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6. Process monitoring appropriate measures

Environment Agency

July 13
08:10 2022

1. You must monitor, assess and record the performance of your WTEE treatment plant on a continual basis. You must report this to the Environment Agency in line with the measures set out in this guidance and the conditions of your environmental permit.

2. You must record the number and type of WTEE that you process through your stage 1 and stage 2 treatment processes.

For stage 1 processes, you must record the number of:

  • WTEE by refrigerant type (VFC, VHC or other for example, ammonia)
  • defective WTEE, identified by visual inspection (for example, no compressor, pressure gauge or manometer shows no gas pressure)

For stage 2 processes, you must record the:

  • number of WTEE by blowing agent type (VFC, VHC or other, such as carbon dioxide), and any that are identified as containing VIP
  • number of WTEE by appliance type (see section 6.2 on blowing agent recovery for more information on the relevant types Type 1, Type 2, Type 3 and Type 4)
  • quantity (kg) of separate dismantled foam panel processed

3. You should use an independent laboratory to complete compliance tests and analysis on the waste fractions and residues produced by your treatment process. The laboratory should:

  • be appropriately accredited, for example by UKAS
  • use recognise accredited methods if they are available

The tests and analysis to determine the quantity of residual foam in metal and plastic fractions must not be done on-site, unless you have appropriately experienced and trained staff. You must keep records of staff training and experience.

The compositional tests and analysis carried out on oil, foam and gases must not be done on-site, unless you have an appropriately accredited laboratory and qualified staff.

You must have, and be able to provide, a full description of the material testing and analysis procedures and methods used. This must include details of relevant calibration methods and reference standards. You must keep records of your test results.

For further guidance on waste sampling, characterisation and analysis see:

4. You must weigh recovered gases, waste fractions and residues produced by your treatment process using calibrated electric scales of an appropriate precision.

5. You should make sure that relevant treatment plant, vessels and containers are cleaned and empty before doing the refrigerant recovery and annual blowing agent recovery assessments. This is unless pre-existing content can be accounted for and excluded from the gas recovery measurements and calculations.

6. Because of the high volatility of VFCs and VHCs, to avoid any loss of refrigerant or blowing agent gases you must:

  • fill sample containers to the top, closing and sealing them immediately after filling
  • close and seal the containers and vessels that samples have been taken from immediately after sampling
  • send all samples containing (or suspected of containing) these substances to the laboratory as quickly as possible on the same or next day
  • store and transport samples below 4C where possible

7. You must inform your Environment Agency inspector about the dates of sampling in advance, providing at least 5 working days notice.

8. If process monitoring shows that the performance of your treatment plant does not meet any of the standards stated in this guidance (for example, the refrigerant or blowing agent recovery rate standards, or compositional standards for waste fractions and residues), you must send a report to the Environment Agency, summarising:

  • the actions you will take to improve performance to achieve the standards given, including any additional sampling and testing
  • the dates you will complete these actions by, including the dates for any additional sampling and testing

6.1 Refrigerant recovery

1. You must assess and report plant performance against the refrigerant removal and recovery rate, stated in appropriate measure 9 of section 5.1 on stage 1 treatment (minimum of 90% recovery), on a 6-monthly basis. More frequent assessment and reporting may be required if your assessed recovery rate falls below the minimum recovery rate.

2. You must assess refrigerant recovery using a representative sample of the WTEE treated at your facility. The sample must reflect the range of WTEE types accepted for treatment and include a minimum of 100 intact appliances. You should select the WTEE to make sure it is in good condition, with the cooling circuit and compressors intact, legible rating plate or label in place, and inspected to confirm there is no visible damage or leaks.

3. Using calibrated electronic scales of an appropriate precision, you must weigh and record:

  • the mass of the chosen appliances before and after degassing
  • the mass of refrigerant and oil collected from the degassed appliances

Base this on a mass balance calculation comparing the weight of the WTEE before and after stage 1 degassing (before other parts and components are removed following degassing, for example, compressors), and the mass of refrigerant and oil collected (recording and comparing the mass of the collection vessels before and after degassing). Record the number of any defective units identified.

To calculate the amount of refrigerant collected as a percentage, for comparison to the performance standard, you should use the formula:

(A (B ? C)) 100 = % recovered

Where, A is the mass of refrigerant recovered (grams), B is the reduction in mass of degassed appliances (that is, mass of appliances before degassing minus mass after degassing (grams)) and C is the mass of oil recovered (grams).

4. In addition to the detailed 6-monthly assessment, you must record the total number and type of WTEE processed and quantity of refrigerant and oil recovered and report this to the Environment Agency on a quarterly basis. You must also record and report the number of defective WTEE treated (for example, appliances that have no gas pressure in the cooling circuit due to damage or removal of the compressor).

6.2 Blowing agent recovery

1. You must assess plant performance against the monthly blowing

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