Select Committee on Environment, Food and Rural Affairs Appendices to the Minutes of Evidence


Memorandum submitted by Onyx Environmental Group plc


  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.

    —  So, the position is

    —  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.


    —  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.


    —  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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