Memorandum submitted by SITA Holdings
UK Limited (E5)
Background to SITA
SITA is Europe's leading waste service operator
and the third largest in the world. The Group's activities span
the waste management chain, including collection, sorting, recovery,
treatment and ultimate disposal of hazardous, domestic, commercial
and industrial wastes.
SITA has provided waste management services
in the UK since 1989. The Company has grown to become the country's
largest service provider, operating more than 100 municipal service
contracts, 103 landfill sites, several recycling and recovery
facilities along with energy from waste facilities at Edmonton
in North London, Cleveland on Teesside and at Kirklees.
Landfilling within the context of the Government's
emerging waste management strategy and the Landfill Directive
(LFD) is therefore a significant and critical component of SITA's
portfolio of waste management services in the UK. SITA landfills
approximately 6.5 million tonnes of waste per year in the UK in
60 operational landfill sites, of which approximately 300,000
tonnes comprises special waste, difficult waste, or wastes that
will be banned from landfills from 16 July 2002. While this tonnage
appears small relative to the total, the revenue generated from
these waste streams is significant.
Scope of this Memorandum
SITA is currently assessing the likely impact
of the Landfill Directive (LFD) on its hazardous waste market
in the UK, drawing on our operational experience in alternative
treatment options in Europe and elsewhere. For example, SITA operates
ten stabilisation/solidification plants internationally, treating
400,000 tonnes of hazardous waste per year. The largest facility
in Europe is located at the landfill site in Villeparisis, France,
with a capacity of 100,000 tonnes per year. SITA also operates
bioremediation and soil washing/stripping facilities, in addition
to hazardous waste incinerators, co-incineration and solvent recovery
This memorandum presents our views on four issues
connected with the implementation of the LFD in the UK:
the requirements for alternative
treatment options, with respect to both type of option and national
analytical issues concerning tests
for the measurement of waste acceptance criteria;
the application of the waste acceptance
criteria to a range of waste types, and the landfilling decisions
that result thereof;
the timing of a ban on the co-disposal
of hazardous and non-hazardous waste.
We have sourced waste arisings and capacity
data from available Environment Agency statistics, and particularly
from the report published by the DETR in 2000 entitled Implications
of the Landfill Directive on the Disposal of Hazardous and Liquid
Waste in the UK, commissioned from the Babtie Group. We understand
this report is currently being updated. We have supplemented the
published information with a preliminary in-house analysis of
current practices in hazardous waste management in the UK, and
have made additional assumptions to allow for gaps in the available
We are constrained by the same data gaps and
uncertainties experienced by the rest of the waste management
industry and indeed by Government, and therefore cannot claim
any greater accuracy for our estimates. Our intention was to paint
a broad canvas at this stage.
Treatment OptionsTypes and Capacities
SITA has assessed the likely movement of hazardous
wastes from landfilling to other forms of treatment. Environment
Agency statistics suggest annual waste arisings of 4.9 million
tonnes, but this includes "grey" waste categories such
as construction and demolition waste (1.1 million tonnes per year).
The Babtie study assesses annual hazardous waste arisings at 4.6
million tonnes but this includes 300,000 tonnes of non-hazardous
liquids. We have therefore based our analysis on an annual arising
of 4.3 million tonnes of which 2.1 million tonnes are landfilled
(Figure 1). Translating the generic waste description of significant
special waste solid and sludges currently being deposited in landfills
into their nearest European Waste Catalogue (EWC) equivalent,
we developed a matrix of alternative treatment options as shown
in Table 1. Finally, taking into account the potential for routing
a proportion of the banned liquids to wastewater treatment works,
we arrived at estimates for alternative treatment requirements
listed in Table 2. Coupled with tonnages currently treated in
the UK, column 5 in Table 2 lists our estimate of the total tonnage
of wastes that will require treatment from July 2004. Our estimates
of current treatment capacity are listed in column 6 of Table
Tables 1 and 2 point up several potential features
of a post-2004 hazardous waste management regime:
High temperature incineration capacity
is currently at or near saturation. Our preliminary analysis suggests
that additional capacity of some 170,000 tonnes might be required
Co-incineration in kilns and boilers
appears to offer a disposal route for a significant proportion
(170,000 tonnes) of the re-routed waste. This option has thus
far not been incorporated explicitly into a hazardous waste strategy
for the UK, despite the potential that it offers as a safe alternative
under appropriately controlled conditions.
Our analysis suggests that solvent
recovery will not be impacted appreciably by the diversion of
hazardous wastes from landfills.
Physicochemical treatment is appropriate
for an additional 230,000 tonnes of hazardous waste post-2004.
With an estimated installed capacity of 1,500,000 tonnes only
50-60 per cent utilised, we believe that the excess installed
capacity will be sufficient to meet post-2004 demands, albeit
with the possibility of process changes to enable the product
to meet the relevant waste acceptance criteria (see below).
be appropriate for 800,000 tonnes of hazardous waste, and additionally
has the potential to treat a further 525,000 tonnes of contaminated
soil depending on the type and degree of contamination present.
Where this treatment is practised in continental Europe, the product
While these figures would seemingly indicate
a reasonable basis on which to make future investment decisions,
Table 1 highlights some of the uncertainties that SITA and the
rest of the waste industry are currently facing, for example:
Some waste streams are amenable to
treatment by more than one alternative route. For example, the
contaminated soil component of construction and demolition waste
can be incinerated, directly landfilled, bioremediated or subjected
to thermal desorption depending on the nature and degree of contamination
and on the economic viability of the redevelopment. If market
conditions were such that stabilisation was not a viable option,
then potentially 60 per cent of a national installed stabilisation
capacity of 1,400,000 tonnes would not be utilised. Stated differently,
525,000 tonnes of treatment capacity distributed across a range
of alternative treatment options would represent, for options
where this makes up the dominant waste stream, a highly unstable
and unpredictable market.
These overlaps also result in double
counting of required treatment capacity, particularly between
stabilisation/solidification and physicochemical treatment, and
between high temperature incineration in dedicated facilities
and co-incineration in industrial kilns.
In addition, changes to the Hazardous
Waste List will most likely increase both the volumes and types
of waste that will be classified as hazardous. It is not known
at this stage what quantitative effect of these changes might
have on current waste tonnages, especially in the light of the
large number of mirror codes in the EWC.
Crucially, waste producers have not been market
tested for price sensitivity. If the incremental cost of treatment
is significant, generators are likely to alter their processes
or as a minimum adopt more effective waste management practices
(for example, segregating their waste streams or pretreating in
order to declassify the non-hazardous component) and thus reduce
the quantities coming forward for treatment in merchant facilities.
While SITA will certainly not discourage such moves, the lack
of information on industry's perspective on the LFD does nevertheless
add a significant degree of uncertainty to merchant waste management
Finally, it should be noted that diversion of
specific hazardous waste streams such as batteries will require
the development of alternative collection and segregation facilities
which are linked to municipal waste contracts rather than to hazardous
waste management contracts.
Central to the implementation of the LFD is
the development of waste acceptance criteria (WAC) which determine
the waste quality required for deposition of relevant waste streams
in inert, non-hazardous or hazardous waste landfills. The Technical
Adaptation Committee (TAC) of the European Commission published
a Working Document on WAC on 21 March 2002. The numeric WAC are
based on the analysis of eluate from leach tests conducted on
the waste, at liquid to solid (L/S) ratios of 2 and 10.
As a first step in developing in-house WAC analytical
procedures, SITA has assessed whether the standardised analytical
determination methods noted in the Working Document (ENV 12506
and ENV 13370) and their embedded procedures are appropriate for
the determination of parameter concentrations in the eluate to
the levels stipulated in the WAC lists.
Results and Discussion
Columns 2-5 of Table 34 summarise the WAC eluate
thresholds for hazardous waste deposited into non-hazardous and
hazardous waste landfill sites, in relation to the analytical
parameters listed in column 1. The detection limit (DL) and/or
quantification limit (QL) for each standard procedure in ENV 12506
and ENV 13370 are listed in columns 5 and 6 of the table. The
quantification limit (QL) generally corresponds to the detection
limit (DL) multiplied by a factor of 3 to 5. Correctly determining
concentrations for a given parameter requires that the QL is at
least 20 per cent-30 per cent below the desired value. In the
remaining columns of the table we have listed various analytical
techniques and their ability to meet the lowest thresholds required
by the WAC. The terms are explained in the key attached to the
table. For the analysis of metals, most modern waste management
laboratories would be equipped with an atomic absorption spectrometer
(AAS) or an inductively coupled plasma (ICP), the latter with
the capability of rapid simultaneous analysis of a range of metals
concentrations in the test eluate.
can be interpreted as follows:
Metals: We do not envisage difficulty
in determining analytical WAC for arsenic (As), barium (Ba), total
chromium (Cr), copper (Cu), molybdenum (Mo), nickel (Ni), lead
(Pb) and zinc (Zn) concentrations in the test eluate using standard
methods with AAS and/or ICP equipment.
Mercury: The ICP-AES method cannot
be used to determine mercury concentrations at the proposed thresholds
for acceptance at non-hazardous waste landfills (ie 0.002-0.02
mg/l). Mercury concentrations may be determined using the AAS
hydride technique, ie the method specified in eluate analysis
standards (which specify a quantification limit of 0.0001 mg/l).
Cadmium: Depending on the thresholds
selected for acceptance of cadmium (Cd) at non-hazardous waste
landfills (the two thresholds currently proposed differ by a factor
of 10), some methods specified in the two eluate analysis standards
(for example ICP and direct AAS) may not be suitable for determining
the WAC concentration levels. It should be noted that organic
matter and some metals interfere with the latter method (eg. iron
at concentrations above 1 mg/l).
Antimony (Sb) and Selenium (Se):
The two eluate analysis standards do not take account of Sb and
Se. ICP-AES is used as the standard method to determine concentrations
of these two parameters in water.
Salts: Relative to the methods listed
in the two eluate analysis standards (see Table 3),
there are no particular problems in analysing proposed thresholds
for chlorides, fluorides and sulphates. Chloride concentrations
may be determined using volumetric titration with silver nitrate
(subject to interference when bromides or iodides are present)
and using ion chromatography. Fluoride concentrations may be determined
using ion chromatography and kits, but are subject to interference
problems. Fluoride concentrations may also be determined using
specific electrode potentiometric analysis. Sulphate concentrations
may be determined by ion chromatography, which is rapid but subject
to interference when samples are discoloured or turbid, or by
the gravimetric method, which is less subject to interference
but takes up to 24 hours to obtain results.
Organic parameters (TOC in liquids,
TOC in solids and Loss on Ignition, LOI): For the proposed thresholds,
there are no particular problems in analysing Total Organic Carbon
(TOC) in liquids, TOC in solids and LOI. The 5 per cent threshold
for TOC in solids and sludges will have a marked impact on the
acceptance of these waste types at both non-hazardous and hazardous
The WAC parameter Dissolved Organic Carbon (DOC)
corresponds to the TOC in eluates. The analytical method proposed
for TOC analysis in the TAC is not a standard method and has yet
to be discussed at a European level. Although the proposed method
may be justified for organic matter found in the soil, it is not
justified for industrial organic matter, nor specifically in the
case of stabilised waste with neutral pH, requiring the addition
of very significant acidity, which does not correspond to any
realistic environmental scenario given the high buffering capacity
of stabilised waste. The proposed WAC thresholds for the pH-neutral
TOC parameter should therefore be removed.
Concerning acceptance of waste at hazardous
waste landfills, WAC thresholds can be assessed with ICP-AES.
Quantification limits obtained with AAS are close to the proposed
thresholds and may require refinement using a hydride technique,
which is much more difficult and constraining to implement than
the direct method.
For acceptance of waste at non-hazardous waste
landfills, the AAS method cannot be directly applied to determine
WAC thresholds, and the ICP-AES method can be used to determine
concentrations only up to the threshold limit, depending on the
performance of each apparatus and the sample matrix.
Significant additional analysis costs could
be generated by the addition of new parameters not normally analysed
on a regular basis (antimony, barium, molybdenum, selenium, chlorides,
fluorides, sulphates) for hazardous waste acceptance and especially
by the appearance of parameters for non-hazardous waste acceptance,
with some very low corresponding thresholds (eg mercury, antimony,
Finally, we note the absence of numeric WAC
thresholds for solidified, monolithic treated products, a significant
information gap given that stabilisation/solidification appears
capable of treating a wide range of diverted hazardous wastes
streams. We understand the TAC is currently considering this issue,
as well as the relevance of physical WAC such as compressive strength
for stabilised waste.
The Influence of the WAC on Treatment Options
In order to gauge the effect of the numeric
WAC on waste disposal practices, we analysed twenty waste types
which were amenable to stabilisation/solidification as a tertiary
treatment option. We then compared the test eluates against the
WAC thresholds for acceptance into a non-hazardous waste landfill
(albeit in a separate cell) and in a hazardous waste landfill.
Eluates from both treated and untreated wastes were tested for
a range of WAC parameters for which analytical facilities were
already available at SITA laboratories. Thus, barium, molybdenum,
selenium and antimony were excluded from the test protocol.
The results are shown in Table 4.
The table can be interpreted as follows. Against each of the L/S
The letter A signifies whether the
parameter criterion is passed for deposit of the waste into a
non-hazardous waste landfill, without further tertiary treatment.
The letter B signifies that the parameter
criterion is passed for deposit of the waste into a hazardous
waste landfill, without further tertiary treatment.
The letter C signifies that the parameter
criterion is passed for deposit of the waste into a hazardous
waste landfill, but only after stabilisation.
The table indicates that for some waste types
(for example, N waste (flyash) and M waste (bottom ash)) the suite
of parameters analysed do not produce a consistent outcome, in
that some parameters fail the WAC test for disposal into non-hazardous
waste landfills, while others pass the test. Furthermore, application
of the WAC test with a L/S ratio of 2 can in some cases result
in a different outcome to a test conducted with a L/S ratio of
10. For example, A waste (sludge from inorganic chemistry), I
waste (sludge from organic chemistry) and Q waste (foundry dust)
would be accepted in hazardous waste landfills without stabilisation
by applying an L/S ratio of 10, but would require stabilisation
if an L/S ratio of 2 was applied in the eluate test. Testing for
the remaining metals would not alter this basic picture.
Thus, it would appear that an eluate test conducted
with an L/S ratio of 2 is more restrictive for landfill disposal
and/or requires pre-treatment before landfill disposal. Clearly,
further work is required to better understand the impact of the
WAC thresholds on treatment options and eventual acceptance of
the treated waste into landfills.
There remains the issue of applying waste acceptance
criteria representing Final Storage Quality (FSQ) to wastes destined
for landfills. FSQ has yet to be developed into a set of numeric
criteria, but the concept is one that SITA supports in relation
to hazardous waste management, if by meeting the relevant quality
criteria an operator is, by implication, released from future
liabilities attached to the site. If the aftercare provisions
of the LFD cannot be amended (ie. the requirement to monitor and
manage closed sites for 30-40 years), then it would appear to
SITA that no advantage would be gained in treating hazardous waste
to a standard stricter than the current WAC requirements, which
will inevitably add further cost to the treatment process.
Timing of the Ban on Co-disposal
For a number of hazardous waste streams, the
LFD will begin to take effect from 16 July 2002, in particular
the banning of hazardous liquids from landfills. With spare capacity
at existing physicochemical treatment plants, SITA believes the
needs for this particular waste stream should be met, especially
since the sludges resulting from such treatment can continue to
be co-disposed in landfills.
The key issue is how the ban on co-disposal,
currently scheduled to take effect from July 2004, should be managed
from a regulatory standpoint. If the UK wishes to adhere to this
All players need to gain a better
understanding of the waste streams affected, the measures to be
taken by waste generators on their production sites, incremental
treatment costs, and the net effect on waste arisings and associated
treatment needs. Also to be assessed is the effect on hazardous
waste arisings following changes to the Hazardous Waste List.
Waste acceptance criteria, together
with standard protocols for measurement and interpretation, must
be in place for all treated waste types, including stabilised
monolithic waste forms. In the absence of numeric WAC, landfill
operators will not accept liability resulting from the deposit
of hazardous waste into either hazardous waste landfills or into
separate cells created in non-hazardous waste landfills.
Alternative treatment options must
be substantially in place, either in terms of new facilities,
or by refurbishment of existing treatment capacity.
Government must ensure that the regulatory regime
and the market conditions it engenders do not disadvantage alternative
treatment schemes. SITA believes that the present two-year transition
period to July 2004 during which co-disposal will continue to
co-exist with alternative treatment, could in itself discourage
investment in new plant, given the disparity in disposal costs
that additional treatment will impose. We expect landfill prices
to fall as landfill operators seek to maximise hazardous waste
deposits, especially into sites scheduled to close by July 2004,
while waste producers will continue to use the least cost (legal)
option of landfilling.
Any further delay in implementing the ban on
co-disposal is likely to exacerbate this tendency, but at the
same time SITA recognises the practical and logistical difficulties
in gearing up for a July 2004 date. We therefore suggest the following:
July 2004 should still be the preferred
date for implementation of the ban on co-disposal, and should
be targeted as such in any action plan developed by the Environment
Agency and DEFRA.
The ban should be implemented from
a single date rather than being phased in geographically or over
time, and in conjunction with the relevant waste acceptance criteria.
There may be a need for the UK to
seek derogations on one or more of the numeric waste acceptance
criteria, perhaps linked to specific waste types and say for a
further two years, to allow time for the development of appropriate
treatment processes. These might include flyash (and perhaps bottom
ash) residue from incineration and other thermal treatment processes
with respect to chloride and sulphate levels in the test eluate,
and total/dissolved organic carbon (TOC/DOC)) in industrial sludges.
Concurrently, Government must take
measures to streamline the planning and permitting process in
order to reduce determination times which currently can run to
2-5 years depending on the type of facility.
We note in passing that monies from the Landfill
Tax Credit Scheme have almost exclusively been directed towards
enhancement of the management of municipal, commercial and non-hazardous
industrial waste in the UK. The challenges faced by waste producers
and by the waste management industry with respect to hazardous
waste are as daunting, with solutions required in a far shorter
Notwithstanding the challenges in readying for
a ban on co-disposal from July 2004, SITA considers a more prolonged
continuation of co-disposal alongside more costly alternative
treatment options to be counterproductive, and less likely to
achieve the objective of providing alternative facilities.
We recommend that Government continues
to regard July 2004 as the target date for the implementation
of a ban on co-disposal. Work is required both nationally and
through the Technical Adaptation Committee to complete the development
of waste acceptance criteria, final storage quality and associated
test procedures for treated waste (including monolithic products)
in order for these to be applied simultaneously with the ban on
co-disposal nationally, and on a single date.
There are large uncertainties in the data and
information pertaining to the arisings and management of hazardous
waste in the UK. In particular, the surveys conducted to date
have not elicited much information on the waste producers' preparations
for the LFD and its effect on their production processes, disposal
practices and costs.
We recommend that Government constitutes
a working group comprising the relevant industry associations,
to arrive at a consensual position between waste producers and
the waste management industry as to the net effect of the LFD
on waste arisings, associated treatment requirements and disposal
costs. The present uncertainties must be addressed before the
waste management industry accelerates the investment decisions
necessary for the UK to implement a ban on co-disposal.
This is an immediate need for Government and
other stakeholders to consider whether derogations are to be sought
for some waste types and/or WAC parameters.
We recommend that the working group
considers this as a priority issue, and that the appropriate negotiations
are commenced through the TAC and the European Commission.
The ultimate challenge is to convert strategies
and plans into operating facilities. The waste management industry
has for many years faced inordinate delays in achieving planning
and permitting for its facilities, be they incinerators or "greener"
alternatives such as recycling and compost plants.
We recommend that Government develop
systems and procedures that conflate the planning and permitting
process into a shorter timeframe, while retaining the checks and
balances required to ensure appropriate scrutiny of the applications
and protection of the environment.
ALTERNATIVE TREATMENT ROUTES FOR SOME PRINCIPAL
HAZARDOUS WASTE STREAMS CURENTLY LANDFILLED
|Contaminated soil/C&D waste||-
|Oil/Water separator sludge||-
|Sludge from industrial WTP||-
|Still bottoms and residues (org chem)||
|Sludge from pet. refining||-
|Production of org preservatives and biocides
|Waste containing fuel (cleaning and transport)
|Sludge from mechanical surface treatment
SSP = Stabilisation/solidification processes
INC = High temprature incineration and co-incineration
PC = Physicochemical treatment
S = Solvent recovery
L = Direct landfilling
BM = Bioremediation (of contaminated soil)
TDES = Thermal desorption (of contaminated soil)
ESTIMATES OF ANNUAL DIVERTED TONNAGES (TOTAL 2.1 MILLION
TONNES) AND ALTERNATIVE TREATMENT REQUIREMENTS (ROUNDED TONNAGES)
|Treatment Option||Diverted Tonnage Requiring Treatment (Post 2004)Tonnage% of Total
||Annual Tonnage Presently Treated
||Total Tonnage for Treatment (Post 2004)
||Estimated Annual Current Capacity (Tonnes)
|W W T Works||100,000
|Biorem/thermal/Stabilsation||525,000 (contam. soil)
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