management facilities where you send ELVs

3. Your contingency plan must include plans and procedures for circumstances where you cannot send your ELVs to other sites due to their planned or unplanned shutdown.

4. If you produce waste material at your facility, your contingency planning must consider issues with storage capacity for the waste.

5. You must make your customers aware of your contingency plan, and of the circumstances in which you would stop accepting ELVs from them.

6. You must consider whether the sites or companies you rely on in your contingency plan:

  • can take the ELVs 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

Where circumstances mean you could exceed your permitted storage limits or compromise your storage procedures, you must look for alternative disposal or recovery options. You must not discount alternative disposal or recovery options on the basis of extra cost or geographical distance.

You must not include unauthorised capacity in your contingency plan. If your contingency plan includes using temporary storage for additional ELVs on your site, then you must make sure your site is authorised for this storage and you have the appropriate infrastructure in place.

7. Your management procedures and contingency plan must also:

  • identify known or predictable malfunctions associated with your technology and the procedures, spare parts, tools, replacement equipment and expertise needed to deal with them
  • include a record of spare parts held, especially critical spares – or state where you can get them from and how long it would take
  • have a defined procedure to identify, review and prioritise items on site which need a preventative regime.
  • include all equipment whose failure could directly or indirectly lead to an impact on the environment or human health
  • identify and decommission ‘non-productive’ or redundant items such as tanks, pipework, retaining walls, bunds, reusable ELVs containers, ducts, filters, and security systems
  • make sure you have the spare parts, tools, and competent staff needed before you start maintenance

8. Your management system must include procedures for:

  • auditing your performance against all these contingency measures
  • reporting the audit results to the site manager
  • taking corrective actions as necessary

2.6. Site decommissioning

1. You must consider the decommissioning of the site at the design stage and make suitable plans to minimise risks during later decommissioning.

2. For an existing site, identify potential decommissioning risks and take steps to address these. Changes and design improvements should be made as and when site is upgraded, or when construction and development works are carried out at your site. Examples of design improvements could include avoiding using underground tanks and pipework. If it is not economically possible to replace them, you must protect them by secondary containment or a suitable monitoring programme.

3. You must have, and maintain, a decommissioning plan to demonstrate that the site will be:

  • decommissioned without causing pollution
  • returned to a satisfactory condition

4. Your decommissioning plan should include details of:

  • whether you will remove or flush out pipelines and vessels (where appropriate) and how you will empty them of any potentially harmful contents
  • site plans showing the location of all underground pipes and vessels
  • how you will remove asbestos or other potentially harmful materials generated from storing the waste and treatment operations, unless we have agreed it is reasonable to leave such liabilities to future owners
  • methods for dismantling buildings and other structures as part of the site closure, and for protecting surface water and groundwater during construction or demolition at your site
  • protecting of surface water and groundwater during construction or demolition at your site
  • any soil testing needed to check for any pollution caused by the site activities, and information on any remediation needed to return the site to a satisfactory state when you cease activities, as defined by the initial site condition report
  • the measures proposed, once activities have definitively stopped, to avoid any pollution risk and to return the site of operation to a satisfactory state (including, where appropriate, measures relating to the design and construction of the site)
  • the clearing of deposited residues, ELVs and any contamination resulting from the ELV treatment activities

5. When the site is changing use, you should make sure that you decontaminate equipment taken out of use and remove it from the site.