6. Emissions control appropriate measures
These are the appropriate measures for emissions control at regulated facilities with an environmental permit to mechanically treat metal waste in shredders.
1. You must identify, characterise and control emissions from your activities that may cause pollution. See our guidance on controlling emissions.
1. You must contain the waste treatment plant (including shredders) to make sure you collect, extract and direct all process emissions to an appropriate abatement system for treatment before release.
2. You must identify the main chemical constituents of the site’s point source emissions as part of the site’s inventory of emissions to air. You must include the speciation of volatile organic compounds (VOCs) if you have identified them in the emissions inventory and it is practicable to do so.
3. You must assess the fate and impact of the substances emitted to air, following the Environment Agency’s air emissions risk assessment methodology.
4. To reduce point source emissions to air (for example, dust, VOCs and odour) from waste treatment, you must use an appropriate combination of abatement techniques, including one or more of the following systems:
- cyclonic filtration
- fabric filters
- wet scrubbing
- high efficiency particulate (HEPA) filter
5. You must assess and design vent and stack locations and heights to make sure dispersion capability is adequate.
6. Where monitoring is required, you must install suitable monitoring points. Monitoring points will be required to meet MCERTS standards. You can find further guidance in the Environment Agency’s M1 – Guidance on sampling requirements for monitoring stack emissions.
7. Your procedures must make sure you correctly install, operate, monitor and maintain abatement equipment. For example, this includes monitoring and maintaining:
- appropriate flow and chemical concentration of scrubber liquor
- the handling and disposal or regeneration of spent scrubber or filter medium
1. You must use appropriate measures to prevent emissions of dust, mud and litter and odour. See our guidance on suggested appropriate measures to control dust, mud and litter and to control odour.
2. You must design, operate and maintain storage and treatment plant in a way that prevents fugitive emissions to air, including dust, organic compounds and odour. Where that is not possible, you must minimise these emissions.
Storage and treatment plant includes associated equipment and infrastructure such as:
- shredders
- conveyors
- skips or containers
- building fabric, including doors and windows
- pipework and ducting
3. You must minimise the number of potential diffuse dust and particulates emission sources, using a combination of the following:
- limiting the drop height of material
- using wind barriers
- covering conveyor belts, including enclosure of transfer points
- fitting spray nozzles or rubber flaps to the inlet and outlet of the shredder mill
- using misting systems and wind barriers in areas with significant dust formation
- venting pipe work and ducting to an appropriate abatement system to prevent fugitive emissions
4. To make sure fugitive emissions are collected and directed to appropriate abatement, your treatment plant must use high integrity components (for example, seals or gaskets).
5. You must use your waste pre-acceptance, waste acceptance and site inspection checks and procedures to identify and manage wastes that could cause, or are causing, fugitive emissions to air. Examples could include gas cylinders, items concealed in baled waste, or poorly depolluted ELVs. When you identify any of these wastes you must:
- take appropriate, risk assessed measures to prevent and control emissions
- prioritise their treatment or transfer
Storage of odorous or dusty wastes
6. Where necessary, to prevent fugitive emissions to air from storing and handling odorous or dusty wastes, you should use a combination of the following measures (7 to 13).
7. You should store and handle the waste within an enclosed building including:
- light fractions of the shredder residue
- dust derived from sweeping the waste treatment and storage areas
- dust derived from the abatement equipment
8. You should use fully enclosed material transfer and storage systems and equipment, for example:
- conveyors
- hoppers
- containers
- tanks and skips
9. You should keep enclosed buildings and equipment under adequate negative pressure with an appropriate abated air circulation and extraction system. Where possible, locate air extraction points close to potential emissions sources.
10. You should:
- use fast-acting or ‘airlock’ doors that default closed
- dampen potential sources of diffuse dust emissions (such as the shredder inlet and outlet, traffic areas and open handling processes) with water or fog
11. You must fully enclose and contain pre- and post-treatment shredder plant to prevent emissions.
12. You must design and operate the shredder plant using appropriate process interlocks. The plant should not operate unless it is enclosed and contained, for example, only working when the loading door on the hopper is closed or sealed.
13. You must contain and extract dust emissions from the shredder plant to an appropriate abatement system, for example HEPA air filtration.
14. Where ambient dust monitoring is required it must be carried out by MCERTS qualified staff.
15. You must use monitoring equipment that meets as a minimum the MCERTS Performance Standards for Indicative Ambient Particulate Monitors. You must calibrate the equipment following the manufacturer’s recommendations and it must be capable of providing representative data that accurately reflect PM10 levels produced operations at the site.
16. Where a dust management plan is required, you must develop and implement it following our guidance.
Maintenance and cleaning
17. You must set up a leak detection and repair programme and use it to promptly identify and mitigate any fugitive emissions from treatment plant and associated infrastructure (for example, pipework, conveyors, tanks).
18. You must regularly inspect and clean all waste storage and treatment areas, equipment (including conveyor belts) and containers. You must contain any residues collected during cleaning.
19. Your maintenance and cleaning schedules must make sure that tanks and plant are regularly cleaned to avoid large-scale decontamination activities.
20. You must take measures to prevent the corrosion of plant and equipment (for example, conveyors or pipes). This includes:
- selecting and using appropriate construction materials
- lining or coating equipment with corrosion inhibitors
- regularly inspecting and maintaining plant
21. You must have an appropriate regular maintenance programme covering all buildings, plant and equipment. This must also include protective equipment such as air ventilation and extraction systems, curtains and fast-action doors used to prevent and contain fugitive releases.
22. If you wash out drums or containers, you must design and operate the washing process and associated equipment in a way that prevents fugitive emissions to air. For example, you could carry out this activity in a contained or enclosed system.
Odorous wastes
23. You must have procedures to minimise the amount of time odorous wastes spend in your storage and handling systems (for example, pipes, conveyors, hoppers, tanks). In particular, you must have provisions to manage waste during periods of peak volume.
24. You must have measures to contain, collect and treat odorous emissions, including using contained buildings and plant or equipment with appropriate air extraction and abatement. We do not consider masking agents to be appropriate measures to treat odorous emissions.
25. You must monitor odour abatement systems to ensure optimum performance. For example, you should make sure that scrubber liquors are maintained at the correct pH and replenished or replaced at an appropriate frequency.
26. Contaminated waters have potential for odours. You must store them in covered or enclosed tanks that are vented to abatement systems, or store them in containers.
27. Where you expect odour pollution at sensitive receptors, or it has been substantiated, you must periodically monitor odour emissions using European (EN) standards, for example either:
- dynamic olfactometry according to EN 13725 to determine the odour concentration
- EN 16841-1 or -2 to determine the odour exposure
If you use methods that are not covered by EN standards (for example, estimating odour impact), you should use ISO, national or other international standards to make sure you use data of an equivalent scientific quality. You must set out the monitoring frequency in the odour management plan.
28. Where you expect odour pollution at sensitive receptors, or it has been substantiated, you must also set up, implement and regularly review an odour management plan. It must be part of your management system and include all the following elements:
- actions and timelines to address any issues identified
- a procedure for conducting odour monitoring
- a procedure for responding to identified odour incidents, for example, complaints
- an odour prevention and reduction programme designed to identify the sources, to characterise the contributions of the sources and to implement prevention and reduction measures
29. Where an odour management plan is required, you must develop and implement it following our odour management guidance.
Deflagration Management
30. To prevent deflagrations and to reduce emissions where deflagrations have occurred, we may require a deflagration management plan. This should include:
- a deflagration reduction programme designed to identify the source, and to implement measures to prevent deflagrations, for example, inspecting waste input and removing dangerous items such as gas cylinders and undepolluted ELVs
- a review of historical deflagration incidents and remedies and sharing deflagration knowledge
- a protocol for responding to deflagration incidents
31. You must also have one or both of the following:
- pressure relief dampers, to relieve pressure waves from deflagrations that may otherwise cause damage and subsequent emissions
- pre-shredding – a low speed shredder installed upstream of the main shredder
32. Where there are a large number of deflagration incidents at a site, and other measures taken do not reduce the number, we may require you to install a pre-shredder.
1. You should design the layout of the facility to locate potential sources of noise (including building exits and entrances) away from sensitive receptors and boundaries. You should locate buildings, walls, and embankments so they act as noise screens.
2. You must use appropriate measures to control noise, including for example:
- adequately maintaining plant or equipment parts which may become more noisy as they deteriorate – for example, bearings, air handling plant, building fabric, and specific noise attenuation kit associated with plant or machinery
- closing doors and windows of enclosed areas and buildings
- avoiding noisy activities at night or early in the morning
- minimising drop heights and the movement of waste and containers
- using broadband (white noise) reversing alarms and enforcing the on-site speed limit
- using low-noise equipment, for example, drive motors, fans, compressors and pumps
- adequately training and supervising staff
- where possible, providing additional noise and vibration control equipment for specific noise sources – for example, noise reducers or attenuators, insulation, or sound-proof enclosures
- including pressure relief control on shredder plant enclosures to take account of possible deflagration incidents
3. Where you expect noise or vibration pollution at sensitive receptors, or it has been substantiated, you must create, use and regularly review a noise and vibration management plan. This must be part of your environmental management system, and must include:
- actions and timelines to address any issues identified
- a procedure for conducting noise and vibration monitoring
- a procedure for responding to identified noise and vibration events, for example, complaints
4. The noise and vibration management plan should also include a noise and vibration reduction programme designed to:
- identify the source(s) of noise and vibration
- measure or estimate noise and vibration exposure
- characterise the contributions of the sources
- implement prevention and reduction measures
5. Where a noise management plan is required, you must develop and implement it following our noise management plan guidance.
This guidance also has information about noise and vibration risk assessments.
1. You must identify the main chemical constituents of the site’s point source emissions to water and sewer as part of the site’s inventory of emissions.
2. You must assess the fate and impact of the substances emitted to water and sewer following the Environment Agency’s risk assessment guidance.
3. Discharges to water or sewer must comply with the conditions of an environmental permit or trade effluent consent. Relevant sources of waste water include (but are not limited to):
- water or condensate collected from treatment processes
- vehicle washing
- vehicle oil and fuel leaks
- washing of containers
- spills and leaks in waste storage areas
- loading and unloading areas
- uncovered storage areas
4. To reduce emissions to water and sewer, if you need to treat waste water before discharge or disposal, you must use an appropriate combination of treatment techniques, including one or more of the following:
- preliminary or primary treatment – for example, physical separation
- physico-chemical treatment – for example, adsorption, precipitation, chemical oxidation or reduction
- solids removal – for example, coagulation, sedimentation, filtration or flotation
1. You must use appropriate measures to control potential fugitive emissions and make sure that they do not cause pollution. See the guidance on emissions to water and leaks from containers.
2. You must have the following in all operational areas of the facility:
- an impermeable surface
- spill containment kerbs
- sealed construction joints
- a sealed drainage system
3. The sealed drainage system must contain all surface water run off and channel it to a blind sump unless you can lawfully discharge it.
4. You must collect and treat separately each water stream generated at the facility. For example, surface run-off water or process water. You must base separation on pollutant content and the treatment required. In particular, you must make sure you segregate uncontaminated water streams from those that require treatment.
5. You must use suitable drainage infrastructure to collect surface drainage from areas of the facility where you store, handle and treat waste. Drainage must be effective to make sure waste is not stored or treated in standing water.
6. Depending on the pollutant content, you must either:
- recirculate what you have collected
- discharge it in accordance with an environmental permit or trade discharge consent
- send it for further treatment
7. You must have design and maintenance provisions in place to detect and repair leaks. These must include regularly monitoring, inspecting and repairing equipment and minimising underground equipment and infrastructure.
8. You should provide appropriate buffer storage capacity at your facility to store waste waters, taking into account:
- potential abnormal operating scenarios and incidents
- the nature of any polluting substances and their impact on the downstream waste water treatment plant and receiving environment
9. You must have appropriate measures in place to monitor, treat and reuse the water held in the buffer storage before discharging.
10. You must take measures to prevent emissions from washing and cleaning activities, including:
- directing liquid effluent and wash waters to foul sewer or collecting them in a sealed system for off-site disposal – you must not discharge them to surface or storm drains
- where possible, using biodegradable and non-corrosive washing and cleaning products
- storing all detergents, emulsifiers and other cleaning agents in suitable bunded or containment facilities, within a locked storage area, or in a building away from any surface water drains
- preparing cleaning or disinfection solutions in contained areas of the site and never in areas that drain to the surface water system
11. Where relevant, you must have measures to prevent pollution from the on-site storage, handling and use of oils and fuels. See the guidance on oil storage regulations for business.
Spill response plan
12. You must produce and implement a spillage response plan and train staff to follow it and test it.
13. Your procedures and associated training must make sure you deal with spillages immediately.
14. You must keep spill kits at locations close to areas where a spillage could occur and make sure relevant staff know how to use them. Make sure kits are replenished after use.
15. You must stop spillages from entering drains, channels, gullies, watercourses and unmade ground. You must make available absorbent materials, sand or drain mats for use when required.
Designing and maintaining surfacing and subsurface structures
16. You must make sure your spillage response plan includes information about how to recover, handle and correctly dispose of waste produced from a spillage.
17. For subsurface structures, you must:
- establish and record the routing of all site drains and subsurface pipework
- identify all sub-surface sumps and storage vessels
- engineer systems to minimise leakages from pipes and make sure they are detected quickly if they do occur, particularly where hazardous substances are involved, see the list of hazardous substances
- provide secondary containment or leakage detection for sub-surface pipework, sumps and storage vessels
- establish an inspection and maintenance programme for all subsurface structures, for example, pressure tests, leak tests, material thickness checks or CCTV
18. For surfacing, you must design appropriate surfacing and containment or drainage facilities for all operational areas, taking into account:
- collection capacities
- surface thicknesses
- strength and reinforcement
- falls
- construction materials
- permeability
- resistance to chemical attack
- inspection and maintenance procedures
19. You must have an inspection and maintenance programme for impermeable surfaces and containment facilities.
Tanks and bunding
20. You must bund all above-ground tanks containing liquids whose spillage could be harmful to the environment. Bunds must:
- be impermeable and resistant to the stored materials
- have no outlet (that is, no drains or taps) and drain to a blind collection point
- have pipework routed within bunded areas with no penetration of contained surfaces
- be designed to catch leaks from tanks or fittings
- have a capacity greater than 110% of the largest tank or 25% of the total tankage, whichever is the larger
- have regular visual inspections – any contents must be pumped out or otherwise removed under manual control after checking for contamination
- be fitted with a high-level probe and an alarm (as appropriate) if not frequently inspected
- have tanker connection points within the bund (where possible), otherwise provide adequate containment
- have programmed engineering inspections – normally visual, but extending to water testing if structural integrity is in doubt
- be emptied of rainwater regularly to maintain their containment capacity
You can find further guidance in Construction Industry Research and Information Association (CIRIA) Containment systems for the prevention of pollution (C736F)