Document dnbEj15kzEwRp67mKjmy5Qwzq

EPR Compliance Assessment Report Report ID: BU5453IY/0452716 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 17/02/2023 Time in 10:00 Out 12:15 What parts of the permit were assessed Site visit _ meeting / labs/ effluent trial Assessment Site Inspection EPR Activity: Installation X Waste Op Water Discharge Recipient's name/position Officer's name Date issued 01/03/2023 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 A 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 A 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 N 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. The purpose of the meeting was to 1. Discuss the incidents reported in December 2022, A1 low boiler and A2 Pyrolysis. For the avoidance of doubt, the compliance issues have been dealt with in separate CAR forms. 2. To get a brief update on the thermal oxidiser 3. To gather some additional information relating to A5 (ARC) modelling 4. To review the effluent treatment trial. Meeting The company made a very helpful presentation in relation to emissions in 2022, which helped to inform our enforcement response, which is dealt with on another CAR form. It is likely that we will want to review the company climate change resilience and actions in relation to future predicted more extreme weather. We will give notice of any such audit. ACTION: I have asked the company to send a copy of the Aspects and Impacts Register. For the avoidance of doubt, I don't expect you to have made amendments for climate change in the meantime; the compliance assessment is at the time we carry out the audit, not on the document as it is now. Please redact any information that is commercially sensitive. Thermal Oxidiser: The company have had some additional problems bringing the TO back online. The company will resend all of the QAL data at once, rather than piecemeal, this is better for us. We also discussed some of the monitoring required by the permit. I am minded to agree a position with respect to monitoring. In particular, where the company can demonstrate that a substance cannot or is unlikely to be produced or is trivial, I may allow the monitoring frequency to be reduced. Data and Annual Reports: You are now sending annual and monitoring reports to our new PPC address. This is part of our programme in the Installations Team to improve the way we deal with reports and data. Additional Monitoring: The Environment Agency will carry out some modelling of ARC plant stack A5, currently a point source emission of SAA-1000 (in place of PF0A). You agreed to provide some additional information to support the model. is leading on this for our area. Can I remind you of this. Health and Safety: Prior to carrying out a site visit, we ensured with you that we had the correct PPE. We confirmed that we would not be passing through any DSEAR zone, and that there were no contractors on site that we needed to be aware of. We were escorted safely on site at all times. On Site: We looked at the effluent treatment trial. I have separately agreed this trial, with conditions. I was satisfied that there was no additional risk of pollution from the trial. I took a number of photographs of the rig. The company have two stages of filtration. The first is a physical filtration to reduce solids, trialling sand and gravel filters, a bag filter and a cartridge filter. The second stage is carbon bed (two of) and a resin exchange. There are three parallel trials, combinations will be changed over time. The company have installed auto sampling so that comparative analysis can be carried out. CAR 2 V2.0 Page 2 of 4