Correspondence from the Environment Agency
to Biffa Waste Services Ltd 4 February 2002
REGULATION EC 2037/2000
Thank you for the copy of your letter of 14
January to Mr Meacher regarding the recovery and destruction of
CFCs/HCFCs in Fridges. I would like to comment on your final paragraph
where you address the possible impact of the proposed new Regulations
on the Environment Agency.
The role of the Agency as regards the Ozone
Depleting Substances (ODS) Regulation will be determined once
the UK Regulations are in force (probably not before end February
2002), clearly until then, the Agency has no duties or powers
under the proposed Regulations.
I have summarised below the current position:
Storage of fridges and collection/recovery
of ODS from fridges currently falls under the requirements of
Waste Management Licensing.
In addition if the process involves
the destruction of the ODS in an incinerator, then the whole process
including the removal of the ODS and destruction of the fridge
normally requires a PPC permit instead.
Furthermore if the incinerator has
an existing IPC permit and the destruction of fridges is not a
significant change to the process, then it may be covered by the
existing IPC permit.
Currently the Agency is determining the applications
it receives from operators to store fridges and/or recover/destroy
ODS in fridges under these respective regimes.
The Agency is working closely with DEFRA to
determine exactly the licensing requirements which will be needed
for the storage/recovery /destruction facilities and has placed
an internally funded contract with Caleb Management Services to
prepare guidance on the "Best Available Techniques"
(BAT) for the various stages involved. The report should be completed
early February 2002, when the output will be turned into Agency
guidance and published.
The Agency has also recently set up a Fridge
Co-ordination Group to:
Receive applications for recovery/destruction
of ODSs in fridges to assess them, and to prepare licenses for
Areas, who will sign them off and issue them.
Provide support to Areas in giving
consultation responses to Town and Country planning applications
for Fridge disposal facilities.
Ensure the development of BAT standards
and guidance for fridge and associated CFC/HCFC processing and
Maintain knowledge of the size of
the problem, including import and export effects, the capacity
available to deal with it and potential capacity that may be permitted
Provide information to Directors
on the development of the issue, Agency progress and performance
in processing applications, and advising on further actions as
The Agency has had almost daily contact with
many of the companies involved with the disposal of fridges. It
has been difficult to advise potential operators since the processes
they plan to carry out are still being developed and the details
of their proposals are unclear. The Agency has stressed to the
operators that the determination process can be minimised if a
complete application is submitted. Operators are being encouraged
to identify where each plant is to be located and begin to discuss
the application with the Local Authority and with the Agency Officer.
||Tonnes (million)||£ million
||£ per tonne
|Fridges 3,000,000 per annum||0.1
|Weight 35kg = 30 per tonne||
|Cars 2 million @ £100||1.8
|Other white goods||0.2