Document Zngdj8Z3BbMrzMOg886KZYYXp

EPR Compliance Assessment Report Report ID: BU5453IY/0451214 This form will report compliance with your permit as determined by an Environment Agency officer Site AG Fluoropolymers, Hillhouse EPR/BU5453IY Permit Ref BU5453IY Operator/ Permit holder AGC CHEMICALS EUROPE LIMITED Date 21/12/2022 Time in 14:00 Out 15:30 What parts of the permit were assessed Site Visit Assessment Site Inspection EPR Activity: Installation X Waste Op Water Discharge Recipient's name/position Officer's name Date issued 16/02/2023 Section 1 Compliance Assessment Summary This is based on the requirements of the permit under the Environmental Permitting Regulations (EPR). A detailed explanation and any action you may need to take are given in the "Detailed Assessment of Compliance" (section 3). This summary details where we believe any noncompliance with the permit has occurred, the relevant condition and how the noncompliance has been categorised using our Compliance Classification Scheme (CCS). CCS scores can be consolidated or suspended, where appropriate, to reflect the impact of some noncompliances more accurately. For more details of our CCS scheme, contact your local office. Permit Conditions and Compliance Summary Condition(s) breached a) Permitted activities 1. Specified by permit A b) Infrastructure c) General management 1. Engineering for prevention & control of pollution N 2. Closure & decommissioning N 3. Site drainage engineering (clean & foul) N 4. Containment of stored materials N 5. Plant and equipment N 1. Staff competency/ training N 2. Management system & operating procedures N 3. Materials acceptance N 4. Storage handling, labelling, segregation N d) Incident management 1. Site security N e) Emissions 2. Accident, emergency & incident planning N 1. Air N 2. Land & Groundwater N 3. Surface water A 4. Sewer N 5. Waste A f) Amenity 1. Odour N 2. Noise N 3. Dust/fibres/particulates & litter N 4. Pests, birds & scavengers N 5. Deposits on road N g) Monitoring and records, 1. Monitoring of emissions & environment N maintenance and reporting 2. Records of activity, site diary, journal & events N 3. Maintenance records N 4. Reporting & notification N h) Resource efficiency 1. Efficient use of raw materials N 2. Energy N KEY: C1, C2, C3, C4 = CCS breach category ( * suspended scores are marked with an asterisk), A = Assessed (no evidence of noncompliance), N = Not assessed, NA = Not Applicable, O = Ongoing noncompliance - not scored MSA, MSB, TCM = Management System condition A, Management System Condition B and Technically Competent Manager condition which are environmental permit conditions from Part 3 of schedule9 EPR (see notes in Section 5/6). Number of breaches recorded 0 Total compliance score 0 (see section 5 for scoring scheme) If the Total No Breaches is greater than zero, then please see Section 3 for details of our proposed enforcement response CAR 2 V2.0 Page 1 of 4 Section 2 - Compliance Assessment Report Detail This section contains a report of our findings and will usually include information on: the part(s) of the permit that were assessed (e.g. maintenance, training, combustion plant, etc) where the type of assessment was `Data Review' details of the report/results triggering the assessment any noncompliances identified any noncompliances with directly applicable legislation details of any multiple noncompliances information on the compliance score accrued inc. details of suspended or consolidated scores. details of advice given any other areas of concern all actions requested any examples of good practice. a reference to photos taken This report should be clear, comprehensive, unambiguous and normally completed within 14 days of an assessment. Meeting The company structure has changed - is now the primary contact for the Environment Agency. There was some discussion about further improving abatement at the site. Some of the notes of the meeting are held separately to this CAR form. The company wants to carry out some trials to remove PFOA and SAA1000 from water discharges. The company proposes a filtration system with carbon beds. I am minded to agree this if you provide a brief written proposal for approval. (Have since provided comments back to the company) C6H - tridecaflourohexane emission to air, as ETFE solvent. The company stated that 99% of the solvent is recovered but 44 tonnes is released to air. This is calculated by mass balance. In the last six months the company has been testing carbon absorption units and is likely to look at installing a second unit. (Have since provided comments back to the company) Health and Safety Prior to going on the site, we checked if there were contractors on site if there was anything that we should be aware of. We were escorted on site and were confident that our H&S was being considered. Site Visit We looked at the waste acid tank while on site. This was in connection with the incident reported on 23/12/2022. I will deal with this incident in a separate report. We also looked at the pipework associated with the incident reported on 19/12/2022 and updated on 12/12/2022. We noted that the pipework was in semi-outdoor covered area. Most of the pipework was insulated but not trace heated. The incident has been followed up with a part B notice. I will deal with this incident in a separate report. We also noted a blocked drain and I asked for this to be attended to. However, this was not associated with the incident. The company have since confirmed that the drain has been cleared. While on site we noted that the filter cake skip was overflowing, we asked for this to be dealt with. On the 20 January 2023, the company provided photographic evidence of the cleanup. Section 3 Enforcement Response Only one of the boxes below should be ticked You must take immediate action to rectify any noncompliance and prevent repetition. Noncompliance with your permit conditions constitutes an offence* and can result in criminal prosecutions and/or suspension or revocation of a permit. Please read the detailed assessment in Section 2 and the steps you need to take in Section 4 below. *Noncompliance with MSA, MSB & TCM do not constitute an offence but can result in the service of a compliance, suspension and/or revocation notice. Other than the provision of advice and guidance, at present we do not intend to take further enforcement action in respect of the noncompliance identified above. This does not preclude us from taking enforcement action if further relevant information comes to light or advice isn't followed. In respect of the above noncompliance you have been issued with a warning. At present we do not intend to take further enforcement action. This does not preclude us from taking additional enforcement action if further relevant information comes to light or offences continue. CAR 2 V2.0 Page 2 of 4