Transcript HazWasteOnline Presentation

Dragging Waste Classification into the 21st
Century
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Dr. Ian Bishop
One Touch Data Ltd
[email protected]
Tel: 01628 771731
www.hazwasteonline.com
July 7, 2015
© 2013 One Touch Data Limited
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Background - Waste Classification
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Following current EC regulations and Environment Agency
guidance, waste holders and their advisors (producer, carrier
or disposal) are required to make an assessment of their
waste materials and classify them as either hazardous or nonhazardous waste.
Waste is “any substance or object which the holder discards
or intends or is required to discard”
Law applied through Regulation 1272/2008/EC Classification, Labelling and Packaging of substances and
mixtures (CLP)
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Annex VI, Table 3.2
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2000/532/EC - European Waste Catalogue List of Waste
 Adaptations to Technical Progress for European Regulation
1272/2008/EC (ATP)
 WM2 v3 – Environment Agency technical guidance
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Hazardous Properties
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 H11 Mutagenic
H1 Explosive
 H12 …release toxic gases….
H2 Oxidising
 H13 Sensitizing
H3 Flammable
 H14 Ecotoxic
H4 Irritant
 H15 …yield another substance
H5 Harmful
after disposal…
H6 Toxic
H7 Carcinogenic
H8 Corrosive
H9 Infectious
H10 Toxic for Reproduction
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Waste Classification
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Not just landfill disposal
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Not the Waste Acceptance Criteria (WAC)
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Not the same as H&S Labelling
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Not just development sites
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Fundamentally different to assessing risks
from contaminated land
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© 2013 One Touch Data Limited
The investigation and remediation of land
contamination is risk based
the assessment of contaminated soil as hazardous
waste is hazard based
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Why classify waste (correctly)
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Required by law
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Money
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Choice of landfill
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© 2013 One Touch Data Limited
Hazardous waste disposal is about 3 to 4 times the
cost of non-hazardous waste
Transportation and associated costs
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Can have a major impact on the viability of
brownfield site development
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Potential breaches of legislation if classification
is incorrect
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Disposal to Landfill - Costs
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Excavation costs: £3 to £5/m3
Haulage e.g.
 Vacuum trucks : £55/hour
 Skips, Roll-on/Roll-off : £45/hour
So cost for 100 miles : ~ £135 to £165/load
+ Profit...
Gate Fees : £12 to £90/tonne1
Landfill tax :
 Standard Rate £80/tonne
 Lower rate : £2.50/tonne
Other costs
 Lab : Chemistry £100 to £150/sample
 Lab : WAC (full suite) £100/sample
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© 2013 One Touch Data Limited
1 WRAP, Gate Fees Report, July 2013
Classification of Hazardous Waste
Classification is based on:
 type of waste, and/or
 the chemistry of the waste
 The challenging wastes are the mixtures:
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such as soils, C&D, sludges, filter cakes, ash
Way the system works – the “waste pipeline”
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consultants
 contractors
 hauliers
 brokers
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→ Waste Receiver
Waste Producer has legal responsibility for disposal
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However – There are “Issues”
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Most classification in UK is actually done by the Waste
Receivers – but
 Most chemistry data is paper based
 Waste Receiver doesn’t have time to type data into
spread sheets or 3rd party software
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Rule(s) of thumb, and
 “Experience”
No audit trail
Many examples of companies losing a tender for
hazardous waste - because another party provides a
lower quote for non hazardous waste..
Huge difference between standard and lower rate of tax
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Different answers
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This “experience” based approach can explain why
 Producers can get different responses from
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different Waste Receivers
 the same Waste Receiver
It should also be remembered that the Waste Receiver has
the final say on any waste (classification) – if they don’t
want it, they don’t have to accept it
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Classification data v WAC data
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They are not the same and cannot be mixed
Classification has to be done first – then you can look at
whether you need WAC data
All waste producers must obtain characterisation data
that, among other uses, will determine the destiny of
each of their waste streams.
First, there may be a need to determine whether the
waste is hazardous or non-hazardous (Classification).
Then, if it is to be landfilled, the class of landfill at which
it can be accepted must be identified.
The waste then has to comply with the waste
acceptance criteria (WAC) for that class of landfill
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Waste Acceptance Criteria
Is the waste to be disposed of to landfill ?
Yes
No
Is the waste defined as hazardous ?
Yes
No
Hazardous WAC apply
Met
Can be accepted at hazardous
landfill
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WAC not applicable
Fail Inert WAC
Failed
May be accepted at
non-hazardous landfill
Meet Inert WAC
May be accepted at
inert landfill
Can not be accepted at hazardous landfill.
Other options required, such as treatment.
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Stable Non-Reactive Hazardous Wastes
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You can dispose of Stable, Non-Reactive Hazardous
Wastes (SNRHW) in non-hazardous landfills
 This is waste that is incapable of reacting with other
wastes
 Managed in dedicated cells
 SNRHW potentially include
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Monolithic solidified wastes in large blocky forms
 eg those mixed with cement or PFA
 Granular solid wastes
 eg filter cakes, treated fly ash
 Asbestos
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SNRHW Waste Acceptance Criteria apply
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Think of it this way
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WAC data tells you what is in the water, while
Classification needs to know what is in the tea bag
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WAC Responsibilities
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There is no obligation on any landfill operator to
take waste if they choose not to
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Their Permit entitles them to take waste of
particular descriptions but does not compel them
to do so
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Waste operators may require additional testing of
waste soils prior to acceptance at landfill
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The obligation to ensure compliance with Waste
Acceptance Criteria (WAC) is placed on the
operator of the landfill.
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How is classification done
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“Experience”
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By hand
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Spreadsheets
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HazWasteOnline
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Spreadsheet approach - Issues
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Limited suite of substances
Version management
Traceability/transparency
Auditability
Accuracy
Unwitting deletion of code by user
Continuity/maintenance when author moves on
Time (cost) taken to:
 Research and add new substances
 Update following :
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new version of WM2
 A new ATP
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Example: Nickel Sulphate
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Soil with 484 mg/kg of nickel in the form of nickel
sulphate – Is it hazardous or non hazardous?
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A consultant had a spreadsheet which said Non
Hazardous
HazWasteOnlinetm said Hazardous
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WM2 v2.3 then added H13
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HazWasteOnline’s Approach
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Waste Producers or their agents should do all the work
and create and generate a standard, electronic
Package containing:
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The data
 Classification(s)
 Assumptions
 Supporting documentation
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They should be able to submit it to one or more Waste
Receivers – on-line, or
To the next person in the chain – also on-line
Stakeholders should be concentrating on what’s in the
waste and not on how to do the calculations
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Review Package
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The Waste Receiver(s) should then be able to:
 Review the Package,
 Question any data, assumptions
 Provide a quote
With no data entry requirement
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HazWasteOnlinetm - Where we are now..
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Now used in UK and Republic of Ireland
Follows current EC regulations and the latest
Environment Agency guidance,
HazWasteOnlinetm provides waste holders and their
advisors (producer, carrier or disposal) with a quick,
easy to use web-based tool that allows for the rapid
assessment of waste materials and their classification
as either hazardous or non-hazardous waste.
Software as a Service
Compatible with all modern browsers
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Published new engine for WM2 v3 in August 2013
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Features
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All 20 chapters of EWC
More than 4,000 substances from:
 Table 3.2, Annex VI of the CLP
 Others
Create your own waste stream templates
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Users can define their own substances
Cut-n-paste from spreadsheets
Analyse one, ten or hundreds of samples at a time
Document Management system
PDF paginated reports
Packaging Tool
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HazWasteOnlinetm is also
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Iterative
 What if - scenarios
Audit trail
Transparent
Users are notified by email about new features,
guidance, substance & ATP updates etc.
Versioning of calculation engine, database and
substances
Can supports a company’s ISO 9000 systems
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Dragging waste classification in to the 21st
century ..
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Software as a Service
Standard approach
Stakeholders can concentrate on what’s in the waste
and not on how to do the calculations
Allow stakeholders to publish packages to other
stakeholders
Quality
Transparency and auditability
Level playing field
Reduces risks
Saves time
Saves money
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PART II
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Natural materials
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FYI - Many other metals:
Also mercury, lead
nickel
Ander et al. 2013:
Methodology for the
determination of normal
background concentrations
of contaminants in English
soil
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G- BASE – iron oxide in surface soils
Mean: 4.52%
Median: 4.24%
Maximum: 33.0%
19,562 samples
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Acid/Alkali Reserve & WM2
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If the waste is hazardous due to pH only (≤2,
≥11.5), this measurement can be used to
indicate whether waste is hazardous due to
H8 or H4 *
 Units = g NaOH /100g of substance
required to adjust the pH to the appropriate
value
 refer WM2 Figure C4.1 Decision tree for
the assessment of hazards H4 and H8”
Add it to a waste stream template by selecting
"Add pH" which loads “pH: acid/alkali reserve”
* WM2: If the acid/alkali reserve test indicates that the waste may not be
corrosive (H8) or irritant (H4), this must be confirmed by an in vitro test
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Changes WM2 - summary
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Status of EWC codes wrt mirrors and absolutes
 eg oil based drilling fluid
 01 05 05* oil-containing drilling muds and wastes
Note 1 applies to all hazard properties
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Re-arranged H14 ecotoxic steps (10 down to 5 steps)
Criteria for H5 and H6 modified
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Substances with R26, R27, R28 are now hazardous
by H6: Toxic at ≥ 0.1%
 Substances with R23, R24, R25 are now hazardous
by H6: Toxic at ≥ 3%
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PCBs and 50 mg/kg threshold made clearer
OILS…
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Example – EWC changes
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Oil Wastes – Select correct EWC code
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First you have to answer the following question:
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HazWasteOnline
does check
50mg/kg when
these EWC code
containing PCB
is selected
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Does the oil waste have a specific entry in the
EWC?
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13 01 09* mineral-based chlorinated hydraulic oil
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13-05-02* sludges from oil/water separators
Most oils wastes are absolute entries;
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Two exceptions:
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13 01 01* hydraulic oils, containing PCBs
 13 03 01* insulating or heat transmission oils containing
PCB
 Asses these first against 50 mg/kg PCB threshold
 If < 50 mg/kg, then select a different absolute entry
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Waste oils and oil contaminated waste
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Example 3 focuses on mineral and hydrocarbon oils
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And focussed on two types of oil:
 1) Waste mineral oils (predominately oils, liquid fuels
& lubricants, synthetic oils & waste separator oil)
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= Absolute entries
 even if no hazardous properties
 Exceptions = edible oil and sometimes biodiesel
 Use safety data sheet, failing that petroleum group
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2) Wastes contaminated with oil
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i.e. oil phase is not major component
 Known oil
 Known group of oils
 Unknown oil
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3 Scenarios – soils contaminated with oil
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Known oil
 eg - oil spill
 Use SDS
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Known oil type
 Eg - diesel tank on a farm
 Use diesel petroleum group
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Unknown oil
 eg – contaminated soils
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Wastes that are contaminated with oil
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If can identify petroleum group, e.g. diesel, but specific
brand is unknown
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Can use petroleum group
 Can use markers to assess carcinogenicity for some oils
 All other hazardous properties must be considered
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Cannot assume that if DRO range (C10-C25) is present
that it is a diesel
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© 2013 One Touch Data Limited
Would need a lab to report that results are consistent with
diesel/weathered diesel
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Weathering - diesel
Fresh diesel
Weathered diesel
- losses of more
volatile components
up to C12
- Could get similar
result with air-dried
samples
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Unknown oil
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Case where identity of the oil is unknown and cannot be
determined
Have to consider potential present of other organic
contaminants e.g. coal tar, solvents, ash, plant material
Have to ask lab to consider whether oil could be diesel
Otherwise assume following risk phrases
 R65 (H5 Harmful) ≥25%
 R63 (H10 Toxic for Reproduction) ≥5%
 R51/53 (H14 Ecotoxic) ≥2.5%
 R45 (H7 Carcinogenic) ≥0.1%
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Flammability (H3A/H3B)
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Unknown oil – use of the BaP marker
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Unknown oil can be classified as non carcinogenic if..
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the concentration of TPH is ≥ 0.1% the waste will
be H7 Carcinogenic and H11 Mutagenic, unless the
concentration of the marker benzo[a]pyrene is
<0.01% w/w of the concentration of the TPH; and
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this has been determined by an appropriate and
representative sampling approach in accordance
with the principles set out in Appendix D; and
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the analysis clearly demonstrates, for example by
carbon bands or chromatograph, and the laboratory
has reasonably concluded that the hydrocarbons
present have not arisen from petrol or diesel
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