7. Emissions monitoring and limits appropriate measures
The emissions limits and appropriate measures for monitoring emissions to air and water at regulated facilities with an environmental permit for the treatment or transfer of waste batteries.
We may set emission limits and monitoring requirements in your permit, based on your emissions inventory and environmental risk assessment. We may need to set emission limits lower than those provided in this guidance to protect the environment.
Where you are required to monitor emissions to comply with the requirements of your environmental permit you must follow our monitoring guidance when carrying this out.
You must create and maintain an inventory (emissions inventory) of point source emissions to air and water (including emissions to sewer) for your facility.
7.1 Point source emissions to air
1. Your facility’s emissions inventory must include information about the relevant characteristics of point source emissions to air, such as the:
- average values and variability of flow and temperature
- average concentration and load values of relevant substances and their variability
- flammability, lower and higher explosive limits and reactivity
- presence of other substances that may affect the waste gas treatment system or plant safety – for example, oxygen, nitrogen, water vapour, dust
2. Monitoring locations must meet the Environment Agency’s Monitoring Certification Scheme (MCERTS) standards. Monitoring must be carried out using MCERTS qualified accredited methods and MCERTS certified staff. Further guidance can be found in our guidance M1 sampling requirements for stack emissions monitoring.
3. You must carry out emissions monitoring when the plant is operating at or near to full treatment capacity. Information regarding the plant treatment processing rate and air flow rate at the time of monitoring must be recorded and submitted with the monitoring results.
4. You must monitor point source emissions to air from your treatment plant for the following substances using the monitoring standards stated. You must monitor at the frequencies stated and meet the specified emission limits unless your permit states alternative requirements.
Channelled emissions to air from the treatment of waste batteries
Dust
Monitoring standard – EN 13284-1.
Frequency – every 6 months.
Emission limit – 5mg/m³.
In addition, you should monitor for the following substances and meet the specified emission limits where the substance concerned is identified as relevant based on your facility’s emissions inventory unless your permit states alternative requirements.
TVOC (total volatile organic compounds)
Monitoring standard – EN 12619.
Frequency – every 6 months.
Emission limit – 30mg/m³.
Dioxin-like polychlorinated biphenyls (PCBs)
Monitoring standard – EN 1948-1, -2 and -4.
Frequency – every 12 months.
Dioxins and furans (PCDD/F)
Monitoring standard – EN 1948-1, -2 and -3.
Frequency – every 12 months.
Brominated flame retardants (BFRs)
Monitoring standard – Method based on procedural requirements of EN 1948, or other standard as agreed by the Environment Agency.
Frequency – every 12 months.
Metals and metalloids excluding mercury (including As, Cd, Co, Cr, Cu, Li, Mn, Ni, Pb, Sb, Se, Tl, V, Zn)
Monitoring standard – EN 14385.
Frequency – every 12 months.
Emission limit – set based upon environment risk assessment.
Total mercury
Monitoring standard – EN 13211.
Frequency – every 3 months.
Emission limit – 7 µg/m³.
Sulphuric acid
Monitoring standard – US EPA method 8.
Frequency – every 6 months.
Emission limit – 10mg/m³.
Hydrogen chloride
Monitoring standard – EN 1911.
Frequency – every 6 months.
Emission limit – 10mg/m³.
Hydrogen fluoride
Monitoring standard – CEN TS 17340.
Frequency – every 6 months.
Emission limit – 1mg/m³.
Sulphur dioxide
Monitoring standard – EN 14791.
Frequency – every 6 months.
Emission limit – 150mg/m³.
Ammonia
Monitoring standard – EN ISO 21877.
Frequency – every 6 months.
Emission limit – 10mg/m³.
Perfluorooctanoic acid (PFOA), perfluorooctane sulfonate (PFOS)
Monitoring standard – US EPA OTM-45, or other standard as agreed by the Environment Agency.
Frequency – every 12 months.
Other poly fluoroalkyl substances (PFAS)
Monitoring standards – US EPA OTM-45, US EPA OTM-50, or other standard as agreed by the Environment Agency. US EPA OTM-55 was under development at the date of publication but should also be considered once available.
Frequency – every 12 months.
Periodic monitoring results should consist of the average value of 3 consecutive measurements of at least 30 minutes each. For some parameters, due to analytical limitations, a longer sampling period may be required (for example, dioxins and furans and dioxin-like PCBs should be monitored over a single period of at least 6 hours).
Monitoring frequencies may be reduced if emission levels are proven to be sufficiently stable over time.
Other monitoring requirements and limits may also apply to other relevant substances that are identified through your emissions inventory, depending upon the type and composition of the waste batteries treated and nature of your treatment process.
7.2 Point source emissions to water or sewer
1. Your facility’s emissions inventory must include information about the relevant characteristics of point source emissions to sewer or water, such as:
- average values and variability of flow, pH, temperature, and conductivity
- average concentration and load values of relevant substances and their variability – for example, chemical oxygen demand (COD) and total organic carbon (TOC), nitrogen species, phosphorus, metals, priority substances or micropollutants
- data on bio-eliminability – for example, biological oxygen demand (BOD), BOD to COD ratio, Zahn-Wellens test, biological inhibition potential, for example, inhibition of activated sludge
2. For relevant emissions to water or sewer identified by the emissions inventory, you must carry out monitoring of key process parameters (for example, waste water flow, pH, temperature, conductivity, or BOD) at key locations. For example, these could either be at the:
- inlet or outlet (or both) of the pre-treatment
- inlet to the final treatment
- point where the emission leaves the facility boundary
3. For the following types of discharges, you must monitor point source emissions to water or sewer for the substances listed using the monitoring standards stated. You must meet the specified emission limits unless your permit states otherwise.
Direct discharges to water from the treatment of waste batteries
TOC
Monitoring standard – EN 1484
Frequency – every month
Emission limit – 60mg/l
COD
Monitoring standard – ISO 6060
Frequency – every month
Emission limit – 180mg/l
The requirement is to monitor for either total organic carbon or chemical oxygen demand
Total suspended solids
Monitoring standard – EN 872
Frequency – every month
Emission limit – 60mg/l
Direct or indirect discharges to water from the treatment of waste batteries
Hydrocarbon oil index
Monitoring standard – EN ISO 9377-2
Frequency – every month
Emission limit – 10mg/l
Direct or indirect discharges to water from the treatment of waste batteries, when the substance concerned is identified as relevant based on your facility’s emissions inventory
Metals and metalloids
Monitoring standard – various EN standards available, including EN ISO 11885
Frequency – every month
Emission limits:
- arsenic, 0.05mg/l
- cadmium, 0.05mg/l
- chromium, 0.15mg/l
- copper, 0.5mg/l
- lead, 0.1mg/l
- nickel, 0.5mg/l
- mercury, 0.005mg/l
- zinc, 1.0mg/l
- manganese (limit set based upon environment risk assessment)
- cobalt (limit set based upon environment risk assessment)
- lithium (limit set based upon environment risk assessment)
PFOA and PFOS
Monitoring standard – various standards available, including ISO 21675, ISO 25101 and EN 17892, or other standard as agreed by the Environment Agency.
Frequency – every 6 months
Other PFAS
Monitoring standard – various standards available, including ISO 21675, EN 17892 and US EPA 1633A, or other standard as agreed by the Environment Agency.
Frequency – every 6 months
Decabromodiphenyl (deca-BDE)
Monitoring standard – EN 16694
Frequency – every 6 months
Monitoring frequencies may be reduced if the emission levels are proven to be sufficiently stable over time.
Monitoring frequencies for discharges to sewer may be reduced if the downstream waste water treatment plant abates the pollutants concerned.
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