6. Emissions control

These are appropriate measures for emissions control for a regulated facility permitted to store and treat or transfer (or both) ELVs. You must identify, characterise and control emissions from your activities that may cause pollution.

6.1. Enclosure within buildings

1. Enclosing activities within buildings can be an appropriate measure for preventing and minimising emissions of pollution. An appropriately designed building will reduce a range of pollutant types, such as noise, dust and odour.

2. A partially enclosed building may be an appropriate measure on its own, or together with other appropriate measures, depending on the site-specific circumstances. 

3. If your waste treatment activities are likely to cause (or are causing) significant pollution at sensitive receptors, and you cannot address this by alternative measures, you must carry out that waste treatment activity within an enclosed building. 

4. You must also carry out non-treatment activities in enclosed buildings if they are likely to cause (or are causing) significant pollution at sensitive receptors and you cannot address this by alternative measures. For example, activities such as storing and transferring waste (including loading and unloading).

5. An enclosed building means a construction designed to provide sheltering cover and minimise emissions of noise, particulate matter, odour, and litter. It must be enclosed on all sides.  

6. Enclosed buildings must be ventilated to provide a safe working environment for employees. Your building’s ventilation system must be properly designed and effective for the building to provide adequate containment and prevent fugitive emissions and unacceptable noise. You must understand and consider the needs of the occupants working in the building.  

7. You must regularly assess the integrity of your building for damage that could result in fugitive emissions, including noise breakthrough. You must prevent and minimise damage by implementing a maintenance programme. 

8. To reduce emissions of noise and vibration, the building must have appropriate acoustic seals on doors and windows. 

6.2. Point source emissions to air (channelled emissions)

1. You must use appropriate measures to make sure that you collect, extract, and direct all process emissions to an appropriate abatement system for treatment before release.

2. You must make an assessment of the fate and impact of the substances emitted to air, following the Environment Agency’s risk assessment guidance.

3. To reduce point source emissions to air (for example dust and odorous compounds) from the treatment of waste, you must use an appropriate combination of abatement techniques. Or you must demonstrate to the Environment Agency that your alternative abatement is equally effective.

4. You must have procedures to make sure that you correctly operate, monitor, and maintain abatement equipment.

5. Your monitoring should demonstrate the effectiveness of the abatement, so that you can take preventative or corrective action as necessary.

6.3. Fugitive emissions to air

1. You must use appropriate measures to prevent and minimise fugitive emissions to air, including:

2. You must use your waste pre-acceptance, waste acceptance and site inspection checks and procedures to identify and manage wastes that could cause, or are causing, fugitive emissions to air. When you identify any such wastes you must:

  • take appropriate risk-assessed measures to prevent and control emissions
  • prioritise their treatment or transfer

3. Where necessary to prevent fugitive emissions to air from the storage or handling of wastes, you should use a combination of the following measures:

  • store and handle the waste within a suitably enclosed area (for example bays), a building or enclosed building
  • keep doors closed except when access is required

4. You must have an appropriate, regular maintenance programme covering all buildings, plant, and equipment. It must help prevent emissions or minimise them.

Other measures for dust, mud, and litter

5. If your activities are likely to produce dust and particulates, mud, or litter that could cause pollution at sensitive receptors, or if such pollution has been substantiated, you must implement and regularly review a dust, mud and litter management plan. You must do this following our guidance. Your dust, mud and litter management plan must explain how you will prevent and minimise emissions of dust, mud, and litter from your facility. 

6. You should locate measures such as litter fencing, and micro-netting as close as possible to areas where you load and unload lightweight loose waste if this activity is done outdoors. You should not rely on fences and screens at the perimeter of your facility to stop litter escaping. 

Other measures for odour

7. If your activities are likely to produce odour pollution at sensitive receptors, or such pollution has been substantiated, you must implement and regularly review an odour management plan following our guidance, which includes H4 odour management. Your odour management plan must explain how you will prevent and minimise odorous emissions from your facility.

8. You must cover odorous or potentially odorous waters or liquids or keep them in enclosed tanks or containers. 

Other measures for noise and vibration

9. If your activities are likely to produce noise or vibration pollution at sensitive receptors, or such pollution has been substantiated, you must implement and regularly review a noise and vibration management plan.

10. You should follow our guidance on noise and vibration management: environmental permits. Your noise and vibration management plan must explain how you will prevent and minimise emissions of noise and vibration from your facility. 

11. You should take care not to drop ELVs or components as this could produce noise and vibration pollution.

12. If you are detonating airbags in situ, you must consider and implement the measures needed to prevent and minimise the risk of noise and vibration pollution.

6.4. Point source emissions to water (including sewer)

1. You must identify the main chemical constituents of your facility’s point source emissions to water and sewer as part of your inventory of emissions. 

2. You must assess the fate and impact of the substances emitted to water and sewer following the Environment Agency’s risk assessment guidance

3. Discharges to water or sewer must comply with the conditions of an environmental permit and a trade effluent consent. 

4. Relevant sources of wastewater include: 

  • runoff from all waste storage and handling areas, including loading, and unloading areas
  • condensate collected from treatment processes
  • vehicle washing
  • washing of containers and vessels
  • vehicle oil and fuel leaks
  • spills and leaks
  • rainwater from bunds around containers and tanks

If you need to treat wastewater before discharge or disposal, you must use appropriate treatment techniques. An appropriate combination of treatment techniques, for example, could include silt or solids removal and using an oil separator to manage site drainage.

5. You must segregate uncontaminated water streams (for example, clean runoff from roofs) from those that require treatment.

6. You must separate contaminated water streams based on pollutant content and treatment required. For example, you may need to collect and treat separately contaminated surface runoff water and process water.

6.5. Fugitive emissions to land and water

1. You must use appropriate measures to control potential fugitive emissions and make sure that they do not cause pollution. See the guidance on emissions to water and leaks from containers

2. You must design appropriate surfacing and containment or drainage facilities for all operational areas, considering: 

  • collection capacities
  • surface thicknesses
  • strength and reinforcement
  • falls
  • materials of construction
  • permeability
  • resistance to chemical attack
  • inspection and maintenance procedures
  • relevant standards of construction
  • end use, for example by tracked or wheeled vehicles or vehicle weight

3. Your drainage infrastructure must:

  • prevent incompatible wastes coming into contact with each other
  • make sure that fire cannot spread

4. You must store and treat all waste (except uncontaminated plastic, glass, ferrous and non-ferrous metals arising from ELVs) can be stored on either:

  • an impermeable surface with contained drainage that meets CIRIA 736
  • an equivalent approved standard

The impermeable surfaces must have sealed construction joints. These requirements do not apply in designated areas where the waste being stored or handled does not pose any significant risk of contaminating surface water or ground water. You must appropriately isolate these designated areas from other operational areas so that there cannot be any flows between them. This includes in the event of an accident, for example a fire.

5. You must provide bunds for all tanks containing liquids (whether waste or otherwise) that could be harmful to the environment if spilled. Bunds must meet CIRIA 736 or an equivalent approved standard and:

  • be impermeable, stable, and resistant to the stored materials
  • have no outlet (that is, no drains or taps) and drain to a blind collection point
  • have pipework routed within bunded areas with no penetration of contained surfaces
  • be designed to catch leaks from tanks or fittings
  • have an appropriate capacity
  • have regular visual inspections – any contents must be pumped out or otherwise removed under manual control after checking for contamination
  • be fitted with a high-level probe and an alarm (as appropriate) if not frequently inspected
  • have tanker connection points within the bund (where possible), and if not, possible you must provide adequate containment for spillages or leakage
  • have programmed engineering inspections (extending to water testing if structural integrity is in doubt)
  • be emptied of rainwater regularly to maintain the containment capacity

6. You must keep all above-ground tanks containing liquids (waste or otherwise) that could be harmful to the environment if spilled on an impermeable surface. This must have contained drainage that meets CIRIA 736 or an equivalent approved standard. You must fit the tanks with alarms and cut-out systems to detect and prevent leaks and spills.

7. You must minimise using subsurface equipment and infrastructure and decommission it where possible. For subsurface structures, you must:

  • establish and record the routing of all site drains and subsurface pipework
  • identify all subsurface sumps and storage vessels
  • engineer systems to minimise leakages from pipes and make sure they can be detected quickly if they do occur
  • provide secondary containment or leakage detection for subsurface pipework, sumps, and storage vessels – vessels must be fitted with alarms and cut-out systems to detect and prevent spills when filling
  • establish an inspection and maintenance programme for all subsurface structures, for example, pressure tests, leak tests, material thickness checks or CCTV

8. You must provide secondary containment that meets CIRIA 736, or an equivalent approved standard, for all drums and other mobile containers which: 

  • are greater than 200 litres in capacity and are kept outside
  • contain liquids (waste or otherwise) that could be harmful to the environment if spilled

9. You must comply with the oil storage regulations. These apply to non-hazardous wastes such as vegetable and cooking oil, as well as to biofuels and mineral oils. 

10. You must provide appropriate buffer storage capacity at your facility to store waste waters, taking into account: 

  • potential abnormal operating scenarios and incidents
  • the nature of any polluting substances and their impact on the downstream wastewater treatment plant and receiving environment

You must have appropriate measures to monitor, treat and reuse the water held in the buffer storage before discharging. 

11. You must take appropriate measures to prevent emissions from washing and cleaning activities, including: 

  • containing and directing spray, liquid effluent and wash-waters to foul sewer or collecting them in a sealed system for offsite disposal – you must not discharge them to surface or storm drains
  • where possible, using biodegradable and noncorrosive washing and cleaning products.
  • storing all detergents, emulsifiers, and other cleaning agents in suitable bunded or containment facilities, within a locked storage area, or in a building away from any surface water drains
  • preparing cleaning or disinfection solutions in contained areas of the site and never in areas that drain to the surface water system or groundwater

12. You must produce and implement a spillage response plan and train staff to follow it and test it. 

13. Your procedures and associated training must make sure you deal with spillages immediately. You should follow the manufacturer’s health and safety advice for any products or substances involved. 

14. You must keep spill kits at locations close to areas where a spillage could occur and make sure relevant staff know how to use them. You must make sure kits are replenished after use. 

15. You must stop spillages from entering drains, channels, gullies, watercourses, and unmade ground. You must make available proprietary sorbent materials, sand, booms or drain mats for use when required. 

16. You must make sure your spillage response plan includes information about how to recover, handle and correctly dispose of waste produced from a spillage. 

17. You must have a documented inspection and maintenance programme for impermeable surfaces and containment facilities and keep records to demonstrate its implementation. 

6.6. Pests

1. You must manage waste in a way that prevents pests. For example, if you do not manage flies, rats, and birds they can affect operations, be a nuisance to neighbours and pose an environmental and health hazard as a potential vector for pathogens. We have produced internal guidance for our officers on fly management. Contact us if you would like a copy. 

2. If you expect pests will cause pollution, hazard or annoyance at sensitive receptors, or if this has been substantiated, you must create, use and regularly review a pest management plan, following our guidance. 

3. Your pest management plan must include procedures for: 

  • inspecting for and controlling pests
  • rejecting loads of infested waste
  • treating pest infestations promptly, and removing waste if necessary
  • storing, handling, and using approved pest control products – you can get information on  using chemicals at work from the Health and Safety Executive

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