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Vehicle Depollution and Dismantling Facilities - Environmental Permits [Hardfacts]

Introduction

Vehicle Depolluting/Recycling facilities now require Environmental Permits in order to operate. Environmental Permits are regulated under the Environmental Permitting Regulations (England and Wales) 2014. If you previously operated under a Waste Management Licence, this was automatically transferred to an Environmental Permit when the regulations changed.

Under the Environmental Permitting Regulations sites will either require a standard permit or a bespoke permit, both of which are issued by the appropriate Environment Agency. Standard permits are available to operators who want to comply with standard rules and are cheaper, quicker and easier to apply for than bespoke permits. The standard rules apply to the recovery (including storage) of all waste motor vehicles and do not permit the burning of any wastes in the open, inside buildings or in any form of incinerator. The rules also do not allow the storage of more than 25 tonnes of whole waste vehicle tyres. You can apply for a standard permit if you can comply with the standard rules and meet the following criteria:

  • The quantity of waste that can be accepted onto the site is less than 5,000 tonnes per annum
  • The only discharges to controlled waters are surface water from the roofs of buildings and from areas of the site not used for the storage or treatment of waste

The activities are not carried out within 200 metres of a European site, Ramsar site or Site of Special Scientific Interest (SSSI)

STANDARD PERMITS

If you operate under a standard permit you will need to familiarise yourself with the standard rules under that permit and ensure that you comply with these rules. Full details of these rules can be obtained from the Environment Agency (doc ref SR2011No3).The Environment Agency also publishes information to help you comply with your permit. Some of the areas you will need to consider in terms of compliance are as follows :

Management Systems

Your site must have a recorded management system, which identifies and minimises risks of pollution, including those arising from operations, maintenance, accidents, incidents, non-conformities, closure and those drawn to the attention of the operator as a result of complaints.

Competence

You must have sufficient persons who are competent in respect of the resposbilities to be undertaken by them in connection with the operation of the activities and you must be able to demonstrate this competence.  Operators have to comply with the requirements of an approved competence scheme or shall hold an appropriate certificate of technical competence or other approval issued by the Agency.  As an ongoing demonstration of competence, the competent person will be required to sit a continuing competence assessment every 2 years.     

Accident Management Plan

Your site needs to have a maintained and implemented accident management plan, which is reviewed at suitable intervals.

Permitted Activities

Operators are only authorised to carry out the activities specified and listed in the rules. It is important to check that you operate within these parameters.

Waste Acceptance

The site can only accept wastes that are of the type and quantity detailed in the rules. The waste must also conform to the description in the documentation supplied by the producer and holder.

The site

Your permit will have a plan attached to it which highlights the boundary of your site. It is essential that you do not operate outside this boundary.

Technical Requirements

The storage (including temporary storage) and treatment of waste motor vehicles shall meet the requirements of article 6(1) of the End-of-Life Vehicles Directive.

Minimum technical requirements for treatment in accordance with Article 6(1) and (3)are as follows :

Treatment operations for depollution of end-of-life vehicles :

  • Removal of batteries and liquefied gas tanks
  • Removal or neutralisation of potential explosive components, (e.g. air bags)
  • Removal and separate collection and storage of fuel, motor oil, transmission oil, gearbox oil, hydraulic oil, cooling liquids, antifreeze, brake fluids, air-conditioning, system fluids and any other fluid contained in the end-of-life vehicle, unless they

are necessary for the re-use of the parts concerned

  • Removal, as far as feasible, of all components identified as containing mercury

You must ensure that you are familiar and comply with these minimum technical requirements. There is a guidance document for Authorised Treatment Facilities on depolluting and end-of-life vehicles produced by Defra and BIS. Depolluting End-of-Life Vehicles.

Emissions of Substances

You must ensure that measures have been taken to ensure that emissions of substances not controlled by emission limits (excluding odour) do not cause pollution. You may be requested by the Environment Agency to prepare, submit and implement an Emissions Management Plan to formally demonstrate that these risks are being appropriately controlled.

There are specific control measures that need to be considered such a secondary containment (e.g. bunding) for liquid pollutants and acceptable surfaces types or containers for the storage of certain waste materials. It is important that you familiarise yourself with these requirements and ensure that your existing storage arrangements are compliant.

Odour

You must ensure that emissions containing odour are eliminated or controlled via an odour management plan.

Noise and Vibration

You must ensure that activities causing emissions of noise and vibration are controlled and a noise and vibration management plan exists where a recognised problem occurs.

Records

All records, plans and the management system must be held on the site and retained for at least 6 years. Records relating to off-site environmental effects and matters which affect the condition of land and groundwater must be retained until your permit is surrendered.

Reports

The Environment Agency will provide you with a form which needs to be submitted within one month of the end of each year. This form includes information relating to the site and the waste accepted and removed from it during the previous year. It is important that you submit this form including all the necessary information required within the prescribed timescale.

Notification

You must notify the Environment Agency in the event of certain changes, events or incidents. It is important that you familiarise yourself with the information that requires notification and the notification procedure.

BESPOKE PERMITS

If you do not meet the specified criteria or you cannot comply with any of the standard rules, you will need to apply for a bespoke permit. Your application must include additional information about the criteria that you cannot meet and how you intend to control the associated risks.

Further Information

Sources of Information and Sector Specific Guidance

Business Link (In Association with Environment

Agency/Netregs) www.businesslink.gov.uk

Environment Agency www.environment-agency.gov.uk

Motor Vehicle Dismantlers Association www.MVDA.org.uk

Department for Business Innovation and Skills www.gov.uk/government/organisations/department-for-business-innovation-skills

Next Steps:

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  • View our Tools and Templates
  • Call our Risk Helpline on 0345 366 66 66
  •  Email us at riskadvice@aviva.com

Please Note: This document contains general information and guidance and is not and should not be relied on as specific advice. The document may not cover every risk, exposure or hazard that may arise and Aviva recommend that you obtain specific advice relevant to the circumstances. AVIVA accepts no responsibility or liability towards any person who may rely upon this document.

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