4. ELV storage
These are the appropriate measures for ELV storage at regulated facilities with an environmental permit to treat ELVs.
Directive 2000/53/EC (known as the ‘ELV Directive’) sets out minimum standards for dismantling and recycling ELVs. Its purpose is to minimise the environmental impacts of dismantling ELVs and to set targets for reuse, recycling, and recovery of ELVs and their components.
The ELV Directive requirements relate only to cars and light commercial vehicles. However, the Environmental Permitting Regulations (EPR) have extended these requirements to cover all motor vehicles, including motorbikes and commercial vehicles.
Sites that accept, depollute, and dismantle ELVs must have an EPR waste permit authorising the activity, and must have the following facilities:
- impermeable surfaces and sealed drainage for areas where the depollution process is carried out
- suitable storage for parts removed from the ELV that are destined for re-use – this will prevent damage to the parts
All undepolluted ELVs are classed as hazardous. They contain fluids and components that can cause pollution if not removed and handled correctly.
Oil contaminated parts (such as engines and gear boxes) must be stored in an area that has an impermeable surface and sealed drainage.
Oils, fluids, and other components removed as part of the depollution process should be stored in a manner that prevents contamination and in separate containers. If pollution is likely to occur, then fluid contaminated parts should be stored in an area that has an impermeable surface and sealed drainage.
Inadequate or poor depollution processes may lead to contamination of soils and water. This may also increase the risk of fire and explosions at sites that store and treat ELVs.
After dismantling, the remaining ELV shell is either crushed, baled, or sent intact to a metal shredder. In all cases the vehicle must be fully depolluted before crushing, baling, or shredding.
1. Areas storing undepolluted ELVs awaiting depollution must have the following infrastructure:
- an impermeable surface
- sealed drainage
Impermeable surface means a surface or pavement constructed and maintained to a standard sufficient to prevent the transmission of liquids beyond the pavement surface. It should be read in conjunction with the term sealed drainage system
Sealed drainage system in relation to an impermeable surface, means a drainage system with impermeable components which does not leak, and which will ensure that:
- no liquids will run off the surface other than into the system
- all liquids entering the system are collected in a sealed sump, except where liquids may be lawfully discharged
The definition of sealed drainage can vary between permits. Standard rules permits take a narrower definition of sealed drainage and bespoke permits may have additional specific conditions. It is important to always check the wording and conditions of the permit.
Permits issued before the ELV Regulations 2003 came into force were directly modified by the regulations to make the ELV Directive requirements apply.
Although the permitting parts of the ELV Regulations have been revoked, the Environmental Permitting Regulations have kept the condition that automatically applies the ELV Directive requirements to permits.
1. After the ELVs are fully depolluted they can be stored on either:
- an impermeable pavement with a sealed drainage system
- a hard standing
Hardstanding means ground surfaced with a durable material. It must have the ability to be kept clear of debris, remain level and rut free. It must be maintained so that it is permeable and does not cause surface water ponding.
2. Uncontaminated plastic, glass, ferrous and non-ferrous metals arising from ELVs can be stored on either:
- an impermeable pavement with a sealed drainage system
- a hard standing
3. You must store parts contaminated with oils in an area that has an impermeable surface and sealed drainage. Oils, fluids and other components removed as part of the depollution process should be stored in a manner that prevents pollution and in separate containers.
4. You may be able to store intact shock absorbers and undeployed airbags in otherwise fully depolluted ELVs on a hardstanding until you remove them for second hand parts, if you comply with the requirements of regulatory position statement (RPS) 195.
Dangerous Substances and Explosive Atmospheres Regulation 2002 (DSEAR)
5. You should assess areas of the site where explosive atmospheres could occur (for example, ELV depollution bays). Where appropriate, you must classify these into hazardous zones, following the Dangerous Substances and Explosive Atmospheres Regulation 2002 (DSEAR).
Battery storage
1. You must check for damage and the chemistry type of any batteries:
- produced through depollution activities on site
- accepted as discrete loads
2. You must do this before allocating them to the storage area.
3. You must isolate damaged batteries from other batteries.
4. You must store batteries in appropriate containers that are either:
- weatherproof
- stored in a building, but in a way that prevents them from being exposed to high temperatures
5. You must store:
- lead acid batteries upright in acid proof containers to prevent leaks and short circuits
- nickel metal hydride (Ni-MH) batteries in a way that will prevent them being damaged
6. You must not mix batteries of incompatible chemistries, for example lead acid batteries with Ni-MH batteries.
7. You must store lithium-ion (Li-ion) batteries from electric vehicles separately from other batteries.
8. You must store them in a way that prevents them from:
- coming into contact with any liquids
- being damaged
- being exposed to high temperatures