3. Waste pre-acceptance, acceptance and tracking appropriate measures
These are the appropriate measures for waste pre-acceptance, acceptance and tracking at regulated facilities with an environmental permit to mechanically treat metal waste in shredders.
These measures are designed to make sure operators select only appropriate infeed for processing, to achieve low emission levels in line with overall BAT objectives.
1. You must implement waste pre-acceptance procedures so that you know enough about a waste (including its composition) before it arrives at your facility. You need to do this to assess and confirm the waste is technically and legally suitable for your facility and processes.
2. Your procedures must follow a risk-based approach, considering:
- the source and nature of the waste
- its hazardous properties
- potential risks to process safety, occupational safety and the environment (for example, from deflagrations and other emissions such as noise or particulates)
3. You must get the following information in writing when you receive a customer query:
- details of the waste producer including organisation name, address and contact details
- the specific source of the waste – for example, ELV depollution site, general scrap metal transfer station, car manufacture, or metal from other types of manufacturing processes
- a description of the waste including its composition and quantity
- the List of Waste code (European Waste Classification, EWC, code)
- if the waste has an EWC code showing it is a non-hazardous mirror entry - you should request evidence of the assessment from the producer
- any hazardous properties or whether it contains any regulated chemicals, for example, POPs
- confirmation from the producer that ELVs have been depolluted to ELV directive requirements
- confirmation from the producer that drums will be accompanied by a certificate of cleanliness
4. You must also get confirmation that the waste does not contain a radioactive source. If there is a risk of radioactive contamination you must get confirmation that the waste is not radioactive, unless your facility is permitted to accept such waste.
5. You must consider whether specific wastes, from among those you are permitted to receive, have properties that can pose unacceptable risks to the site or process, for example, due to:
- a risk of deflagration (for example, gas or aerosol canisters, baled ELVs or undepolluted ELVs)
- a risk of fire (for example, small mixed WEEE containing Li-ion batteries, or Li-ion batteries within metal loads from other sources)
6. You should establish a list of these wastes and procedures for managing the risks from them.
You can verify the pre-acceptance information by contacting or visiting the producer. Dealing with staff directly involved in waste production can help to fully characterise a waste.
7. You must keep pre-acceptance records for at least 3 years in a computerised waste tracking system following receipt of the waste. If an enquiry from a waste producer does not lead to the receipt of waste, you do not need to keep records.
8. You must reassess the information required at pre-acceptance if the:
- waste changes
- process giving rise to the waste changes
- waste received does not conform to the pre-acceptance information
9. In all cases you must reassess the information required at pre-acceptance annually. The information required and the assessment made at the pre-acceptance stage is to make sure you:
- only accept wastes that are suitable for the site
- avoid accumulating waste
- have enough storage and treatment capacity
1. You must implement waste acceptance procedures to check that the characteristics of the waste received matches the information you obtained during waste pre-acceptance. This is to confirm that the waste is as expected and that you can accept it.
2. If the waste is not as expected, you must confirm that you can accept it as a non-conforming waste, or you must reject it. If you are rejecting hazardous waste you must follow the guidance on the procedure for rejecting hazardous waste.
3. Procedures should be documented and auditable and must follow a risk-based approach, considering:
- the source, nature and age of the waste
- the waste’s hazardous properties
- the waste’s potential to contain POPs
- potential risks to process safety, occupational safety and the environment (for example, from odour and other emissions)
- knowledge about the previous waste holders
Some facilities receive waste on an ad hoc basis, which may occur with loads of metal waste. In those instances you can still do pre-acceptance checks before you accept the waste. For example, by exchanging information at the weighbridge before accepting the waste on site.
4. You must assess the load to make sure it is technically (and legally) suitable for the plant. Your checks and assessment must be risk-based considering, for example, the:
- hazardous properties of the waste
- risks posed by the waste in terms of process safety, occupational safety and environmental impact
Storage areas
5. All relevant storage areas (quarantine, reception and general) and treatment processes in your facility must have the physical capacity needed for the waste you receive. You must not receive wastes if this capacity is not available. The amount of waste you receive must also comply with storage limits in your permit.
6. The waste offloading, reception and quarantine areas must have impermeable surfaces with a sealed drainage system. This system must collect all surface water run off and channel it to a blind sump, unless you can lawfully discharge it in another way.
7. You must clearly designate a materials reception area (or areas). Staff controlling the inspection, reception and validation of materials at the installation, must be trained in their respective roles.
Waste acceptance
8. You must weigh each load of waste on arrival to confirm the quantities against the accompanying paperwork, unless alternative reliable systems are available (for example, based upon volume). You must record the weight in the computerised waste tracking system.
9. You must check and validate all transfer documentation and resolve discrepancies before you accept the waste. If you believe the incoming waste classification and description is incorrect or incomplete, then you must address this with the customer during waste acceptance. You must record any non-conformances. If you have assessed the waste as acceptable for on-site storage or treatment, you must document this.
10. You must use clear criteria for rejecting non-conforming wastes. You must also have a written procedure for recording, reporting and tracking non-conforming wastes, including notifying the relevant customer or waste producer to prevent reoccurrence.
Monitoring for radioactive substances
11. You must have fixed radiation detectors on weighbridges to monitor waste delivered to the site for any radioactive substances or materials. These detectors must have both a visual and audible alarm. You must also have a hand held detector to investigate alarms generated by the fixed radiation detectors.
12. The radiation detection equipment must include solid state scintillation detectors and have a sensitivity to gamma radiation that is consistent with the minimum performance recommended by the International Atomic Energy Agency. These are specified in Annex IV of ‘Recommendations on Monitoring and Response Procedures for Radioactive Scrap Metal’, UNECE, 2006.
13. You must maintain, calibrate and test the radiation monitoring equipment in accordance with the manufacturer’s specification.
14. You must have clear procedures for responding to radiation detector alarms.
There is a standard rules permit available for radioactive material or radioactive waste that you receive unintentionally: SR2017 No1: Unintentional receipt of radioactive materials and radioactive waste by the operator of any facility which uses a radiation detection system.
Acceptance of drums and tanks
15. You must make sure you only receive and accept drums or tanks:
- that have a certificate of cleanliness
- with prior notice
- with hazard warning symbols obliterated
Acceptance of baled metal waste
16. You must produce and follow a detailed procedure for accepting and inspecting baled material before accepting bales for processing. For example, batch acceptance, inspection and upstream auditing.
17. You must carry out risk-based assessments for baled and other infeed materials. You must base your inspection and pre-processing procedures on these assessments before fragmentising. This may include, but not be limited to, different inspection frequencies for different customers, depending on risk.
Quarantine storage
18. You must establish quarantine areas for materials that are prohibited, awaiting full inspection, or awaiting testing or removal.
19. Quarantine storage must be for a maximum of 14 working days. For some limited and specific cases (for example gas cylinders and beer barrels) you can extend the quarantine storage time if the Environment Agency agrees.
20. You must have written procedures for dealing with wastes held in quarantine, and a maximum storage volume.
21. Quarantine storage must be separate from all other storage and clearly marked as a quarantine area.
22. You must identify and isolate gas cylinders and other prohibited items to remove them from the waste stream. You must store gas cylinders in locked cages. Where possible, you must send prohibited items back to the appropriate owner.
1. You must use a computerised tracking system to hold up-to-date information about the available capacity of the waste quarantine, reception, general and bulk storage areas of your facility. This must also include treatment residues and end-of-waste product materials.
2. Your waste tracking system must hold all the information generated during:
- pre-acceptance
- acceptance
- non-conformance or rejection
- storage
- repackaging
- treatment
- removal off site
You must make this information readily available
3. You must create records and update them to show deliveries, on-site treatment and despatches. Your tracking system will also operate as a waste inventory and stock control system. It must include this information as a minimum:
- the date the waste arrived on-site
- the original producer’s details (or unique identifier)
- a unique reference number
- waste pre-acceptance and acceptance information
- the intended treatment or disposal route
- accurate records of the nature and quantity of wastes held on site, including all hazards (identifying the primary hazards)
- where the waste is physically located on site
4. The tracking system must be able to report:
- the total quantity of waste present on site at any one time
- a breakdown by type of the waste quantities you are storing pending treatment or transfer
- the quantity of waste on site compared with the limits authorised by your permit
- the length of time the waste has been on site
- the quantity of end-of-waste product materials on site at any one time, and where applicable, details of any non-conformances and rejections
5. You must store back-up copies of computer records off site. Records must be readily accessible in an emergency.
6. You must hold acceptance records for a minimum of 2 years after you have treated the waste or removed it off site. You may have to keep some records for longer if they are required for other purposes, for example, hazardous waste consignment notes.