tbt 14: permit compliance hills’ ethos: improvement engagement prevention accountability...

TBT 14: Permit ComplianceHILLS’ ETHOS:

IMPROVEMENT ENGAGEMENT PREVENTION ACCOUNTABILITY

PROGRESSIVE FRONT FOOTROLES AND RESPONSIBILITIES

HWS – Toolbox Talk 14 Permit Compliance v001 23.02.12

TBT 14: Permit Compliance

1. What is an Environmental Permit?

An environmental permit is designed to protect the environment and people.

It allows regulators to:•concentrate resources on medium and high-risk operations; and•protect the environment and human health.

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2. When does a Permit apply?

Applies to activities which could harm the environment or human health unless controlled

Aims to:•Protect the environment•Deliver permitting and compliance effectively and efficiently•Promote best practice•Continue to fully implement EU legislation

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3. Types of Permit

A number of different types of EP exist•Standard•Bespoke•Exemptions

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4. General ManagementTypically condition 1.1 in an Permit

• The operator shall manage and operate the activities in accordance

with a written management system • Identifies and minimises all risks of pollution arising from activities

on the site• Operator must use technically competent persons and sufficient

resources• Maintain records to demonstrate compliance

In a bespoke permit, this section may also include management plans for energy efficiency, accident management, raw materials use and waste minimisation.

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5. Typical Management Plan Structure Contents, document review, introduction and summary of EMS are

typical of an Management Plan.

More specific information includes:• Site location, description and facility overview

– Receipt and storage of household waste– Receipt and storage of mixed recyclables– Loading and dispatch of waste and recyclables– Potential odour sensitive receptors

• Identification of odour sources and activities– Municipal ‘black bag’ household waste– Mixed recyclables – cans, glass bottles, paper, card and plastics– Loading and dispatch of waste and recyclables– Other potential odour sources

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• Control Measures– Building design and odour suppression systems– Failure or abnormal event scenarios

• Management Controls– Responsible person– Meteorological conditions– Olfactory monitoring– Complaints monitoring– Records

• Monitoring– Control trigger levels– Compliance actions– Response to complaints– Detection of moderate odour during olfactory survey– Corrective action– Reporting

The content of the Management Plan will change slightly depending on the permitted activity e.g. acceptance of hazardous waste, landfill activity etc.

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6. Permitted ActivitiesTypical condition 2.1

Tells you what you can and cannot do in relation to the site activities

What waste types and quantities permitted on site

The Operator is only authorised to carry out the activities specified in table 2.1 of the permit

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7. Waste AcceptanceTypical condition 2.2Waste acceptance procedures must be written into the management

system.

This is found in Hills’ EMOP 09 - HRCs waste acceptance procedure

Records must be kept of all wastes received on site in the form of a Waste Transfer Note (WTN) or Consignment Note (HWCN) (for Hazardous Waste if permitted).

A WTN must be kept for two years

A HWCN must be kept for three years

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8. Operating Techniques Typical condition 2.3

The activities shall only be operated using the techniques and in the manner described in the permit. Specific to the activities stated.

You can only carry out the activities listed in the permit.

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9. The Site

Typical condition 2.4

The green line on the site plan indicates what?

Other criteria need to be met

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10. Emissions and monitoringTypical condition 3.0

Sets out conditions relating to point source emissions

Other typical emissions where limits may be set (usually requires a bespoke permit) include:

• VOCs, bio-aerosols, particulates, odour and noise, landfill gas, stack emissions.

All should be monitored at regular intervals and controlled via management plans, if this is deemed necessary by the permit condition.

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11. InformationTypical condition 4.0 – broken into three sub-headings

Records


Records include site inspection forms, WTN/CN and those written in conjunction with Hills document control procedure/record procedure (EMCP 07 and 12).

Reporting


Quarterly and annual reports as specified in the permit. Amount and types of waste accepted/ transferred, monitoring results

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Notifications


As per permit. Certain events need to be reported to EA within stipulated timeframes.

Hills use procedure EMOP 06 – Schedule 6 and other Notifications to ensure these are undertaken appropriately.

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12. Revision1. What is an Environmental Permit?

2. When does it apply?

3. Types of Permit

4. Condition 1.1 – General Management

5. Management Plan Structure

6. Condition 2.1 – Permitted Activities

7. Condition 2.2 – Waste Acceptance

8. Condition 2.3 – Operating Techniques

9. Condition 2.4 – The Site

10. Condition 3.0 – Emissions and Monitoring

11. Condition 4.0 – Information including records, reporting and notifications

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Statistically, waste management and recycling has a very high accident rate

Do NOT walk on by!

Report accidents, incidents & near-misses!

“See it – sort it”

Do NOT become a statistic!HILLS’ ETHOS:

IMPROVEMENT ENGAGEMENT PREVENTION ACCOUNTABILITY PROGRESSIVE FRONT FOOT

ROLES AND RESPONSIBILITIES

tbt 14: permit compliance hills’ ethos: improvement engagement prevention accountability...

Documents

environmental permit

bespoke permit

permit compliance1

permit compliance2

permit compliance3

permit compliance4

permit compliance5

permit compliance6