1. Mechanical treatment in shredders
Definition of mechanical treatment in shredders, when appropriate measures apply, implementing measures at new and existing facilities, site design and suitability.
Mechanical treatment in shredders includes plant such as:
- hammer mills
- chain mills
- rotary shears
- other similar equipment designed to fragment metal into smaller pieces to separate metallic and non-metallic fractions
Mechanical treatment in shredders includes using the equipment to re-size metal into smaller fragments for logistical or transport reasons.
It does not include shearers and guillotines which use a range of hydraulic machinery with hard steel blades to cut metals into manageable sizes.
There is a lot of overlap between best available techniques (BAT) for waste installation facilities and necessary measures for waste operation facilities. The Environment Agency uses the term ‘appropriate measures’ to cover both sets of requirements.
Appropriate measures are the standards that operators should meet to comply with their environmental permit requirements. This guidance sets out what you must consider when you assess the appropriate measures for your site. It is not definitive, and it does not replace your obligation to assess appropriate measures fully.
Some measures may not be suitable or relevant for your operation. Appropriate measures will depend on the:
- activities being carried out
- size and nature of the activities
- location of the site
For installations there are additional requirements for using energy and raw materials (including water) efficiently. These are called ‘process efficiency measures’.
Where a measure is not suitable, an operator can propose alternative measures that achieve the same level of environmental protection. Or they can provide an explanation of why the specific measure is not appropriate.
In certain situations, you may need to provide a higher standard of environmental protection, for example:
- where there are local sensitive receptors
- if there is a risk that an operation may exceed an Environmental Quality Standard
This guidance also covers some activities where legislation applies directly to that activity. This guidance, and any time scales for the appropriate measures, does not remove the need to comply with that legislation. For example, legislation relating to F-gases, persistent organic pollutants (POPs), or hazardous waste. This is not an exhaustive list.
The standards in this technical guidance have been grouped into the following sections. All sections apply to regulated facilities with an environmental permit to mechanically treat metal waste in shredders.
- General management
- Waste pre-acceptance, acceptance and tracking
- Waste storage, segregation and handling
- Waste treatment
- Emissions control
- Emissions monitoring and limits
- Process efficiency (measures for using energy, raw materials and water apply to Industrial Emissions Directive (IED) installations only)
Other generic technical guidance also applies to metal shredding facilities, including guidance on emissions, odour and noise.
You also need an approved fire prevention plan that meets the requirements of our fire prevention plan guidance.
Medium combustion plant (MCP) with a rated thermal input between 1 megawatt but less than 50 megawatts must comply with the relevant requirements of the Medium Combustion Plant Directive. Specified generator controls, unless excluded, apply to generators with a rated thermal input of up to 50 megawatts. See our guidance to find out if you need to meet the MCP or specified generator regulations.
The appropriate measures in this guidance apply to both new and existing facilities with a permit to mechanically treat metal waste in shredders.
For new facilities the appropriate measures must be in place before operations start. For existing facilities, if the cost of complying with the appropriate measures is disproportionate to the environmental benefit, immediate compliance may not be reasonable.
Through permit reviews, the Environment Agency will assess the current operating techniques of existing facilities against the relevant appropriate measures.
Where an operator is not using appropriate measures, we will expect them to provide improvement plans and timetables for implementing the relevant appropriate measures. We will review these proposals and set formal timescales for making the improvements needed. We will do this by varying the environmental permit to include improvement conditions.
Improvements at existing facilities are likely to fall into 1 of the following 2 categories.
Standard good practice requirements
For example, these could be:
- updated management systems
- waste, water and energy efficiency measures
- measures to prevent fugitive or accidental emissions
- waste acceptance and handling techniques
- appropriate monitoring equipment
Where these improvements are relatively low cost, operators should implement them as soon as possible and in any event within 12 months.
Larger, more capital-intensive improvements
For example, these could be:
- installing significant abatement equipment
- using a pre-shredder
- the significant redesign of facility layout, including the design and installation of new buildings or treatment plant
Operators should complete these improvements as soon as practicable and in any event within 3 years. However, local environmental impacts may mean you need to take action more quickly than the timescales provided here. For example, if there are sensitive receptors or an air quality management area close by.
Complying with BAT AELs
Existing installations must comply with relevant BAT Associated Emission Levels (AELs) by August 2022, unless we approve a derogation. BAT AELs are set out in the published Waste Treatment BAT Conclusions document.
New installations (including new or replacement plant at existing facilities or a substantial change to existing plant) must comply with any relevant BAT AELs from when operations begin, unless we approve a time limited derogation.
Section 3.6 of our Environmental Permitting charges guidance explains what we mean by a substantial change.
You should consider the potential impacts of climate change when selecting a site, especially:
- flood risk
- drought
- extreme temperatures
- extreme weather events
You should have enough space on site to manage wastes and to make sure that you minimise potential pollution impacts on nearby receptors. For example, you should have enough space for appropriate fire breaks between stockpiles of combustible waste, and to allow access for fire-fighting.
You must store and handle waste as far as technically and economically possible from sensitive receptors and watercourses. You must minimise unnecessary handling.
You must have enough space on site to operate your plant and equipment safely, and to segregate waste to prevent cross-contamination.
At the design stage you should consider:
- how you will monitor emissions from your site
- the access to waste treatment processes so you can take representative samples