In part one of three articles, WAMITAB trainer and assessor Linda Waite discusses what is required to ensure that your vehicle recycling facility complies when acquiring the necessary environmental permit.
If your Authorised Treatment Facility (ATF) operates under an Environmental Permit, then you need to have a Management System (MS) in place that shows what procedures you have in place to minimise the risk of pollution from your activities to comply with your permit conditions.
If you have a waste permit granted before 6 April 2008 that does not require you to have an MS, you will still need to manage and operate your waste activity in line with a written management system.
Your MS must be in place before you start operating, it must be implemented, or you will be in breach of your permit. If your site is going to have combustible waste stored on it, you will also need a Fire Prevention Plan – we will look at this plan at a future date.
The amount of information you will need in your management system will depend on how complicated and risky your activities are; here are some of the things you will need to include.
You can develop and maintain your own MS or use an environmental management system scheme; using an accredited certified management system is not a guarantee that you will meet your permit conditions; you are responsible for implementing your MS effectively and making sure you comply with permit conditions.
What to put in your Management System (MS)
Your MS must include a plan of your site, drawn to scale, showing where the activities covered by your permits/exemptions take place. It must show buildings; storage facilities for hazardous materials like oil and fuel, chemical stores, waste materials; location of items used in accidents and emergencies, like absorbents for chemical spills; entrances and exits that can be used by emergency services; points designed to control pollution, e.g., inspection or monitoring points; trade effluent or sewage effluent treatment plants; effluent discharge points; and land that you believe is contaminated, e.g., areas of your site that have previously been used for industrial purposes.
It must also show areas particularly vulnerable to pollution that are on or near to your site, foul and combined drainage facilities marked in red and your surface water drainage, facilities marked in blue including the direction of flow of the water in the drain; the location of discharge points to the sewer, watercourse or soakaway; the location of manhole covers and drains; and the location of stop and diverter valves and interceptors.
The plan must show the location of mains water, gas and electricity supplies on your site, including the mains water stop tap; gas and electric isolating valves and switches; the routes for gas, electricity and water supplies around your site – electric wiring and gas and water pipes must be labelled on the plan.
The MS to break down the site operations that will be carried out during start-up, normal operation and shut down, into a list of activities and processes, for example, unloading waste, storing waste, incinerating waste. List the wastes that will be produced by each activity or process and the steps you will take to prevent or minimise risks to the environment from each. Be specific about the actions you will carry out to do this.
You must include a waste storage plan that states the longest amount of time that you will store each type of waste; how you will make sure you will not exceed these time limits – you need to consider your emissions when deciding how long you can store types of waste for; the maximum amount of each type of waste you will store in terms of volume; the maximum height of each storage pile on-site; how you will identify the specific types of waste you are storing; how you will separate different types of waste if required; and how you will make sure your site only takes waste that your permit allows you to store.
The MS will need to have a plan for how the infrastructure of your site and any machinery will be maintained. You must maintain any machinery according to the manufacturers or suppliers’ recommendations; you will need to record each time you carry out maintenance.
You need a contingency plan to minimise the impact on the environment of any breakdowns, enforced shutdowns, and any other changes in normal operations due to flooding or other extreme weather.
You need an accident prevention and management plan for dealing with any incidents or events that could result in pollution. More about this in the next article.
If you would like to find out more, please contact Linda on 07814 932225 or email her at lindawaite1@aol.com
