As an environmental consultant, I spend a lot of time helping companies become registered ATFs. This includes applying for an environmental permit and producing all of the associated surveys to accompany the application, including complying with the Fire Prevention Guidance published by the Environment Agency.
Along with the aforementioned applications, I tend to get asked to help with the ELV permit after the company has chosen a site and signed the leasehold with the landlord.
Below are some of the most common issues encountered with sites during the ELV application process that have not been considered by the company before they signed the leasehold:
- Proximity To Sites of Special Scientific Interest (SSSI’s) & Other Protected Areas
Unfortunately, if you are located close to a SSSI or an area of outstanding natural beauty, you will not be allowed to apply for a standard rules environmental permit. The distances allowed are printed on the standard rules permit itself. However, many operators fail to take these into account.
You will have to apply for a “Bespoke” permit if you are close to one of these protected areas and subsequently your fees to the Environment Agency and associated work involved will be much greater.
- Access To Water Supplies
The fire prevention guidance stipulates that you must have access to water to put out a fire on your largest waste pile. You’ll need a water supply of at least 2,000 litres a minute for a minimum of 3 hours for a 300 cubic metre pile of combustible material. This is not usually a problem if you are on an industrial estate and are close to a water hydrant, however, several of my clients have had to privately fund a water hydrant installation or install a large water tank on-site because they are located in rural areas.
- Site Is Above A Source Protection Zone or Primary Aquifer
If your chosen site is above an aquifer or close to an abstraction point used for drinking water, the Environment Agency will ask you to undertake further risk assessments and mitigation measures to protect this resource. This may include installing an impermeable surface to prevent the infiltration of contaminated water and enhanced security and bunding arrangements to make sure that contaminated water does not seep into the ground during an emergency or fire.
- Sealed Drainage System
All ELV permits require a sealed drainage system. This means that any rainwater in contact with waste cannot enter a surface water system, even if you have an interceptor installed. Your options are to
a) Roof the waste areas – so only clean water enters the surface water system
b) Divert water to a foul sewer with agreement of the local water company
c) Ensure that all water is collected in a blind sump and tankered away
For many sites this causes the biggest problem, especially again if they are situated in rural areas where there is no access to a foul sewer and drainage runs are poor.
- Physical Size Of The Site
Although the permit conditions may be straight forward to comply with, quite often the restricting factor on most sites is compliance with the fire prevention plan guidance. There is a requirement to keep waste at least 6m from the site perimeter (A 6m clearance all round the yard from the boundary where waste cannot be stored) and all other waste piles. There is also a requirement for a quarantine area with 6m clearance all round it.
If your site is small you may not be able to store or treat the volume of ELV’s you want to make the business viable. Your only option will be to install specially designed firebays.
If you need help becoming a registered ATF and need to make an environmental permit Application call us on 01428 768 087 or Paul on 07790147084.