6. Process monitoring appropriate measures

The additional appropriate measures for process monitoring at regulated facilities with an environmental permit for treating WTEE.

You must also follow the guidance for waste electrical and electronic equipment (WEEE).

1. You must monitor, assess and record the performance of your WTEE treatment plant on a continual basis. You must report this to the Environment Agency in line with the measures set out in this guidance and the conditions of your environmental permit.

2. You must record the number and type of WTEE that you process through your stage 1 and stage 2 treatment processes.

For stage 1 processes, you must record the number of:

  • WTEE by refrigerant type (VFC, VHC or other – for example, ammonia)
  • defective WTEE, identified by visual inspection (for example, no compressor, pressure gauge or manometer shows no gas pressure)

For stage 2 processes, you must record the:

  • number of WTEE by blowing agent type (VFC, VHC or other, such as carbon dioxide), and any that are identified as containing VIP
  • number of WTEE by appliance type (see section 6.2 on blowing agent recovery for more information on the relevant types – Type 1, Type 2, Type 3 and Type 4)
  • quantity (kg) of separate dismantled foam panel processed

3. You should use an independent laboratory to complete compliance tests and analysis on the waste fractions and residues produced by your treatment process. The laboratory should:

  • be appropriately accredited, for example by UKAS
  • use recognise accredited methods if they are available

The tests and analysis to determine the quantity of residual foam in metal and plastic fractions must not be done on-site, unless you have appropriately experienced and trained staff. You must keep records of staff training and experience.

The compositional tests and analysis carried out on oil, foam and gases must not be done on-site, unless you have an appropriately accredited laboratory and qualified staff.

You must have, and be able to provide, a full description of the material testing and analysis procedures and methods used. This must include details of relevant calibration methods and reference standards. You must keep records of your test results.

For further guidance on waste sampling, characterisation and analysis see:

4. You must weigh recovered gases, waste fractions and residues produced by your treatment process using calibrated electric scales of an appropriate precision.

5. You should make sure that relevant treatment plant, vessels and containers are cleaned and empty before doing the refrigerant recovery and annual blowing agent recovery assessments. This is unless pre-existing content can be accounted for and excluded from the gas recovery measurements and calculations.

6. Because of the high volatility of VFCs and VHCs, to avoid any loss of refrigerant or blowing agent gases you must:

  • fill sample containers to the top, closing and sealing them immediately after filling
  • close and seal the containers and vessels that samples have been taken from immediately after sampling
  • send all samples containing (or suspected of containing) these substances to the laboratory as quickly as possible – on the same or next day
  • store and transport samples below 4°C where possible

7. You must inform your Environment Agency inspector about the dates of sampling in advance, providing at least 5 working days’ notice.

8. If process monitoring shows that the performance of your treatment plant does not meet any of the standards stated in this guidance (for example, the refrigerant or blowing agent recovery rate standards, or compositional standards for waste fractions and residues), you must send a report to the Environment Agency, summarising:

  • the actions you will take to improve performance to achieve the standards given, including any additional sampling and testing
  • the dates you will complete these actions by, including the dates for any additional sampling and testing

6.1 Refrigerant recovery

1. You must assess and report plant performance against the refrigerant removal and recovery rate, stated in appropriate measure 9 of section 5.1 on stage 1 treatment (minimum of 90% recovery), on a 6-monthly basis. More frequent assessment and reporting may be required if your assessed recovery rate falls below the minimum recovery rate.

2. You must assess refrigerant recovery using a representative sample of the WTEE treated at your facility. The sample must reflect the range of WTEE types accepted for treatment and include a minimum of 100 intact appliances. You should select the WTEE to make sure it is in good condition, with the cooling circuit and compressors intact, legible rating plate or label in place, and inspected to confirm there is no visible damage or leaks.

3. Using calibrated electronic scales of an appropriate precision, you must weigh and record:

  • the mass of the chosen appliances before and after degassing
  • the mass of refrigerant and oil collected from the degassed appliances

Base this on a mass balance calculation comparing the weight of the WTEE before and after stage 1 degassing (before other parts and components are removed following degassing, for example, compressors), and the mass of refrigerant and oil collected (recording and comparing the mass of the collection vessels before and after degassing). Record the number of any defective units identified.

To calculate the amount of refrigerant collected as a percentage, for comparison to the performance standard, you should use the formula:

(A ÷ (B − C)) × 100 = % recovered

Where, A is the mass of refrigerant recovered (grams), B is the reduction in mass of degassed appliances (that is, mass of appliances before degassing minus mass after degassing (grams)) and C is the mass of oil recovered (grams).

4. In addition to the detailed 6-monthly assessment, you must record the total number and type of WTEE processed and quantity of refrigerant and oil recovered and report this to the Environment Agency on a quarterly basis. You must also record and report the number of defective WTEE treated (for example, appliances that have no gas pressure in the cooling circuit due to damage or removal of the compressor).

6.2 Blowing agent recovery

1. You must assess plant performance against the monthly blowing agent recovery rate, as stated in appropriate measure 13 of section 5.2 on stage 2 treatment (that is, a minimum recovery of 80%), on a monthly basis. The results of the monthly assessment should be reported to the Environment Agency on a quarterly basis. More frequent reporting may be required if your assessed recovery rate falls below the minimum stated.

2. You must report the total number and type of WTEE processed (based upon their blowing agent (VHC, VFC or other) and appliance type (Type 1, Type 2, Type 3, Type 4) and the quantity (mass) of blowing agent recovered. Where dismantled insulation panels are treated (for example, panels from cold rooms or large commercial refrigeration units) you must report the quantity (kg) of panel foam treated and it’s blowing agent type (VHC, VFC or other).

3. You must base the monthly assessment of stage 2 plant performance on the total number of WTEE and total quantity (mass) of dismantled panel foam treated during that month. You must compare the measured and recorded mass of blowing agent recovered during that month from the WTEE and dismantled panels treated to the theoretical mass available for recovery (based upon the number and type of appliances treated). You should calculate the theoretical mass of blowing agent available for recovery using the relevant values from the tables that follow. You must exclude recovered water from the calculation of recovered blowing agent.

4. You must also assess and report plant performance against the annual blowing agent removal and recovery rate stated in appropriate measures 13 of stage 2 treatment (that is, a minimum of 90% recovery) on an annual basis. More frequent assessment and reporting may be required if your assessed recovery rate falls below the target recovery rate.

5. You must base the annual assessment of stage 2 plant performance upon a representative sample of the WTEE treated at your facility. The sample must reflect the range of WTEE types accepted for treatment (excluding Type 4 appliances, unless theoretical blowing agent figures are agreed with the Environment Agency) and include a minimum of 100 appliances. You should select the WTEE to make sure it is in good condition, labelled with the type of blowing agent it contains and inspected to confirm there is no visible damage. The mass of recorded blowing agent collected from the treatment of the WTEE must be compared to the theoretical mass available for recovery, as detailed previously for the monthly assessment.

Theoretical foam and blowing agent (BA) content of untreated WTEE by type (in grams)

WTEE containing VFC blowing agents

These figures are calculated on the basis that the BA content of VFC foam is 8.2% w/w (82g per kg).

WTEE Type Type 1 Type 2 Type 3 and Type 4
Foam content 3,140 4,180 5,230
Blowing agent content 257 343 429

WTEE containing VHC blowing agents

These figures are calculated on the basis that the BA content of VHC foam is 3.8% w/w (38g per kg).

WTEE Type Type 1 Type 2 Type 3 & Type 4
Foam content 3,300 6,300 8,300
Blowing agent content 125 239 315

Notes about WTEE type and theoretical values

Source of data: CENELEC, 2017, Collection, logistics and treatment requirements for WEEE, Part 3-4: Specification for de-pollution – Temperature exchange equipment, PD CLC/TS 50625-3-4:2017, BSI Standards Publication.

Types of WTEE for blowing agent calculation:

  • Type 1 are refrigerators with storage capacity no more than 0.18m3 (for example, small under-counter refrigerators)
  • Type 2 are refrigerators or combined fridge-freezers with storage capacity from 0.18m3 to 0.35m3 (for example, full height refrigerators and standard freestanding fridge-freezers)
  • Type 3 are freezers with storage capacity no more than 0.5m3 or refrigerators or combined fridge-freezers with capacity greater than 0.35m3 and no more than 0.5m3 (for example, freezers, chest freezers and large freestanding fridge-freezers)
  • Type 4 are any refrigerators, freezers or combined fridge-freezers with a capacity over 0.5m3 (for example, very large American-style fridge-freezers and chest freezers)

You should record and report (in terms of type and number processed) treated WTEE that are not fridges, freezers or combined fridge-freezers and exclude them from blowing agent recovery rate calculations, unless you can determine a theoretical foam and blowing agent content for them.

Theoretical blowing agent content of WTEE is calculated by multiplying foam content of WTEE type by blowing agent content (% w/w). The Environment Agency will periodically review these benchmark figures.

You should calculate the theoretical blowing agent content of dismantled foam panels from large commercial or industrial WTEE (for example, commercial refrigerators and freezers used in retail premises) by multiplying the blowing agent content (% w/w) by the weight of foam processed. You may need to agree alternative BA content of foam figures with the Environment Agency for reporting and assessing blowing agent recovery for the treatment of dismantled panels from large commercial or industrial WTEE.

If you process WTEE with a missing door, and it is the full height and width of the appliance, you should assume the amount of foam contained in the appliance is 20% lower than the figure in the previous tables for the relevant type. If you process separate doors, you should assume the treatment of 5 doors is equal to 1 WTEE of the relevant type if they are the full height and width of the appliance in question. These figures should be corrected for appliances that have 2 doors. For example, for fridge-freezers with 2 doors of approximately the same size, each door would represent 10% of the foam contained in the appliance and 10 doors would equal 1 WTEE.

6.3 Residual materials

1. You must report the quantity (mass) of waste fractions and residues produced by your WTEE treatment processes and removed from site to the Environment Agency every quarter, in line with your permit conditions. This must include the quantity (mass) of refrigerant and blowing agents, oil, foam, metals, and plastics.

2. Every quarter, you must get a representative, composite sample (consisting of at least 3 individual samples) of relevant waste fractions and residues and send them for testing and analysis. This is to assess their composition against the standards set out in appropriate measure 10 of stage 1 treatment and appropriate measures 15 and 16 of stage 2 treatment. You must report the results of the analysis and comparison to the relevant material standards to the Environment Agency, in line with your permit conditions. More frequent assessment and reporting may be required if tests results show that standards are not being met.

3. You must test the waste fractions and residues for the following parameters and standards:

  • refrigerant in degassed oil (% w/w) – limit 0.9%
  • blowing agent in treated foam (% w/w) – limit 0.2%
  • untreated foam in plastic fraction (% w/w) – limit 1.0%
  • untreated foam in non-ferrous metal fraction (% w/w) – limit 0.5%

  • untreated foam in ferrous metal fraction (% w/w) – limit 0.5%