Select a waste recovery or disposal method for your environmental permit
How to choose a waste recovery or disposal method and assess its risks when applying for or changing your bespoke environmental permit.
Applies to England
To operate under an environmental permit, you must do a risk assessment predicting the environmental impact that different ways of disposing of waste will have.
In your risk assessment you must compare the different options you have for recovering or disposing of the waste you produce. You need to do this when you’re:
- choosing between recovery or disposal options for the waste you produce
- doing a derogation options appraisal because you cannot operate within the Best Available Technique (BAT) associated emissions levels
Best Available Techniques are the techniques you can use that are the best for preventing or minimising emissions and impacts on the environment. Waste is any material that you do not reuse on site for the purpose it was originally intended for.
To find out which waste recovery or disposal options are available to you, read the BAT reference note (BREF) for your sector. If you choose recovery or disposal methods that are not listed in BREF, you’ll need to justify your decision using the instructions in this guide.
When identifying your waste recovery or disposal options, you should also:
- consider ways to prevent producing waste, eg by changing the raw materials your process uses
- consider ways to reduce the amount of waste you produce eg consider producing less waste or recycling your waste
You also need to make sure the waste recovery or disposal options you choose cause the least damage to the environment as possible. Read the waste hierarchy to find out which options cause the least damage.
Follow these steps to complete your risk assessment.
- Find the different ways you could recover or dispose of your waste.
- Create your waste recovery or disposal ‘scenarios’ - different combinations of waste recovery or disposal methods that you could use for the different types of waste that you produce.
- Compare your waste recovery or disposal scenarios.
- Choose the scenario that you propose to use.
If you produce waste at your installation, you must also:
- read the risk assessment overview
- follow ‘duty of care’ rules
What to include in your assessment
In your assessment you must create a table for each recovery or disposal scenario you want to compare. You should create tables for at least 3 scenarios.
In the table for each scenario, you must include the:
- nature of the waste you produce eg hazardous, non-hazardous
- hazard rating of your waste
- waste recovery or disposal methods you’ll use for each type of waste
- waste code number and ‘environmental impact score’ of each recovery or disposal method
- amount of waste you’ll dispose of each year via each recovery or disposal method
Once you’ve created tables for each waste recovery or disposal scenario, you need to calculate the total impact score of each scenario. Send these details to the Environment Agency with your bespoke permit application.
Generally, the Environment Agency will only allow you to operate using the waste recovery or disposal scenario with the lowest impact score.
Create tables for your waste recovery or disposal scenarios
You need to create the following tables, with your own details, for each of your waste recovery or disposal scenarios. Each scenario is split into ‘waste streams’ which show the different types of waste that you’d dispose of, and the different recovery or disposal methods you’d use for them.
You can create your own tables with the headings given in the examples or you can use the Environment Agency’s H1 software tool to make these tables for you. You can use the tool to create bar charts to compare your waste recovery and disposal scenarios.
To get the tool, contact the Environment Agency’s National Customer Contact Centre on 03708 506506.
Example scenario 1
| Waste stream number | Type of waste | Nature of waste | Hazard rating | Recovery or disposal method you’ll use | D or R code | Recovery or disposal method impact score | Amount of waste (tonnes per year) |
|---|---|---|---|---|---|---|---|
| 1 | Bottom ash | Non-hazardous | 8 | Recycling | R4 | 3 | 2000 |
| 2 | Bottom ash | Non-hazardous | 2 | Landspreading | R10 | 4 | 3000 |
| 3 | Ferrous metal | Non-hazardous | 4 | Releasing waste into rivers and lagoons | D4 | 30 | 1000 |
| 4 | FGT residue | Hazardous | 10 | Biological and physical-chemical treatment | D9 | 12 | 3000 |
Example scenario 2
| Waste stream number | Type of waste | Nature of waste | Hazard rating | Recovery or disposal method you’ll use | D or R code | Recovery or disposal method impact score | Amount of waste (tonnes per year) |
|---|---|---|---|---|---|---|---|
| 1 | Bottom ash | Non-hazardous | 8 | Permanent storage | D3 | 8 | 2000 |
| 2 | Bottom ash | Non-hazardous | 2 | Landfill | D5 | 30 | 3000 |
| 3 | Ferrous metal | Non-hazardous | 4 | Biological and physical-chemical treatment | D8 | 12 | 1000 |
| 4 | FGT residue | Hazardous | 10 | Recycling | R5 | 3 | 3000 |
Nature of waste and hazard rating
Under the ‘nature of waste’ heading in the table, you need to show if the waste is hazardous or not. You can find out if your waste is hazardous by following the Environment Agency’s WM3 guidance on waste classification.
Under the ‘hazard rating’ heading in the table, you need to show the hazard rating of your waste.
Use the following hazard rating scores:
- hazardous waste - score 10
- stable non-reactive hazardous waste - score 8
- biodegradable non-hazardous waste - score 4
- other non-hazardous waste - score 2
- inert waste - score 1
Choose waste recovery or disposal methods
Under the ‘recovery or disposal method you’ll use’ heading in the table, you need to show the recovery or disposal method for each waste stream.
You must assess all waste recovery or disposal methods that are possible for you to use at your site. You do not need to assess methods that are impossible for you to use.
You must show the Environment Agency why you chose not to include a particular waste recovery or disposal method in your risk assessment.
If there is a technical reason that you cannot use a particular recovery or disposal method, you can show this in writing - you do not need to provide mathematical evidence.
If a recovery or disposal method is too expensive for your site to operate economically, you need to show the Environment Agency how much this method would cost you in £ per tonne of waste.
You can use BAT for your sector. If you want to propose to use an alternative method to BAT, you must tell the Environment Agency why. You must also show that the method you propose is not more damaging to the environment than BAT.
‘D or R code and environmental impact score
Under the ‘D or R code’ heading in the table, you need to show the number for your recovery or disposal method.
Some common codes are given below - check the waste framework directive (scroll down to annex I or II) to find the code that most closely matches your recovery or disposal options.
Under the ‘Recovery or disposal method impact score’ heading in the table, you need to show the score for your recovery or disposal method.
Some scores are given below. The higher the score, the more impact the waste recovery or disposal method is likely to have on the environment.
Choose from the following list:
- composting - R3 - score 2
- recycling of wood, metal, plastic or glass - R3, R4, R5, R11, R12 - score 3
- chemical recovery - R2 to R9 - score 4
- landspreading - R10 - score 4
- using waste as fuel - R1 - score 6
- biological treatment (with energy recovery) - D8 - score 8
- incineration (with energy recovery) - D10 - score 10
- biological and physico-chemical treatment - D8, D9 - score 12
- releasing waste into rivers and lagoons - D6, D7 - score 15
- permanent storage - D3, D12 - score 17
- incineration without energy recovery - D10 - score 20
- landfill - D1 or D5 - score 30
Calculate the total impact of each scenario
You need to calculate the total impact score of each scenario using the information in your tables.
To work this out, do the following for each waste stream in that scenario and add the result for each waste stream together:
- Multiply your disposal method environmental impact score by the hazard rating score for the type of waste being recovered or disposed of.
- Multiply the result by the quantity of waste being recovered or disposed of (tonnes per year).
Choose a waste disposal scenario
You should choose to use the waste recovery or disposal scenario that has the lowest total impact on the environment.
If you do not choose the scenario with the lowest total impact, you must explain to the Environment Agency why you chose a different scenario.
Send your assessment to the Environment Agency
You need to send:
- all the tables you’ve created for each scenario
- your calculations showing the total impact score of each scenario
- details of the waste recovery or disposal scenario you’d like to use
Send these details to the Environment Agency along with your application for a bespoke permit. You can email everything to enquiries@environment-agency.gov.uk or post to:
Permitting Support Centre
The Environment Agency
Quadrant Two
99 Parkway Avenue
Sheffield
S9 4WF
Check if you need to complete other risk assessments
Check if you need to complete other risk assessments. Once you’ve done all the required risk assessments, submit them with your permit application. You can also use the risk assessment tool to submit your air emissions risk assessment.