5. Waste treatment appropriate measures
The additional appropriate measures for waste treatment at regulated facilities with an environmental permit for treating WTEE.
You must also follow the guidance for waste electrical and electronic equipment (WEEE).
1. Treatment plant and equipment must only be operated by appropriately trained and competent staff. You must be able to demonstrate this through your written training procedures and records.
2. You must use appropriate measures to minimise waste handling at your facility where possible, for example using:
- hydraulic lifting
- belt conveyors
- other mechanical means
3. Before subjecting WTEE to stage 2 destruction, you must remove any:
- capacitors containing polychlorinated biphenyls and any capacitors over 25mm containing substances of concern
- mercury switches
Where necessary, you should also allow any excess water to drain from the WTEE before treating it.
4. You must fully contain and seal the treatment plant and equipment you use to carry out stage 1 and stage 2 treatment of WTEE, including any on-site treatment of recovered gases. This is to make sure you capture, collect and contain all liquids and gases released from the equipment during the treatment process in appropriate gas-tight storage vessels and containers.
5. The plant and equipment you use to carry out stage 1 and stage 2 treatment of WTEE (including any on-site treatment of recovered gases) and any associated plant, for example, storage vessels, pipework and plant used to generate or store nitrogen gas, must be regularly:
- monitored
- inspected
- maintained
- serviced
This is to:
- make sure they continue to function efficiently and safely throughout their operational life
- prevent emissions to the environment (for example, of contaminated water, dust, VFC and VHC gases)
You must be able to demonstrate this through your written procedures and records.
6. You must support routine inspection by regularly using proprietary gas detection equipment as part of a structured and documented leak detection and repair programme. This is to check for and repair any gas leaks from the treatment plant or associated infrastructure, including:
- pipework
- valves
- seals
- connections
- storage vessels
7. You must place storage vessels holding the refrigerant and blowing agent collected from the stage 1 and stage 2 treatment processes on calibrated electronic scales of an appropriate precision. This is so you can monitor how much gas has been recovered and identify (in advance) when a tank will need to be changed.
8. For any oil, refrigerant or blowing agent removed from site, you must have procedures in place to make sure you record its:
- quantity (mass)
- origin (for example, from the treatment of WTEE) and destination
- date of collection
- mode of transport
- treatment method (for example, incineration or recycling through refining)
9. You must sample and analyse separately collected wastewater resulting from the treatment of WTEE. This is to decide appropriate treatment and whether it can be recovered and reused or must go for disposal.
1. Your stage 1 treatment process must:
- extract oil and refrigerant from the cooling circuit in the same step, using a vacuum suction system, to achieve the best recovery rate
- use high-integrity equipment (such as a specially designed drill heads or piercing pliers) that pierces the cooling circuit of the WTEE in a way that maximises recovery of both oil and refrigerant
Gas pressure in the cooling circuit will assist in the removal of the oil. To maximise the recovery of oil, your degassing process should make sure the oil is removed before the gas, by allowing the oil in the circuit to drain into the compressor before piercing it at the lowest point.
2. You must only remove the compressor from WTEE after you have checked and confirmed that the cooling circuit has been fully degassed.
3. You must:
- minimise the amount of oil remaining in the compressor after treatment
- check that any remaining oil residues will not drip out from the compressor, unless the compressor is stored in (or over) a suitable covered container designed to drain and collect residual oil
- make sure that oil removed from WTEE is not mixed with oil from other equipment or sources in your facility
4. Your operating procedures must make sure that compressors are routinely checked and tested to confirm they contain no (or minimal) residual oil before storage. For example, this could be by choosing a number of compressors at random each day and leaving them inverted, to drip, for an appropriate period. If you find any compressors drip oil, you must take appropriate action to improve the treatment process or operating procedures to prevent this happening.
5. Oil removed from WTEE, including residual oil that has been drained and collected from compressors, may contain significant quantities of dissolved refrigerant. To prevent the loss of refrigerants to the atmosphere, you must keep the oil within a gas-tight system or container until it has been fully degassed (treated to remove the refrigerant gas).
6. You must transfer the recovered refrigerants to appropriate gas-tight storage vessels through a fully contained gas-tight system, for on-site treatment or off-site transfer.
7. You must carry out the degassing treatment process:
- on an impermeable surface with sealed drainage
- in a building or under cover
8. Your stage 1 treatment plant must be designed to remove and collect all (more than 99%) of the refrigerants and oils from the cooling circuit and compressor of WTEE and prevent emissions to the environment.
9. Your treatment process must achieve and demonstrate a refrigerant removal and recovery rate of at least 90% (see appropriate measures for refrigerant recovery in process monitoring appropriate measures.
10. Your degassing process must be designed and operated to make sure that the residual refrigerant content (VFC and VHC) in recovered compressor oil is less than 0.9% weight per weight (w/w), unless the oil is both:
- transferred immediately to a suitable sealed container to prevent fugitive emissions
- sent for further refrigerant recovery or destruction
Your sampling and testing must demonstrate that you’ve met the standard. You must be able to demonstrate this through your written sampling and testing procedures and records.
11. If you accept WTEE containing ammonia refrigerant for treatment, you must either:
- make sure that the ammonia refrigerant is safely removed from the cooling circuit by your stage 1 treatment process
- demonstrate that the stage 2 destruction plant is capable of safely treating the equipment and that it will capture and contain the ammonia released upon destruction and prevent emissions to the environment
1. There must be no prior size reduction of WTEE, other than minimal cutting of disassembled foam panels (for example, from large commercial refrigerators) where this is necessary for them to fit inside the plant.
Before stage 2 treatment, you must only cut panels to the extent required to fit in the treatment plant. Once cut, these panels must be prioritised for treatment to minimise storage time (treating them within 24 hours if possible).
If you cut panels, you must do this:
- inside a building
- using appropriate, intrinsically safe equipment
- with measures in place to prevent and minimise (collect and abate) emissions of dust and blowing agent gases
2. Your stage 2 treatment process must be designed and operated to make sure you:
- sort and separate foam, plastic and metal (ferrous and non-ferrous) fractions to achieve high standards of recovery
- treat the foam fraction to maximise the release and capture of the blowing agent gas
- collect and contain the treated PUR foam (including dusts and powders)
3. The destruction process must:
- take place in an enclosed treatment chamber
- be provided with effective extraction and abatement systems that capture and prevent emissions of blowing agent gases, dust and particulates
4. Your treatment plant must make sure that the blowing agent gas released from the foam is collected and contained in gas-tight equipment and vessels. You should collect the blowing agent gas and prevent emissions of VFCs or VHCs to air using one or a combination of the techniques below:
- cryogenic condensation, using a cryogenic fluid such as liquid nitrogen
- adsorption on activated carbon
You should store the collected gases in appropriate gas-tight storage vessels for destruction at a permitted facility, for example, by incineration. Destroying or breaking down the blowing agent on-site as part of the permitted treatment process (for example, by thermal or catalytic oxidation) may be an acceptable alternative to off-site destruction.
5. If you use a gas adsorption process your treatment plant should be served by at least 2 filters, which operate in parallel, so that at least one is adsorbing whilst the other one is regenerating. During filter regeneration, following removal of the blowing agent from the waste gas for collection (for example, by compression and cooling), the treated gas should be fed back into the adsorption system to minimise emissions of any residual VFCs or VHCs.
6. You must prevent and control emissions to air of dust and particulate-bound metals from your stage 2 treatment process using an appropriate air extraction and abatement system. Your abatement system should use one or a combination of:
- cyclonic separation
- fabric filtration
- wet scrubbing
7. Your treatment process should recover and collect water separately from the blowing agent. However, if they are not separated by the treatment process and are collected together, you must:
- collect and contain the blowing agent and water mixture in gas-tight pressure vessels
- monitor the quantity (mass) of water collected with the blowing agent and record this weight for weight (w/w) on a regular basis, so that it can be excluded from blowing agent recovery calculations
8. Your enclosed treatment plant must be designed and operated to control the concentration of gases and prevent the risk of explosion. You should do this by one of the following methods:
- inert atmosphere – continuously monitoring and maintaining the concentration of oxygen below the relevant limiting oxygen concentration by injecting nitrogen
- forced ventilation (treatment of VHC equipment only) – continuously monitoring and maintaining the hydrocarbon concentration below the relevant lower explosive limit through forced aeration
9. Your plant must be fitted with appropriate gas detection and monitoring systems to:
- detect any build-up of explosive vapours
- trigger automatic safe shutdown of the plant if the relevant limiting oxygen concentration or lower explosive limit is exceeded
10. If your treatment process is not conducted under an appropriate inert or forced ventilation atmosphere, you must take appropriate measures to prevent WTEE containing hydrocarbon blowing agents (or other flammable substances and materials) from entering the process.
11. You must carry out continuous indicative monitoring of the air contained in plant extraction systems for VFC gases using infrared analysers and record the results.
12. If you use thermal or catalytic conversion systems to destroy or break down recovered blowing agent on-site as part of the permitted treatment process, you should consider and use energy recovery options where possible (for example, for preheating untreated gases or reactors).
13. Your plant must be designed, operated and maintained to maximise the removal and recovery of blowing agent and prevent emissions to the environment. Your treatment process must achieve and demonstrate both of the following blowing agent removal and recovery rates:
- 90% or more, based upon an annual assessment of a selected sample of WTEE
- 80% or more, based upon a monthly assessment of the WTEE treated during that period
Further information on how plant performance should be assessed against these removal and recovery rates is provided in the appropriate measures for blowing agent recovery.
14. If you destroy recovered refrigerants or blowing agents on-site as part of the permitted treatment process, for example, using thermal or catalytic oxidation, you must achieve and demonstrate a 99.99% destruction efficiency through your routine process and emissions monitoring. Operation of your destruction process must be monitored continuously and recorded to demonstrate that the required destruction efficiency is always maintained.
15. Your treatment process must be designed and operated to make sure that the residual blowing agent (VFC and VHC) content of treated foam is less than 0.2% w/w. Sampling and testing must demonstrate that the standard is met. You must be able to demonstrate this through your written sampling and testing procedures and records.
16. Your treatment process must be designed and operated to make sure that the residual content of untreated foam (foam that has not been fully treated to release the blowing agent) in the recovered metal and plastic fractions is less than:
- 0.5% w/w in metal streams (ferrous and non-ferrous)
- 1.0% w/w in plastic streams
These limits apply both to the quantity of foam attached to pieces of metal and plastic and the quantity of loose pieces of foam present in the recovered fractions. You must show you meet both standards through sampling and testing. You must be able to demonstrate this through your written sampling and testing procedures and records.
The standards referred to in this measure are set with the purpose of demonstrating appropriate measures are in place to separate and treat WTEE insulating foam. They are not set to determine whether an output fraction of waste should be classified and described as a mixed waste or separate fraction for onward transfer.