Document xdYo6JNLZ4kYzVXqLxeY9eRYE

EPR Compliance Assessment Report Report ID: BU5453IY/0451805 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 23/02/2023 Time in Out What parts of the permit were assessed Assessment 4.2.3. 2002 Q4 emissions report Report/data review EPR Activity: Installation X Waste Op Water Discharge Recipient's name/position Officer's name Date issued 12/04/2023 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 b) Infrastructure c) General management d) Incident management 1. Specified by permit N 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 A 3. Materials acceptance N 4. Storage handling, labelling, segregation N 1. Site security N 2. Accident, emergency & incident planning N e) Emissions 1. Air A 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 A 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 (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 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. Thank you for your finalised six monthly returns in compliance with section 4.2.3 of your permit, submitted on 27/02/2023: 4.2.3 Within 28 days of the end of the reporting period the operator shall, unless otherwise agreed in writing by the Environment Agency, submit reports of the monitoring and assessment carried out in accordance with the conditions of this permit, as follows: o in respect of the parameters and emission points specified in schedule 4 table S4.1; o for the reporting periods specified in schedule 4 table S4.1 and using the forms specified in schedule 4 table S4.4 ; and o giving the information from such results and assessments as may be required by the forms specified in those tables. You reported the following exceeded emissions: o Annual CO emissions 01/01-31/12/22: 30.86 tonnes reported against a limit of 25 tonnes o A1 Pentafluoroethane emissions 12-18/12/22: 0.28 kg/hr reported against a limit of 100g/hour o A1 Chlorodifluoromethane emissions 12-18/12/22: 0.46 kg/hr reported against a limit of 100 g/hour o A2 Chlorodifluoromethane emissions 19-25/12/22: 0.81 kg/hr reported against a limit of 800 g/hour (in- house method, uncertainty not stated) As you have already notified us of these breaches, they are not scored on this Compliance Assessment Report. We are still awaiting part B notification for the CO emissions breach and will consider scoring once we have received it. W4 and A14 emissions were not reported, as the thermal treatment plant was not operational in 2022. You've also notified us that the following monitoring required in table S4.1 was not completed in July to December 2022: 1. Hydrogen Fluoride from emissions point A4 2. SAA-1000 from emissions point A5 We have decided not to score these omissions, as long as the missed monitoring is completed in Q1 of 2023, as stated in your returns. If you have any issues in relation to the details within this form, or if you disagree with or object to any of the comments, would you please write to me with full details within 28 days of receipt. 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. CAR 2 V2.0 Page 2 of 4