Project Aims
Our client specialises in the bulk liquid storage of chemicals. The site currently holds two Environmental Permitting Regulations Part B Permits. IKM was requested to review the activities being undertaken within the installation boundaries and assess if the site was compliant with their permits and if any additional steps were required under the Air Quality Standards Regulations 2010. Consideration of the COMAH Regulations were not part of this current scope, however guidance was given regarding how this legislation would interact with the EPR and the AQS Regulations 2010.
IKM were requested to conduct the following scope of work, which forms the basis of our report:
- Review the two existing EPR Permits
- Review the activities/processes undertaken onsite at present.
- Assess the level of compliance against the existing EPR Permits and the AQS Regulations 2010.
- Assess compliance against a list of specific chemicals stored within the installation boundaries.
- Recommend any future steps required.
Strategy Employed
A thorough review was undertaken regarding of the types of chemicals and the quantities being stored within the installation. The annual emission levels of specific substance and the current use of BAT for the storage of these substances was also reviewed. The level of compliance was then assessed against the EPR Regulations, the Ambient Air Quality Directive and AQS Regulations 2010. For specific substances which were being stored onsite, an assessment of DEFRA’s background air quality emission values was also made against the specific legal AQS Regulation limits.
The activities, quantities and substances currently being stored onsite were assessed to be authorised under the relevant sections of the Environmental Permitting Regulations. Currently no other Sections within EPR were deemed to be relevant to the activities being undertaken within the installation. The site was also assessed to be currently compliant with their EPR Permits and the DEFRA background air quality emission values at a sampling location close to the site were found to be significantly lower that the legal AQS Regulation limits. For the priority substances being stored onsite which had been of concern to our client, the Best Available Techniques (BAT) currently being used was found to reduce the emission levels to a negligible amount and therefore did not have the capacity to cause harm to humans or the environment. A number of recommendations were made to the site to future proof their operations and provide reassurance that they would remain compliant going forward.
