APPENDIX 3
Memorandum submitted by Onyx Environmental
Group plc
SUMMARY
Given the detail in the Government's Waste Strategy
2000 it is disappointing that a UK strategy for dealing with hazardous
waste has been sadly lacking. Preparation for the implementation
of the Landfill Directive has been tardy, with key informations
still awaited. The full consequence of its implementation has
not been thought through and it is clear that there is insufficient
suitable treatment capacity available. A piece-meal approach rather
than a co-ordinated approach to dealing with the problems arising
from hazardous waste appear to be the way in which this very important
matter has been dealt with, as evidenced by the differing approaches
taken with the varying number of directives and regulations. This
has led to confusion, uncertainty and lack of necessary investment.
The Onyx Environmental Group is pleased to submit
evidence to the EFRA New Inquiry in to Hazardous Waste.
Our comments are as follows:
The Onyx Environmental Group is one of the largest
waste management companies in the UK with an estimated 10 per
cent market share and an expected turnover of £400 million
in 2002. Onyx was formed in the UK in 1990 and the Onyx name is
the trade mark for all waste activities within Vivendi Environment.
The Company has swiftly grown into a multi-service provider offering
integrated waste management to the municipal sector and total
waste management to industry.
The international standing of Vivendi Environment
and its considerable experience means that the Group is known
for its knowledge of environmental legislation and innovative
solutions.
Achievements that may be of particular interest
to the Committee include:
— The development of the first effective
integrated waste management system in France in 1989 and then
introduced this new waste management approach in the UK in 1993
as Project Integra in Hampshire where we work closely with Hampshire
County Council and other local authorities in the county.
— Involvement in a number of projects
to promote recycling. For example, we have recently opened a materials
recycling facility (MRF) in Maidenhead and we have invested £3.6
million in a new MRF in Portsmouth which is one of the largest
municipal waste recycling plant of its type in Europe.
— Project Integra currently operates
three green waste composting plants. Further plants are planned
which are expected to result in 70,000 tonnes of green waste being
recycled per annum. The soil conditioner, PROGROW, is produced
by Hampshire Waste Services and has proven to be a high quality
product.
— Financing, designing and construction
of the first two new state of the art Energy-from-Waste facilities
in the UK since the 1970s; SELCHP in London and Tyseley in Birmingham,
with a further three planned with appropriate permissions in Hampshire.
— The construction of new transfer
stations across the UK and have fully engineered landfill facilities
at locations around the country. We collect methane gas at a number
of landfill sites and convert it into energy.
— The operation of seven major strategic
hazardous liquid and solid treatment facilities across the UK
providing services and solutions to industry's problems.
— The operation of the largest hazardous
liquid waste collection fleet, with over 100 specialist vehicles
in the UK. Currently we collect and treat 300,000 tonnes per annum
of hazardous liquid waste.
— The financial backing of its parent
company and because of this has been able to raise capital and
invest in the new facilities which have been essential for growth.
— All encompassing expertise in all
aspects of municipal, commercial and industrial waste management
from collection through to recycling, to treatment and disposal.
A particular strength lies in the design of workable "integrated"
solutions to local authorities waste management needs through
a partnership approach. This approach has been developed and extended
to meet the needs of our commercial and industrial partners, which
was pioneered as "Total Waste Management", providing
an all encompassing on site waste management system. Our partners
included Ford UK, Glaxo Welcome, Peugeot, British Timkin, Astra
Zeneca, Esso, BP, and Huntsman Chemicals.
— Establishment of the first research
centre in the world dedicated to waste and the environment. The
work undertaken at CREED (Centre de Recherches per l'Environnement,
l'Energies et le Dechet) ensures that the Group is at the forefront
of waste management thinking and technology. Vivendi Environnement
believes that to meet the increasing demands from industry, local
authorities, and the public, high performance technical solutions
for waste management must be developed.
Recent past changes in legislation and implementation
of the Landfill Directive.
— Recent legislative changes have had
little impact in the disposal of hazardous waste (special) to
landfill. The lack of any measures to control and prohibit the
disposal of liquid waste to landfill has had a detrimental effect
on investment in new technology to allow the treatment of hazardous
waste which is in contrast to our European partners. Liquids to
landfill was and is the cheapest option and neglects the requirements
of the Best Practicable Environmental Option, or Best Available
Technology. This has never been Onyx's policy and disposal of
liquids to landfill has never been practised in the UK.
— There is now a desperate need for
treatment technologies since the implementation of the landfill
directive will:
— divert liquids from landfill, and
— requires all waste to be treated
prior to landfill.
— Liquid hazardous waste will be banned
from landfill in July 2002. The key question is whether there
will be sufficient capacity to deal with the diverted waste, some
400,000 tonnes, although because of the new definition of hazardous
waste (see section 6, Special Waste Regulations), a meaningful
figure is difficult to ascertain. Co-disposal ends in July 2004
and there will be a further major diversion of hazardous waste
from landfill. The difficulty is compounded by the absence of
waste acceptance criteria from the Technical Adaptation Committee.
One must not forget the 0.5 million tonnes of contaminated soils
that are currently being landfilled. These will be required to
be treated to a standard not yet defined prior to being landfilled.
— There are also significant quantities
of non-hazardous liquid waste being landfilled today much of which
may well be defined as hazardous because of the review of the
special waste regulations. In any event pre-treatment of these
liquids will be required.
— The quantities of hazardous waste
requiring treatment are not known.
— The standard to which hazardous waste
must be treated is not defined since waste acceptance criteria
will not be known in time.
With these uncertainties how can any industry
be expected to invest in major capital projects running to many
millions of pounds:
— For existing treatment plants planning
permission may well have to be sought to modify and develop additional
capacity and treatment capability. To develop new treatment plant
planning permission will be required as well as an IPPC permit.
This will inevitably delay any introduction of new or additional
capacity and capability for several years.
— There is, however, a difficulty in
that the detailed information required to be presented to obtain
permission is dependent upon the standard to which one is aiming
to meet. So, the design of the plant, its capacity, the controls,
the planning footprint are difficult, if not impossible, to determine
whilst the standard of treatment is not known. Then of course,
if permission is forthcoming there is the construction time phase.
— The UK is not ready for the implementation
of the landfill directive since key elements have not been forthcoming
from either Government (DEFRA), Europe and, to a lesser extent
the Environment Agency, who through no fault of their own share
the same deficit of information as we do. We are not prepared.
— There are existing physico-chemical
treatment plants that could well be adapted or developed but will
not satisfy the new demands. The Cement industry offers additional
capacity, with the ability to process hazardous waste pre-treated
to a very controlled specification with a high calorific value.
The emissions standards have been shown by the Environment Agency
to give more environmental benefits as a replacement to fossil
fuels. Expansion in this area must be encouraged.
— Of particular concern is DEFRA's
interpretation of the word "prevent" with reference
to the ingress of groundwater/surface water into the landfill.
If the word prevent means stop, as appears to be the case, all
landfill in the UK will cease with devastating consequences for
the UK's waste management options. It seems quite incredulous
that the Landfill Directive allows landfill, but one word "prevent"
disallows landfill.
DIRECTIVES—THE
INCINERATION OF
HAZARDOUS WASTE
DIRECTIVE.
— Integrated Pollution Prevention and
Control Directive.
— End of Life Vehicles Directive.
— Waste Electrical and Electronic Equipment
Directive
— Waste Incineration Directive-the
incineration of hazardous waste directive has been superseded
by the Waste Incineration Directive, where emissions standard
for all incinerators will be the same. For new plants these are
effective now, but for existing plant implementation is in January
2005. There appears to have been a piece-meal introduction of
the new, more stringent standards, by variation of existing plants
with little or no consultation by the Environment Agency. This
phased approach to the implementation of new regulation must be
avoided since it gives rise to differing standards.
— Integrated Pollution Prevention and
Control Directive—the guidance preferred by the Environment
Agency although late, has been helpful. Nevertheless, the workload
associated with converting waste management licences for treatment
plants and landfills, both of which will be regulated under IPPC
will be enormous. The planned phased introduction of the permitting
system will lead to waste tourism and double standards, or financial
penalties to those first served with a permit. There must be a
single implementation date. Regulation would also be difficult.
This is unacceptable.
— End of Life Vehicles Directive and
Waste Electrical and Electronic Equipment Directive—there
has been little information to date, no advice, and seemingly
little planning. The fear is that there will be a repeat of the
refrigerator fiasco.
ROOT AND
BRANCH REVIEW
OF THE
SPECIAL WASTE
REGULATIONS
— In 1995-96 the arisings of special
waste in the UK was circa 2.5 million tonnes. A review of the
1980 regulations which led to the Special Waste Regulations 1996,
by new definition, resulted in a near doubling of the arising
of special waste. The current review where it is understood that
any waste that appears in the European Hazardous Waste list will
be classified as hazardous waste, could well result in another
doubling of the quantity of hazardous waste arising, ie 10 million
tonnes per annum.
It is disappointing that with such a significant
change and the associated difficulties that, to our knowledge,
Government nor the Environment Agency have made any attempt to
give an analysis of the likely outcome and impact upon the UK.
Further it is believed that also being caught
within the definition will be wastes that are not on the European
Hazardous Waste List, but exhibit any one of the fourteen hazardous
properties. This will lead to an even greater quantity of hazardous
waste, will certainly complicate matters and is not necessary
for the protection of the environment.
— The polluter pays principle, ie registration
of producers of hazardous waste is supported, however dialogue
with producers has been negligible and awareness is low. This
is especially concerning, since the number of producers will vastly
increase for the reason given above.
— The operator of a hazardous waste
facility will be required to return completed consignment notes
to the waste producer and the Environment Agency. This is an added
major administrative burden that the industry will have to shoulder
and can do without.
— There is a great need for an urgent
publicity campaign to prepare industry for the new requirements
as well as those producers whose waste will fall into the hazardous
category for the very first time, many of whom will be SMEs.
In all of this there is an urgent need for Government
and the Environment Agency to consult with and involve fully the
waste management industry at the very earliest time, since that
industry is expected to provide the solution.
Onyx Environmental Group plc
14 May 2002
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