TBT 14: Permit Compliance HILLS’ ETHOS: IMPROVEMENT ENGAGEMENT PREVENTION ACCOUNTABILITY PROGRESSIVE FRONT FOOT ROLES AND RESPONSIBILITIES HWS – Toolbox Talk 14 Permit Compliance v

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. 1 of 15

TBT 14: Permit Compliance 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 2 of 15

TBT 14: Permit Compliance 3. Types of Permit A number of different types of EP exist Standard Bespoke Exemptions 3 of 15

TBT 14: Permit Compliance 4. General Management Typically 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. 4 of 15

TBT 14: Permit Compliance 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 5 of 15

TBT 14: Permit Compliance 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. 6 of 15

TBT 14: Permit Compliance 6. Permitted Activities Typical 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 7 of 16

7. Waste Acceptance Typical condition 2.2 Waste 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 8 of 15 TBT 14: Permit Compliance

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. 9 of 15

TBT 14: Permit Compliance 9. The Site Typical condition 2.4 The green line on the site plan indicates what? Other criteria need to be met 10 of 15

TBT 14: Permit Compliance 10. Emissions and monitoring Typical 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. 11 of 15

TBT 14: Permit Compliance 11. Information Typical condition 4.0 – broken into three sub-headings Records Typical condition 4.1 Records include site inspection forms, WTN/CN and those written in conjunction with Hills document control procedure/record procedure (EMCP 07 and 12). Reporting Typical condition 4.2 Quarterly and annual reports as specified in the permit. Amount and types of waste accepted/ transferred, monitoring results 12 of 15

TBT 14: Permit Compliance Notifications Typical condition 4.3 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. 14 of 15

TBT 14: Permit Compliance 12. Revision 1. 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 15 of 15

TBT 14: Permit Compliance 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