«How to comply with your environmental permit for intensive farming Introduction and chapters Version 2 January 2010 EPR Intensive Farming Contents ...»
Operations The reference to "operations" in 1.1.1(a) means that you must consider how to minimise the environmental risks and impact of the normal running of the activities. Normal running includes stocking, de-stocking and empty periods. You should have contingency plans that ensure a minimum impact on the environment in the case of equipment breakdown, accidents, disease etc.
Maintenance Poor maintenance is a common cause of environmental incidents. Failure of plant or infrastructure (e.g. hard-standing, bunds) could increase emissions to the environment.
You must carry out a programme of planned preventative maintenance rather than waiting for equipment to fail.
You should use the manufacturers’ recommended inspection and maintenance schedules, or write down your justification for following any other schedule, to check for signs of leakage, corrosion and structural damage, security and correct operation.
Incidents and non-conformances Even when "incidents and non-conformances" occur, you are responsible for the environmental performance of the installation and for achieving compliance with the permit.
Incidents that require investigation include any malfunction, breakdown or failure of plant, equipment or techniques and any near misses. You should be able to cope with abnormal
operation and return the activity to normal operation. You and/or your staff must be able to:
• Detect abnormal operation and investigate the causes.
• Assess the information and decide what to do.
• In the short-term, get back to normal operation.
• In the long-term, take steps to make sure the problem doesn’t happen again.
• Where appropriate, make sure that the public would know what to do if a problem arises.
You are responsible for minimising the environmental impact of your activities and for responding to the concerns of the local community.
• Have a complaints system and do whatever is necessary to prevent, or where that is not possible, to minimise the causes.
• Unless there are overriding security reasons for not doing so, display an identification notice at or near the site entrance telling the public about the nature of the site and who they can contact for further information or to notify a concern. It should be easily readable
from outside the site in daylight hours and should include the following information:
▪ emergency contact name and telephone number of the permit holder and/or operator;
▪ statement that the site is permitted by the Environment Agency;
EPR Intensive Farming Chapter 1 - management Version 2How to comply January 2010 ▪ permit number;
▪ Environment Agency national numbers, 08708 506506 and 0800 807060 (incident hotline), (or any other number subsequently notified in writing by the Environment Agency).
Sufficient persons who are suitably competent You must have enough competent staff to manage and operate your activities without causing pollution. This includes contractors.
Staff should have clearly defined roles and responsibilities. You should write down the skills required for each post and keep records of how each individual in that post has gained those skills and how they are kept up to date with, for example, refresher training. Where appropriate, you should keep written instructions for the work as well. We will refer to these records and instructions if we need to investigate an incident. You can demonstrate
competence in various ways, for example:
• vocational qualifications e.g. NVQs;
• attendance at external or in-house training courses;
• those with approved training to cascade that training to other staff;
• mentoring as part of "on the job" training;
• experience (as long as there is evidence that it is kept up to date).
Site security You should have site security measures in place to prevent unauthorised access to the site, as far as practicable.
The objective of this is to ensure that the site is secure to prevent vandalism, which is a common cause of pollution incidents. What is appropriate will depend on the risks posed by the activity itself and the particular location.
To comply you should provide the following:
• security checks or supervision of people entering the site during normal working hours;
• gates that are closed and locked outside normal operating hours to prevent people walking or driving onto the site;
• fences or hedges around the site perimeter that prevent unauthorised access;
• individual facilities including slurry tank valves and oil tank outlets should be locked, and buildings should be protected from unauthorised access;
• signs warning people not to enter the site.
The above may not apply if you have a public footpath going through your site.
Permit surrender When you come to apply to surrender your permit, you will need to be able to show that the site has been returned to a ‘satisfactory state’. Paragraphs 6.26 to 6.33 of the Defra and Welsh Assembly Government Environmental Permitting Guidance explain what is meant by ‘satisfactory state’.
EPR Intensive Farming Chapter 1 - management Version 2How to comply January 2010 Your management system will need to record details of how the land under the site was thoroughly protected at all times between the date the permit was issued (or when operations started), until the end of operations under the permit. You could do this, for example, by recording the use and maintenance of impermeable surfacing and leak-tight drains. If the land was contaminated before your permit began, we strongly advise that you record details of this contamination. You should also record how you have cleaned up any incidents/spillages as they occur.
We will consider all of these records when you apply to surrender your permit. During compliance checks we will check the records are being collated properly. Section 4.1, Records and the H5 Site Condition Report Guidance give further information.
Records that demonstrate your management system You must keep reliable records. These are an essential part of your management system.
Personnel competency records, for example, should include the date and type of training, the training provider and how the skills and training received meet the requirements. Section 4.1 of the permit tells you how to keep the records. The manner in which records are held is covered by other conditions in the permit.
Display your permit Staff or contractors whose work may have an impact on the environment must be able easily to see a copy of the permit, displayed near where they work.
They should have ready access to the information they need to ensure that they act in a way to comply with the permit. This could be access to this document or instructions more targeted to their responsibilities.
Where can I get further information?
• H5 Site condition report – guidance and templates
• Environmental Permitting Guidance, Defra 2009
1.2 Accident management plan 1.2.1 The operator shall:
(a) maintain and implement an accident management plan;
(b) review and record at least every 4 years or as soon as practicable after an accident, (whichever is the earlier) whether changes to the plan should be made;
(c) make any appropriate changes to the plan identified by a review.
You must have an accident management plan and implement it if an accident occurs. You will have to review this plan at least every four years. As soon as practicable after an accident you will have to analyse the reasons why the accident happened and whether your response was adequate. You will have to change the plan if necessary.
All staff should be aware of the location and contents of the accident management plan, and their responsibilities in the event of an accident.
You should keep a site layout plan, showing details of all diverter valves, surface and foul drains, in the site office, with a back-up copy elsewhere in case the office is inaccessible in an emergency.
EPR Intensive Farming Chapter 1 - management Version 2How to comply January 2010
To produce an accident management plan, you should:
• identify events or failures that could damage the environment, for example flooding; see ‘A’;
• assess how likely they are to happen and the potential environmental consequences; see ‘B’;
• take steps to minimise both the potential causes and consequences of accidents; see ‘C’.
The easiest way to do this is to follow the risk assessment for accidents in Part 1 of H1 Environmental Risk Assessment and describe how you will manage the risks.
A. Identify events or failures that could damage the environment
Hazards you need to think about include:
• transferring substances (e.g. loading or unloading vessels);
• overfilling vessels;
• plant or equipment failure (e.g. over-pressure of vessels and pipework, blocked drains);
• containment failure (e.g. bund or overfilled drainage sumps, slurry tank, wash water);
• fires or failure to contain firewaters;
• making the wrong connections in drains or other systems;
This is not a comprehensive list. You also need to work out what other situations are relevant to you.
B. Assess how likely they are to happen and the potential environmental consequences
This can be viewed as addressing four questions:
• Probability: how often is this likely to occur? Several times a year? Once every few years?
• What gets out and how much?
• Where would it go – i.e. what or whom would be affected - the public or an ecologically important site? How would it get there – by air, along a ditch, etc.?
• What would the consequences be?
The level of assessment will depend on the scale of the severity of the consequences and the complexity of the situation. In general it is more important to identify what you need to do – and then do it – rather than performing in depth analyses of, for example, how far an oil spill may spread into the soil.
C. Action to minimise the potential causes and consequences of accidents:
You should take action to minimise the risks you have identified. As a minimum you should:
• Keep a list of substances that would harm the environment if they were to escape – the raw materials inventory would be sufficient. Remember that many apparently innocuous substances or non-hazardous wastes can be environmentally damaging, e.g. a feed spill into a water course.
EPR Intensive Farming Chapter 1 - management Version 2How to comply January 2010
• Check raw materials and wastes for compatibility with other substances with which they may come into contact.
• Store raw materials, products and wastes properly.
• Have barriers or markers to prevent vehicles from damaging equipment.
• Have appropriate primary and secondary containment e.g. bunds and building containment.
• Prevent overfilling of tanks and drainage sumps by level measurement, separate highlevel alarms or cut-off, and batch metering.
• Install security systems to minimise the risk of unauthorised access.
• Keep a log of all incidents and near-misses.
• Have clear instructions on how each accident scenario should be managed. Should a given spill be contained or dispersed, for example? Should you put a fire out or let it burn?
Who is responsible for isolating drains, or alerting emergency services?
• Have appropriate equipment to limit the consequences of an accident, such as oil spillage equipment.
• Check the composition of the contents of a bund or other container before disposal.
• To prevent fires and minimise their impact you should:
▪ Store incompatible materials apart.
▪ Limit the size of stockpiles of combustible materials and surround them with firebreaks.
▪ Not store materials against the site boundary.
▪ Store contaminated firewater on-site, where practicable.
D. If an accident happens
If an accident causes damage to the environment, or risks doing so, we expect you to:
• Immediately do what it says in the accident management plan.
• Do whatever else is necessary to minimise the environmental consequences.
• Find out why the accident happened and take action to stop it happening again.
• Review the plan.
• Tell us.
Where can I get further information?
• H1 Environmental Risk Assessment – Part 1
• PPG 21 pollution incident response planning
1.3.1 The operator shall:
(a) take appropriate measures to ensure that energy is used efficiently in the activities;
(b) review and record at least every 4 years whether there are suitable opportunities to improve the energy efficiency of the activities; and (c) take any further appropriate measures identified by a review.
*The energy efficiency plan is required to ensure that you have considered all relevant techniques. However, where a CCA is in place we will only enforce implementation of the measure 1 above. H2 provides an appraisal methodology.
If you use a different appraisal methodology you must explain in the application how you have done the appraisal, and provide evidence that you have used appropriate discount rates, asset life and expenditure (£/t) criteria.
3. You should monitor energy flows and target areas for reductions.