draft report current and future controlled waste practices in … · 2011-07-27 · infrastructure...

DRAFT REPORT Current and Future Controlled

Waste Practices in Tasmania

January 2008

Prepared for: The Tasmanian State Government

Current and Future Controlled Waste Practices In Tasmania – SIA 2

LIMITATIONS STATEMENT This report has been prepared in accordance with the scope of services agreed upon by the Tasmanian Department of Economic Development (DED), the Tasmanian Department of Tourism, Arts and the Environment (DTAE), and Sustainable Infrastructure Australia Pty Ltd (SIA). In preparing this report, SIA has relied upon data, surveys, analyses, plans and other information provided by the Tasmanian State Government, industry, and other individuals and organisations. Except as otherwise stated in this report, SIA has not verified the accuracy or completeness of such data, surveys, analyses, plans and other information.


TABLE OF CONTENTS Abbreviations ..................................................................................................... 5

1. EXECUTIVE SUMMARY .................................................................................. 6

1.1 Summary of Findings ........................................................................................ 6

1.2 Recommendations .......................................................................................... 17

2. TASMANIAN CONTROLLED WASTE MANAGEMENT STRATEGY ........... 20

2.1 Purpose ........................................................................................................... 20

2.2 Guiding Principles ........................................................................................... 20

2.3 Key Actions ..................................................................................................... 20

3. INTRODUCTION ............................................................................................. 24

3.1 Purpose ........................................................................................................... 24

3.2 Objective ......................................................................................................... 25

3.3 Scope and Methodology .................................................................................. 25

4. CURRENT PRACTICES AND CONCERNS IN TASMANIA .......................... 28

4.1 Current and Future Regulatory Environment in Tasmania .............................. 28

4.1.1 Controlled Waste Legislative Instruments ....................................................... 29

4.1.2 Key Issues with the Current Regulatory Environment ..................................... 37

4.1.3 Future Regulation ............................................................................................ 40

4.2 Classification of Controlled Waste ................................................................... 42

4.3 Present Controlled Waste Quantities .............................................................. 43

4.3.1 Data Sources ................................................................................................... 43

4.3.2 Evaluation of Data ........................................................................................... 43

4.3.3 Present Quantities ........................................................................................... 44

4.4 Historical Stockpiles ........................................................................................ 45

4.5 Future Generation Forecast ............................................................................ 47

4.6 Current Facilities, Capacity and Practices ....................................................... 50

4.6.1 CONTROLLED WASTE LANDFILLS .............................................................. 50

4.6.2 WASTE TRANSFER STATIONS .................................................................... 54

4.6.3 OTHER TREATMENT / DISPOSAL FACILITIES ............................................ 56

4.7 Controlled Wastes Currently Shipped Interstate ............................................. 56

4.8 Current Cost of Disposal ................................................................................. 61


5. ANALYSIS BY WASTE TYPE ........................................................................ 64

5.1 Cyanides (inorganic) ....................................................................................... 65

5.2 Acid solids and solutions ................................................................................. 67

5.3 Inorganic chemicals ......................................................................................... 70

5.4 Reactive chemicals ......................................................................................... 73

5.5 Paints, lacquers, varnish, resins, inks, dyes, pigments, adhesives ................. 75

5.6 Organic solvents, solvent residues .................................................................. 78

5.7 Oils, hydrocarbons, emulsions ........................................................................ 82

5.8 Putrescible / organic wastes ............................................................................ 86

5.9 Organic chemicals ........................................................................................... 94

5.10 Solid / sludge wastes requiring special handling ............................................. 98

5.11 Clinical and pharmaceutical wastes .............................................................. 102

5.12 Waste tyres ................................................................................................... 110

5.13 Security materials .......................................................................................... 116

5.14 Quarantine wastes ........................................................................................ 117

6. AUSTRALIAN ANTARCTIC TERRITORY ................................................... 125

7. FUTURE DEVELOPMENT OPTIONS AND OPPORTUNITIES ................... 128

7.1 Business Case Assessment .......................................................................... 128

7.2 Economic Analysis of Solutions .................................................................... 130

7.3 Technology Review ....................................................................................... 139

8. BUSINESS RISK ASSESSMENT ................................................................. 144

9. RECOMMENDATIONS ................................................................................. 157

10. REFERENCES .............................................................................................. 160

11. APPENDICES ............................................................................................... 162


ABBREVIATIONS

AQIS Australian Quarantine and Inspection Service BOO Build, Own, Operate (project) CA Consignment Authorisation (issued under the NEPM) CPI Consumer Price Index DED Department of Economic Development DPIWE Department of Primary Industries, Water and the Environment DTAE Department of Tourism, Arts and the Environment EMPCA Environmental Management and Pollution Control Act 1994 EPA Environment Protection Authority EPN Environment Protection Notice FOM Fixed Operations and Maintenance LUPAA Land Use Planning and Approvals Act 1993 N/A Not applicable NEPC National Environment Protection Council NEPM National Environment Protection Measure (for the Movement of

Controlled Wastes between States and Territories 2004) NPV Net Present Value O&M Operation and Maintenance PCB Polychlorinated biphenyls PPA Power Purchase Agreement RoE Return on Equity SIA Sustainable Infrastructure Australia STP Sewage Treatment Plant TPA Tonnes per annum VOM Variable Operations and Maintenance WSA Waste Supply Agreements WTB Waste Transport Business (as permitted under EMPCA) WTC Waste Transport Certificate (issued under the NEPM) WTS Waste Transfer Station


1. EXECUTIVE SUMMARY

1.1 Summary of Findings

Background

The Business Case and Feasibility Study for Controlled Waste Management Facilities in Tasmania was commissioned by the Tasmanian Government to assess the current status and commercial viability of controlled waste management facilities and practices in Tasmania, as part of a state-wide controlled waste management strategy.

This study comes at a critical time, as the performance requirements of the state Landfill Sustainability Guide will come into force on 30 June 2009, by which time all controlled waste facilities in Tasmania must satisfy the acceptable standards and provisions of the Guide in order to continue to accept and dispose of controlled waste. Tasmania currently does not have landfills or processing facilities that are fully compliant with modern best practice standards for ‘secure’ landfills. Lack of adequate facilities may result in significant costs to Tasmanian businesses and may impede economic expansion for the State.

In addition to considerable economic impacts, inadequate controlled waste management facilities and practices have the potential to result in significant harm to the environment and may also have adverse effects on human health. It is therefore essential to develop a strategy that meets the needs of Tasmania’s industry and a growing economy, whilst ensuring controlled waste generated in Tasmania is sustainably managed and the potential risks involved in its transport, storage, treatment and disposal are minimised.

Current Position

Waste regulation, standards, practices and facilities have developed significantly in Tasmania over the past 15 years. With the involvement of State and Local Government and the commercial sector, Tasmania has progressively moved away from very rudimentary practices and facilities. This has resulted in:

Significant reduction and consolidation of landfills in the State from 99 landfills in 1994 to the current 17 landfill facilities. This has also resulted in a larger number of waste transfer stations being developed acting as satellite


infrastructure to key facilities. In many cases due to efficiency, cost and liability issues, Local Government has closed landfills and contracted out waste disposal to regional or other facilities;

An increase in the cost of waste management and disposal, which in some cases has increased significantly;

Issues of non-reporting and inappropriate disposal practices, for example illegal dumping;

A change of culture and attitude towards waste management, risk and liability, including an improved understanding of the ‘waste management hierarchy’;

Improvements in cleaner production, waste recycling/exchange and waste treatment;

Uncertainty, variability and arbitrary responses to infrastructure and waste management from Government, having an impact on new infrastructure development and market-based solutions; and

Greater quantification, understanding and regulation of controlled waste leading to significant improvement in tracking, handling, management and disposal/treatment of controlled waste in Tasmania.

During the course of this review, and specifically as a result of stakeholder consultation, it was clearly understood that inadequacies with respect to the regulation and enforcement of controlled waste are the most significant barrier to improving waste management practices and standards, and encouraging investment in new or existing infrastructure in Tasmania.

The Need for Reform to Promote Investment

A clear finding of this study is that if the current position in relation to legislative controls and enforcement does not change, then this will act as a significant investment barrier to new or existing facility operators developing waste infrastructure to service Tasmania’s requirements. The levels of regulatory risk involved in such developments can be significant, especially when dealing with controlled waste. Not having clear or effectively enforced regulation will be a primary deterrent to new investment. Considerations for the effective regulation of Tasmania’s controlled waste in the future include:

More dedicated resources for compliance and enforcement; Development and implementation of a ‘Controlled Waste Management

Methods Guide’ to provide consistent and high level advice on allowable practices, transport, handling and treatment/disposal options to controlled waste generators, waste companies, facility operators, stakeholders and the public;


An understanding of how to firmly and consistently regulate and enforce best practice standards within the Landfill Sustainability Guide in order to achieve improvements in compliance for landfill siting, design, operation and rehabilitation, and to ensure potential harm to the environment and human health is minimised;

Improvements in education among generators, contractors, local councils, facility managers, and the general public – including awareness of the term ‘controlled waste’ being synonymous with the term ‘hazardous waste’ (thereby emphasising the potential risks involved in its handling and management);

Cooperation between Tasmanian State Government departments; Cooperation and reform of the legislative structure with State and Local

Government to ensure consistency across the Environmental Management and Pollution Control Act 1994 and Land Use Planning and Approvals Act 1993 for waste transfer sites and to promote better infrastructure planning and controlled waste management; and

Additions to the Environment Division’s website, including a functional user-friendly system with appropriate information on controlled waste requirements, options for management, treatment and disposal, and the consideration of a revitalised waste exchange program in a web format.

Controlled Waste Summary

Controlled wastes in Tasmania are categorised as those wastes that are hazardous or potentially hazardous (including the risks involved in transporting, storing and otherwise handling such materials). Due to the extensive number of classified controlled waste types, SIA has grouped together controlled wastes into broader categories, based on the National Environmental Protection Measure (NEPM) waste categories and DTAE guidelines. A number of categories have been combined where there are common handling, treatment and disposal methods. This approach aids in the analysis of options and treatment methods for each waste category discussed in more depth in the report. A brief overview for each controlled waste category is outlined below:

Waste Category Comments

Cyanides (inorganic)

Very small quantities are generated across mining, electroplating and manufacturing operations.

Generation is estimated to decrease in the future. Negligible quantities are transported interstate. Readily destroyed on-site (in tailings dams) by a

natural process, or chemically destroyed by means of neutralisation and oxidation.

Minimal opportunities for re-use or recovery.


Waste Category Comments

Acid solids and solutions;

Alkaline solids and solutions;

Laboratory/photography chemicals

Apart from interstate transport (often in conjunction with other wastes), current management practices in Tasmania include pre-treatment (neutralisation) and disposal to landfill, transport to a wastewater treatment plant, or on-site management.

Very small quantities generated, expected to remain steady.

Acids and alkalis can be used for other waste treatments, for example neutralisation, precipitation and oil/water separation (emulsion breaking). Silver can be recovered from photographic chemicals.

Inorganic chemicals

Zinc compounds comprise the majority of interstate shipments of inorganic chemicals and are produced by one metal products manufacturer.

Also lead and mercury compounds, and batteries from industry, vehicle servicing, domestic sources, electrical equipment and telecommunications.

Mainly exported to minerals processing plants for their metal values.

Apart from interstate transport, management practices include on-site management through recycling and re-use at major industrial sites e.g. hydro-metallurgical metal salts recovery.

Temporary on-site stockpiling, often stored between collection dates (e.g. batteries) and then shipped interstate for recovery, treatment and disposal.

Reactive chemicals

Negligible interstate transport due to potentially hazardous (e.g. explosive) waste characteristics.

Under carefully controlled conditions, specialised disposal companies employ some waste oxidant streams (hypochlorite and peroxide) in the treatment of heavy metal wastes. They can also be safely disposed to sewer under controlled conditions.

Paints, lacquers, varnish, resins, inks, dyes, pigments, adhesives;

Pesticides

Residues from a wide variety of Tasmanian industries, commercial operations and households, generally in small volumes and containing a wide range of toxic and hazardous compounds.

Larger quantities of liquid residues are transported off-shore for recovery into waste oil fuels. There is no such facility in Tasmania.

There are enterprising operators in the paints and coatings industry who produce low-cost primer and


Waste Category Comments undercoat by blending compatible paint residues. Paints are also re-used by tip shop and recovery operations.

The ‘Drum-muster’ program operates successfully, requiring triple rinsing of pesticide/herbicide containers prior to depositing at a council collection point for crushing and recycling.

Organic solvents, solvent residues

Either processed on-site (e.g. distillation), stockpiled awaiting further management (such as re-use by blending into waste oils for use as kiln fuel), or exported for treatment and recovery.

An overall increase in generation expected. Of organic solvents transported interstate, the

majority is sent to Victoria and remainder to NSW. Very few solvent re-distillers available (a

specialised business). Generation of non-halogenated organic solvent

waste in Tasmania is dominated by three organic (bio) chemicals manufacturers. Smaller quantities generated by education and research institutions, and some manufacturers. Large volumes are recovered and re-used on-site very efficiently.

One manufacturer generates the majority of halogenated organic solvent waste, with small quantities also produced by dry cleaners. Industry changes are taking place that will replace these with non-halogenated solvents.

Oils, hydrocarbons, emulsions

Materials in Tasmania are recycled or reprocessed, converted to energy or stored.

Volumes are expected to increase in the future, in line with economic and population growth. Tasmania has a large and diffuse waste oil generating base.

Generators include service stations, machine shops and service facilities, oil terminals, shipping/ports, and mining and industrial sites.

The tarry residue has value to the recipient, and most is sent to Victoria and also NSW.

Waste oil handled by a Tasmanian oil recycler is used to fuel the local lime kiln, a chipboard manufacturing plant, and for greenhouse heating.

Only small quantities are collected via waste transfer and recycle stations.

Putrescible / organic wastes

Includes abattoirs and fish and poultry processors, sewage treatment plants, and commercial and


Waste Category Comments domestic grease trap waste generators.

Negligible interstate transport or stockpiling due to waste characteristics (apart from biosludges stored in earthen bunds).

With the lack of rendering capacity, some abattoir waste appears at landfills and some may go to land-farming, both of which are far from ideal.

A good portion of the fish processing waste goes to one composting operation and is a beneficial raw material for producing compost. Additional composting capacity is required in the State, and this will provide a resource for handling expected increased volumes of fish processing waste.

Fish processing waste may also be rendered, as is already occurring, for value-added products like fish oil and fish meal.

Biosludge is either tankered or dewatered and trucked away for land-spreading. Some dewatered sludge is also received at landfills. Due to the pathogen hazard and potential for heavy metals build-up, in some cases this is far from ideal. Co-composting makes good use of water and carbon.

Organic chemicals

Low annual quantities from a handful of generators, mostly PCB-related material such as capacitors, oil, and solvent transformers (sent interstate for treatment/disposal at Victoria, ACT and Queensland).

Generators include mining sector (electrical equipment) and electricity generators and distributers.

Estimated decrease over time as large owners dispose of their contaminated oil.

Small quantities of a variety of chemicals mean that these wastes in general will have to go into a larger stream or market, most likely interstate.

Solid / sludge wastes requiring special handling

Based on the characteristics of wastes in this category, landfilling appears to be the dominant management method in Tasmania.

Several large stockpiles of items such as filter cake from chemical and metallurgical processes, contaminated containers, contaminated soils, concrete, asphalt and demolition waste.

Minimal, if any, interstate transport. Clinical and pharmaceutical wastes

Materials generated by the health care industry and other clinical settings, which have the potential


Waste Category Comments to cause infection, injury or public offence e.g. anatomical waste and body fluids, sharps, cytotoxics, waste pharmaceuticals, and chemical waste.

There is no evidence to suggest a decrease in generation in Tasmania in the future, as clinical and pharmaceutical waste is likely to increase due to both an increase in the demographic proportion of aged people in Tasmania and the increasing use of health care services for a broad range of applications.

Majority is sent to landfill. Liquid wastes (such as body fluids) are often discharged to sewer, waste pharmaceuticals and cytotoxics destroyed interstate, and body parts cremated.

Cytotoxic waste and waste pharmaceuticals require high temperature thermal destruction, only available in NSW, SA and Queensland.

Opportunities for re-use and resource recovery of clinical and related waste are particularly limited, due to the potential for infection.

Waste tyres

Includes waste tyres generated from public, commercial, transport and industrial use.

There is a $5 levy on the purchase of new tyres or a disposal charge for disposal of used tyres; the system is not catering for a large proportion of tyres, which are unaccounted for at landfills.

Tyres for retreading will have to go to a specialised manufacturer interstate but there is scope for this in Tasmania.

With only about one third of the waste tyres (excluding those from mining sector) being processed to go to landfill, there must be significant volumes stockpiled around the state, at best estimate, up to 240,000 tyres per annum.

Potential resources are currently being lost through co-filling i.e. burial of tyres with other wastes.

Significant opportunities exist for the recycling and reprocessing of waste tyres and tyre waste in Tasmania e.g. recovery of liquid fuels and chemicals from rubber by pyrolysis, and fuelling for cement kilns.

Security materials Security materials include currency notes,

confidential paperwork, contraband, confiscated drugs – generated by the police and defence


Waste Category Comments forces, border security, banks and operators of commercial security services.

This is a small but important waste stream, in that most of it can only effectively be disposed of by burning.

Practices include storing, shredding, burning, and burying, with some of the material (for example confiscated drugs) transported interstate for incineration along with cytotoxic and pharmaceutical waste.

This material is always stockpiled until the volume is sufficient to warrant transport to the incinerator. The chief expense is the necessary security measures and armoured truck service.

Quarantine wastes

Primarily wastes from shipping and aircraft, as well as wastes repatriated by the Australian Antarctic Division from the Australian Antarctic Territory settlements and research stations.

Shipping wastes from cruise liners are expected to increase significantly, possibly to as many as 30 dockings and perhaps 100 TPA of municipal type waste.

Generally undesirable to stockpile quarantine wastes, either because it is putrescible and requires refrigerated storage, or because it requires a high security storage facility.

From stakeholder discussion, there is potentially 40,000 - 100,000 tonnes of Australian Antarctic waste that could require repatriation (much of it contaminated soil), and would then be treated as quarantine waste.

Currently quarantine waste is either disposed of via the incinerators at Burnie and Bell Bay ports, or disposed of to landfill – with McRobies Gully receiving the vast majority of this waste.

Transport and handling presents risks to human health and the environment, so adequate safety and containment measures must be in place.

Other possible disposal methods include autoclave sterilisation and gamma irradiation.


Options for Controlled Waste Management Facilities As part of the Business Case Assessment, a financial model was developed to assess the economic viability of a number of development options for the treatment and disposal of controlled waste. Based on the figures presented and the recommendations proposed, it is recognised that potential developers (investors) will undertake further due diligence on the projects to assess their viability from a financial, commercial and technical perspective. The development options analysed are as follows (in no order of preference):

1. Autoclave disinfection 2. Shredding and chemical disinfection 3. High temperature pyrolysis 4. High temperature incineration 5. Use of the cement kiln at Railton owned by Cement Australia 6. Composting and co-composting of biosludges 7. Rendering 8. Neutralisation, precipitation and solidification

There are many variables which affect the financial viability of these potential solutions, and the volume of waste available for treatment is an important one. Volumes in Tasmania are typically small and this means that plant size and therefore cost cannot benefit from economies of scale. One of the key waste streams which would aid the financial viability of a number of these solutions is quarantine waste. It is important to get resolution as to the situation regarding the future management of quarantine waste, including repatriation of waste from the Antarctic, and therefore the security of this waste volume for years to come.

Below is a summary of the findings obtained from financial analysis of the potential development options (discussed in depth in Section 7), including SIA’s assessment as to whether or not a process/technology warrants investment or further investigation.

1. Autoclave disinfection, shredding and landfill

Based on the estimated cost of treatment (primarily due to the high operating cost), SIA believes this may not warrant further investigation at this time. Additionally, the project is only viable if additional quarantine waste, as from the Antarctic, is secured. The use of regional autoclaves has been raised. This is certainly possible, and whilst the financial analysis has not been undertaken on regional facilities, it is expected that the cost of disposal would be in excess of $1000 per tonne for all waste types. There may be desire to pursue this option further, even taking into consideration the relatively high disposal cost.


2. Shredding, chemical disinfection and landfill SIA believes this should not be pursued at this time due to the viability being contingent on quarantine waste being secured. If it can be secured, then the gate fees are such that the project would warrant further analysis.

3. High temperature pyrolysis

SIA believes this is a project that should certainly be investigated further. The project benefits greatly from the additional revenue stream primarily from the sale of liquid fuel and high value chemicals. Further work would be required on firming up the prices and long-term demand for the fuel and chemicals, in addition to securing purchasers, and this would be one of the barriers to entry. We believe that any developer would not view the risk of tyres being unavailable as a barrier to further due diligence.

4. High temperature incineration

SIA believes this should not be pursued at this time due to the high gate fees. This is primarily due to the high operating costs. From a regulatory and approval point of view it would also be a difficult project to get stakeholder buy in. However, this exercise also shows the cost of implementing this solution even if it was considered.

5. Cement kiln injection

SIA believes this is a project that should be investigated further. The project benefits from using an existing asset and therefore there is a reduction in development costs. Some of the waste streams, such as oil and tyres provide fuel to the kiln and therefore there is an avoided cost to the kiln which assists the economics. However, there are some technical issues to further analyse and resolve in order to obtain maximum benefit from the use of this asset. Any investor would want to do due diligence on the use of third parties for waste-to-fuel preparation, in additional to the life of the cement operation and the factors that Cement Australia use in assessing its Railton facility. Any risk in this regard would potentially mean stranded pre-treatment assets.

6. Co-composting of biosludges

SIA believes that projects for co-composting food waste (e.g. fish processing waste), biosludges (dewatered sewage sludge), with green waste, should be investigated further. This would involve the use of mobile dewatering units. This means establishing co-composting facilities and mobile dewatering services across four regions, namely Central, North, North West and South. Effort will be required in identifying and securing the green waste required, however, with the volumes available in each region, it is believed this is possible. The site locations need to be in areas where there will be minimal or no odour complaints, but not too remote such that the costs of transport limit the viability of the plant. The main barriers to investment are, firstly, securing the waste streams and understanding that in adding value, the waste generator becomes the raw materials supplier and is likely to anticipate that his “product” has worth, rather


than his waste attracting a cost. Secondly, making sure that there is a long-term market for compost, identifying purchasers and locking in short-term purchase agreements. The technology risk is low, but maintaining quantity and quality is the key.

7. Rendering plant

Whilst the economics of establishing rendering facilities appears very attractive, this needs to be analysed in the context of the existing facilities for meat, poultry and fish wastes, and the global markets for quality tallows and fish oils, and local markets for the produced meals. It would be worthwhile looking further into establishing another rendering plant including contemporary emissions control equipment and how, if at all, it would fit in with the existing rendering facilities and alleviate the need for disposal of abattoir waste, fish processing waste, and poultry waste to landfill and composting facilities.

8. Neutralisation, Precipitation and Solidification (NPS) plant

This is a relatively small project, however could be attractive if sited next to or on the site of a sewage treatment plant, as the effluent from the NPS plant would need to go to sewer and this would be the ideal location. Being a small plant, the economics are sensitive to small movements in waste volume and price, and it will be necessary for the owner to get comfortable with the security of waste supply. The other barrier to entry is ensuring that the plant will have long-term access to the sewer, regardless of what happens to the sewage treatment plant.

The following technologies were therefore identified as warranting further work or action:

High temperature pyrolysis; Use of the cement kiln at Railton owned by Cement Australia; Rendering facilities for abattoir, fish processing and poultry wastes; Composting and co-composting of biosludges; and A neutralisation, precipitation and solidification facility.

Additionally, the use of autoclaving may still be considered, subject to stakeholders’ desire to proceed given the high treatment costs.

The analysis has shown that there are certainly potential opportunities to attract private investment for the development of solutions for the treatment and disposal of controlled waste in Tasmania.


1.2 Recommendations

1) The Tasmanian Government needs to apply clear and consistent regulation to controlled waste management practices and infrastructure across the State that is fully enforceable. This is a necessary requirement to promote basic compliance, and remove significant risk factors for the investment in new or upgraded infrastructure.

2) The Department of Tourism, Arts and the Environment should develop a ‘Controlled

Waste Management Methods Guide’ – a high-level tool to advise, educate and apply consistent management practices throughout Tasmania. The guide would provide a current list of appropriate treatment, recovery and disposal facilities, transporters, and waste handlers operating in the State, as well as a clear outline of management and disposal practices for all controlled wastes. Information in the guide would need to be updated on an ongoing basis, particularly to incorporate developments in best practice standards and technologies. This should be an electronic, web based application available to the public.

3) There is a significant opportunity for the State Government to play a facilitation role

with Tasmanian industry, by implementing a program involving targeted controlled waste audits and plans to assist and encourage waste reduction and efficiency measures for key controlled waste generators. The program will provide improved environmental outcomes, and will also make Tasmanian industry more financially competitive. This will also support initiatives such as the Tasmanian Government’s CleanBiz Program implemented in 2006.

4) Key growth industries in Tasmania will deal with the issues of both increasing volume

and increasing cost of waste management. The State Government should consider the development of industry-specific waste plans to assist cost management, business expansion and new investments. Specific industries that are experiencing growth in the State also have some of the most significant controlled waste issues and include:

Mining and metals industry; Food and beverage industry; Aquaculture; Healthcare; and Tourism (quarantine waste from ships and increased visitor numbers).


5) Resource recovery and recycling should be viewed as an opportunity for reducing the cost of waste and environmental impact in Tasmania. Significant ways the State Government can enhance this include:

Providing a facilitation and support role for industry to encourage the development of new options and processes to reduce use, recycle and recover resources;

Improving education within industry, government and the general public; Considering the re-establishment of the Tasmanian Waste Exchange (TWEX)

Program (initially implemented in 2001); and Promoting Tasmania as a centre for excellence in sustainable waste

management.

6) It is critical that State and Local Government in Tasmania work more effectively together, as there are currently overlapping (and at times, ambiguous) roles and responsibilities assigned for controlled waste regulation, control, management and facility operation. Adopting a more cooperative approach will help to deliver the following outcomes:

A reduction in ‘cost-shifting’ for regulation, compliance and provision of infrastructure;

Consistent and uniform regulation for controlled waste management facilities and practices; and

Improved infrastructure planning and efficiency, specifically within regions, leading to improved infrastructure and potential budget savings.

7) The State Government needs to maintain open dialogue with mainland States and

Territories, in order to ensure opportunities for the transboundary movement of controlled wastes are secured under the National Environment Protection Measure (NEPM). Tasmania’s right to trade with other jurisdictions should be kept intact and the NEPM implemented through appropriate negotiation. There needs to be an understanding that Tasmania is a small controlled waste generator, by mainland standards, and requires assistance where possible to manage such wastes.

8) Discussions between Biosecurity Australia, the Australian Quarantine and Inspection

Service, Quarantine Tasmania, the Australian Antarctic Division and the Department of Tourism, Arts and the Environment will continue, with a view to finalising the position on transporting quarantine waste from the Australian Antarctic Territory for treatment and disposal in Tasmania. The type and volume of waste should then be determined, with a view to reassessing the treatment and disposal options.

9) Undertake further due diligence on the high temperature pyrolysis plant for the treatment of tyres, with a view to identifying developers. This report only considers domestic volumes and some commercial volumes. Further opportunities exist if the tyres from operating mines could be used. An audit on the volume of tyres from mines would be necessary.


10) Undertake discussions with Cement Australia regarding the use of the cement kiln at Railton. Discussions could involve the State Government, Tasmanian Minerals Council, Cement Australia and possibly a developer. Further technical and economic due diligence would be required.

11) Fund a feasibility study (or studies) into establishing additional abattoir rendering facilities and incorporating poultry waste; plus facilities for rendering fish processing wastes. Investigate further opportunities for high value meal and oil products from fish processing wastes.

12) Fund a feasibility study into establishing 4 regional co-composting facilities for

biosludges, specifically concentrating on firming up waste volumes, biosludges and green waste, and engaging in discussions with waste generators to establish the commercial basis upon which the wastes could be provided. Furthermore, establish the market and commercial basis for the compost.

13) Identify opportunities for incorporating a neutralisation, precipitation and solidification

plant, possibly at a sewage treatment plant site. Discuss the appetite of the regional water authority to look at the project and undertake further due diligence.


2. TASMANIAN CONTROLLED WASTE MANAGEMENT STRATEGY

This draft strategy has been prepared for consideration by the Tasmanian Government for the current and future management of controlled waste in Tasmania. The strategy has been based upon the detailed study completed by SIA of Tasmania’s controlled waste practices and infrastructure, including consultation with Tasmanian industry and key stakeholders such as waste generators, waste companies and other associations and organisations.

2.1 Purpose

The purpose of this strategy is to outline a clear path forward for the development of suitable waste practices in Tasmania, and to promote the development of controlled waste management facilities to meet the objectives of the State Government’s policy announcement in 2004, set out in the ‘Controlling Waste’ Six Point Action Plan. These objectives include having in place best practice controlled waste management facilities and a regulatory system that supports industrial growth and development both now and in the future.

2.2 Guiding Principles The guiding principles of the Tasmanian Controlled Waste Management Strategy 2007 include:

To meet the objectives, timeframe and requirements of the Landfill Sustainability Guide 2004;

To ensure best practice controlled waste management practices and facilities;

To provide industry with clear planning options for future waste management; and

To provide consistency and certainty with respect to the regulation of controlled waste practices and facilities.

2.3 Key Actions Facilities

Tasmania needs to establish best practice facilities that meet the current and ongoing requirements for controlled waste management throughout the State. This needs to be set within realistic financial parameters to ensure costs are within reason and not prohibitive for Tasmanian industry and business.


All facilities need to meet best practice environmental standards to ensure that controlled waste is managed and dealt with in an appropriate way and does not cause any harm to Tasmania’s land, coast, ecosystems, waterways, atmosphere or human health.

Overcome Barriers to Investment

There is a clear need for consistent and enforceable regulation to reduce investor risk in new or upgraded infrastructure.

The State Government needs to ensure that all current and future facilities

meet required standards to promote the investment opportunity for new or upgraded infrastructure.

The State Government needs to provide clear intentions and direction for all

stakeholders.

Promote Efficiency through Avoidance, Re-use and Recycling

Identify environmental and commercial opportunities with Tasmanian industry and controlled waste generators for waste avoidance, re-use and recycling. This should also be seen as an opportunity to make Tasmanian industry and business more efficient.

Consider re-establishing the Tasmanian Waste Exchange (TWEX) program.

Promote and pursue new technologies and practices to improve waste

avoidance, re-use and recycling as well as efficiencies in waste transport, handling, management and infrastructure.

Industry-specific Strategies

Controlled waste has a much more significant impact on some industries, specifically growing industries such as aquaculture, shipyards, mining, healthcare, and quarantine waste (visiting ships and increasing tourism). These industries require specific strategies to address the needs and requirements for new investment and improved management and waste management options moving forward. These industry strategies need to identify and review all waste issues, not just controlled waste.

Non-commercially Viable Waste Streams

Many smaller volumes of specific controlled wastes that cannot feasibly be treated in Tasmania require a management plan to encourage waste reduction or avoidance, alternative treatment or application as well as options for ongoing management.


If this waste can no longer be transported interstate it may pose a threat to some Tasmanian businesses. The State Government needs to maintain open dialogue with other Australian States and Territories in order for interstate transport from Tasmania to remain possible as a management pathway.

The State Government needs to facilitate controlled waste audits to assist in

reducing the quantities of controlled waste generated, particularly for those small to medium-sized enterprises that generate controlled wastes for which a commercially viable solution is not readily available.

Innovation, Research and Development

Tasmania has some excellent examples in innovation and waste management practice – specifically in facilities, transport and resource recovery.

The waste industry in Australia is worth around $1.25 billion annually. There

is an opportunity to promote and grow that knowledge base to enhance the local industry. This may result in home-grown solutions and better partnerships with industry.

Regulation and Compliance

There is a need for State Government to improve communication and education with all stakeholders (including the public).

There is a need for consistent regulation which must be properly monitored

and enforced.

Regulation needs to keep pace with improvements in best practice standards and any advances in technology or practices.

There needs to be clear options for all waste types and situations through the

development and implementation of a ‘Controlled Waste Management Methods Guide’ to be used by DTAE and any regulatory bodies that will provide consistent and satisfactory information to all stakeholders.

Education

Development of a Controlled Waste Management Methods Guide options for controlled waste need to be made available to all generators (including the public).

Education and awareness of best practice requirements needs to be more

actively provided to all stakeholders (including the public).


Communications Strategy There is a compelling need for the State Government to communicate its

objectives clearly to local authorities, Tasmanian industry and other stakeholders (including interstate authorities) involved in controlled waste management. A cooperative partnership-based approach to achieving these objectives is essential.

There is an opportunity to use controlled waste to promote sustainability and

leadership in Tasmania.

Key Issues and Timeframes The following steps outline the implementation of the proposed Controlled Waste Management Strategy to meet the State Government’s objectives:

1. Commence program to attract investment in key development opportunities identified by the study.

Immediate and ongoing

2. Seek industry and key stakeholder feedback on the draft strategy and revise as appropriate.

February 2008 – April 2008

3. Develop and implement a communications strategy, to advise industry, key stakeholders and the public on the progress of the strategy.

April 2008, ongoing

4. Commence other key elements of the strategy (including development of industry specific strategies, controlled waste audit initiatives, awareness and education program, innovation and research initiatives, associated compliance and regulatory actions).

April 2008, ongoing

5. Undertake a formal program review. October 2008, April 2009

Review

This strategy should be reviewed and updated as conditions change on a biannual or annual basis.


3. INTRODUCTION

3.1 Purpose

Sustainable Infrastructure Australia (SIA) has been engaged by the Tasmanian Department of Economic Development (DED) to conduct a study on the current status and commercial viability of controlled waste management facilities and practices in Tasmania, as part of a state-wide controlled waste management strategy.

This study comes at a critical time as the performance requirements of the state Landfill Sustainability Guide will come into force on 30 June 2009, by which time all controlled waste facilities in Tasmania must satisfy best practice standards and provisions of the Guide in order to continue to accept and dispose of controlled waste. In addition to this, there may be signs that other Australian States and Territories will not continue to support Tasmania’s waste products being shipped to mainland facilities for processing and disposal, or at the very least that mainland regulatory authorities will require Tasmania to accept residues arising from interstate treatment. Sustainable management of controlled waste in Tasmania requires that adequate facilities are available to meet the foreseeable needs of Tasmanian industry. Tasmania currently does not have landfills or processing facilities that are fully compliant with modern best practice standards for ‘secure’ landfills. Lack of adequate facilities may result in significant costs to Tasmanian businesses and may impede economic expansion of the State’s industries.

In addition to considerable economic impacts, inadequate controlled waste management facilities and practices have the potential to result in significant harm to the environment and may also have adverse effects on human health. It is therefore essential to develop a strategy that meets the needs of Tasmania’s industry and a growing economy, whilst ensuring controlled waste generated in Tasmania is sustainably managed and the risks involved in its transport, storage, treatment and disposal are minimised. The development of the feasibility study and review follows on from the State Government’s policy announcement in 2004 to manage controlled waste in Tasmania, with the establishment of the ‘Controlling Waste’ Six Point Action Plan.


3.2 Objective The objective of this report is to provide: Advice to the Tasmanian Government, industry, industry associations and other

stakeholders (including the general public), regarding the facilities and operations required to meet the controlled waste management needs of Tasmania’s industries and business enterprises, currently and for the next 10-15 years, and to provide advice about the potential commercial viability of the specific facilities and operations;

Guidance on the most effective implementation models for potential commercially

viable facilities and operations;

Guidance on the most effective means of establishing the non-commercially viable facilities and operations required to meet the controlled waste management needs of Tasmanian industries and business enterprises;

An assessment of the likely cost implications for Tasmanian industries and

business enterprises as a result of the establishment of new and upgraded facilities, as well as a comparison with mainland facilities and operations;

Guidance on criteria for selecting suitable sites for establishing the facilities

required to service the controlled waste management needs of Tasmanian industries and business enterprises, including transport infrastructure requirements;

Guidance on the approval processes relevant to the establishment of any new or

upgraded facilities to meet the controlled waste management needs of Tasmanian industries and business enterprises; and

Guidance on any potential barriers to investment in new or upgraded facilities to

meet the controlled waste management needs of Tasmanian industries and business enterprises.

3.3 Scope and Methodology

Given the timelines and budget provided for this study, SIA has undertaken a targeted approach to develop this report. This has included the following approach: (i) Preliminary Investigation

A review of background information on controlled waste management in Tasmania, drawing from current Tasmanian legislation and reports, and relevant state and national documents. Regulatory issues in Tasmania were addressed, controlled


waste data including generation rates and stockpiles were aggregated from various sources, and issues relating to waste handling, tracking and fees were reviewed. A key objective of the preliminary investigation was to gain a better understanding of current controlled waste management infrastructure in Tasmania, including identification of the priority controlled wastes in the Tasmanian context, identification of the major treatment and disposal methods, and current practices and operations across the State. The preliminary investigation also included a review of other Australian States and Territories, including relevant reports, facilities, technologies, costs and practices. As some Antarctic wastes have historically been transported to Tasmania for disposal, information on the Australian Antarctic Territory was also reviewed, along with waste types transported to Tasmania with quarantine waste status, current practices for transport and disposal of Antarctic waste in Tasmania, and issues relating to the international ‘Madrid Protocol’.

(ii) Stakeholder Consultation

Industries and stakeholders that have an involvement in Tasmania’s controlled waste through generation, management, transport and disposal/treatment were consulted and invited to provide feedback for the study. This involved a mail-out of over 240 questionnaires to State and Local government, industry and industry associations, and other organisations. SIA also undertook around 30 face-to-face meetings, some including facility inspections. Industry and stakeholder advice and guidance is critical in understanding the current and future needs for controlled waste management in Tasmania, and the final report has benefited greatly from the guidance that has been provided. It is important to note that there was a strong sense of support and cooperation from industry in tackling this key issue, which has been valuable in undertaking the study.

(iii) Detailed Assessment

Controlled waste categories were divided into 14 sub groups. With the significant volume of data and information, including stakeholder feedback, SIA began the task of reviewing and assessing all the information. The most constructive way to approach this was to focus on the key waste subgroups, assess current and alternative practices as well as assess disposal, treatment and resource recovery options. A detailed and comprehensive controlled waste audit has not previously been undertaken in Tasmania. This has meant that estimations have been made based on existing data, SIA’s past experience with controlled waste, and information and feedback from generators, waste companies and all levels of Government.


(iv) Report Preparation

The business case and feasibility study has been prepared by drawing on the preliminary investigation, stakeholder consultation, workshop and detailed assessment. Due to the size and complexity of the issues involved, this report has been broken into key assessments of the 14 waste categories to assist in providing the business case assessment and recommendations.

It is important to note that this report was undertaken within a limited timeframe and budget and did not incorporate a comprehensive and detailed controlled waste audit. Assessment and review of data has been reliant on what information is currently available. During the stakeholder consultation phase, information was provided to SIA on a voluntary and confidential basis from industry, waste management companies and government. However, it is recommended that a detailed and comprehensive controlled waste audit would be of value in assisting in the ongoing sustainable management of controlled wastes in Tasmania.


4. CURRENT PRACTICES AND CONCERNS IN TASMANIA

4.1 Current and Future Regulatory Environment in Tasmania

Waste regulation and enforcement has played a major role in determining controlled waste practices and infrastructure in all States and Territories of Australia. During the course of this review, and specifically as a result of stakeholder consultation, it was clearly understood that problems and issues with regulation and enforcement of controlled waste are the most significant barrier to improving waste practices, standards and encouraging investment in existing or new infrastructure in Tasmania. Waste regulation, standards, practices and facilities have developed significantly in Tasmania over the past 15 years. There has been a significant transition and involvement of State Government and Local Government as Tasmania has progressively moved away from very rudimentary practices and facilities. This has resulted in:

Significant reduction and consolidation of landfills in the State from 99 landfills in 1994 to the current 17 landfill facilities. This has also resulted in a larger number of waste transfer stations (WTS) being developed and acting as satellite infrastructure to key facilities. In many cases due to efficiency, cost and liability issues, Local Government has closed landfills and contracted out waste disposal to regional or other facilities;

Pricing, which in some cases has increased significantly; Issues of non-reporting and inappropriate disposal practices, for example

illegal dumping; A change of culture and attitude towards waste management, risk and

liability, including an improved understanding of the ‘waste management hierarchy’;

Improvements in cleaner production, waste recycling/exchange and waste treatment;

Uncertainty, variability and arbitrary responses to infrastructure and waste management from Government having an impact on new infrastructure development and market-based solutions; and

Greater quantification, understanding and regulation of controlled waste leading to significant improvement in tracking, handling, management and disposal/treatment of controlled waste in Tasmania.

Landfills in Tasmania are primarily owned and managed by local councils. Historically these facilities were developed to meet the needs of Tasmania’s urban and rural communities, however, they were not necessarily designed to meet the needs of ‘industrial’ growth and development. This is an important consideration in developing a strategy to meet the future needs of Tasmania’s industries and growing economy,


and the need to encourage more commercial investment in controlled waste management facilities.

4.1.1 Controlled Waste Legislative Instruments

The following are key legislative instruments that have directly had an impact on controlled waste practices and infrastructure in Tasmania.

(i) Landfill Sustainability Guide 2004

The Landfill Sustainability Guide 2004 contains new best practice environmental management standards for Tasmanian landfills, and is an important tool in the assessment and regulation of current and future controlled waste management facilities in the State. Developed by the Department of Primary Industries, Water and the Environment (DPIWE), the Sustainability Guide provides a framework for minimising environmental impacts arising from the siting, design, operation, and rehabilitation of landfills. The Department of Tourism, Arts and the Environment (DTAE) is now the responsible regulatory authority. The main objectives, as listed in the Guide, are to:

Help developers establish and manage landfilling activities in compliance with

environmental legislation and policies; Promote consistency in the regulation of landfills in Tasmania; Clearly identify the issues that need to be managed and options for their

management; Inform industry and the community of acceptable standards for landfills; and Encourage high-level landfilling standards based on the most effective,

affordable and innovative mix of mechanisms available.

The Sustainability Guide applies to all landfills that are assessed by the Board of Environmental Management and Pollution Control, that is, those classed as Level 2 activities and regulated accordingly under the Environmental Management and Pollution Control Act 1994. However, it is advised that the principles should be applied to all landfills. Although it is not a legally binding document, the Guide provides a benchmark for assessing proposals for new sites or extensions of existing sites, and allows regulators to utilise the acceptable standards as a basis for drafting landfill permit conditions.

From the time of its release, existing Tasmanian landfills were granted up to five years to come into full compliance with the Landfill Sustainability Guide. Hence by June 2009, all controlled waste facilities in Tasmania must satisfy the acceptable standards and provisions of the Guide (or demonstrate reductions in environmental risk by other means) in order to continue to dispose of controlled waste. As a minimum, operators are expected to comply with standards in Sections 4 ‘Operation’ and Section 5 ‘Rehabilitation and After-Care’ within this timeframe. Section 2 ‘Landfill


Siting and Planning’ will generally not be applied to existing landfills, while Section 3 ‘Design’ will be applied to new cells at existing landfills and extensions of landfills.

The current situation in Tasmania has produced much uncertainty among controlled waste generators and facility operators. This is largely due to a lack of facilities able to receive and appropriately dispose of certain classes of controlled waste, inconsistent regulation of disposal practices, and changing sentiment from interstate facilities presently accepting controlled waste shipments from Tasmania. The need to implement best practice standards for Tasmanian landfills, and hence effectively regulate the Landfill Sustainability Guide, has been highlighted by numerous stakeholders who are concerned existing controlled waste facilities are inadequate. Significant investment in new infrastructure is unlikely to occur unless regulations are applied consistently to all facilities and are fully enforced. (ii) Land Use Planning and Approvals Act 1993

The Land Use Planning and Approvals Act 1993 (LUPAA) is the primary planning legislation in Tasmania, and a central part of the Resource Management and Planning System. The Act is supported by the State Policies and Projects Act 1993, the Resource Management and Planning Appeal Tribunal Act 2003 and the Resource Planning and Development Commission Act 1997. LUPAA provides for land use and development approvals across all levels of Government in Tasmania, and for permits issued by a planning authority (local council), within a planning scheme or special planning order. Some permits require standards such as resource recovery to be implemented within the proposed land use or development. The Act ensures the environmental impacts associated with a proposed development are addressed and incorporated into the planning process. Objectives of the planning process established by the Act are many and include:

to require sound strategic planning and co-ordinated action by State and Local Government;

to establish a system of planning instruments to be the principal way of setting objectives, policies and controls for the use, development and protection of land;

to ensure that the effects on the environment are considered and provide for explicit consideration of social and economic effects when decisions are made about the use and development of land;

to protect public infrastructure and other assets and enable the orderly provision and co-ordination of public utilities and other facilities for the benefit of the community; and

to provide a planning framework which fully considers land capability.


Waste transfer stations (WTS) are primarily regulated under LUPAA. They are specifically exempt from Schedule 2 of the Environmental Management and Pollution Control Act 1994 (EMPCA) and therefore do not undergo environmental assessment or ongoing environmental regulation by the State Government. This is gradually becoming an issue, as a large number of landfill closures in Tasmania has resulted in an increased volume of controlled waste handled at waste transfer stations. This trend is likely to continue, with the rationalisation of the State’s waste infrastructure and a greater emphasis on regional landfill facilities. A review of WTS legislation needs to be undertaken in order to provide for uniform site and operational requirements, and consistent regulation and compliance throughout the State. WTS infrastructure will also need to be addressed (see Section 4.6.2 of this report), with consideration of additional resources to be made available to WTS operators for the acceptable management, storage/containment and handling of increased volumes of controlled waste. Much of Tasmania’s WTS infrastructure may need to be upgraded in order to manage current and future waste volumes, with minimal harm to the environment or human health.

(iii) Environmental Management and Pollution Control Act 1994

The Environmental Management and Pollution Control Act 1994 (EMPCA) is the primary environment protection legislation in Tasmania, providing for the assessment, regulation and monitoring of environmental and pollution issues.

The objectives set out in Schedule 1 of EMPCA are many and include:

to protect and enhance the quality of the Tasmanian environment; to prevent environmental degradation and adverse risks to human and

ecosystem health by promoting such approaches as clean production technology, re-use and recycling of materials and wastes minimisation programs;

to regulate, reduce or eliminate the discharge of pollutants and hazardous substances to air, land or water consistent with maintaining environmental quality;

to allocate the costs of environmental protection and restoration equitably, with polluters bearing the appropriate share of the costs that arise from their activities;

to provide for the monitoring and reporting of environmental quality on a regular basis;

to control the generation, storage, collection, transportation, treatment and disposal of waste with a view to reducing, minimising and eliminating harm to the environment; and

to facilitate the adoption and implementation of standards agreed upon by the State under inter-governmental arrangements for greater uniformity in environmental regulation.


Controlled waste is defined in the Interpretation of EMPCA as being either: a) A material defined by the National Environment Protection Measure for the

Movement of Controlled Wastes between States and Territories made by the National Environment Protection Council on 26 June 1998, as amended; or

b) A substance that is prescribed by regulations made under EMPCA to be controlled waste.

As in (b), the Environmental Pollution and Control (Waste Management) Regulations 2000 consider the following factors in defining a controlled waste, provided the waste exhibits an environmentally significant characteristic:

‐ derived or arising from agricultural produce or veterinary chemical products within the meaning of the Agricultural and Veterinary Chemicals (Control of Use) Act 1995;

‐ a dangerous good within the meaning of the Dangerous Goods Act 1998; ‐ derived or arising from poisons within the meaning of the Poisons Act 1971; ‐ a waste within the meaning of the Quarantine Regulations 2000 of the

Commonwealth, as amended; or ‐ a scheduled waste within the meaning of a National Management Plan.

A full list of controlled wastes that are currently regulated in Tasmania for transport and disposal is attached in Appendix [2], and is discussed in more detail in Section 4.2 of this report.

There are three levels of activity under EMPCA, which are controlled by the use of permits. According to DTAE, they are:

Level 1 Activities - those that may cause environmental harm and require a permit from councils under LUPAA. Level 1 activities are generally smaller industrial-type activities and are assessed, approved and regulated by local government.

Level 2 Activities - those activities included in Schedule 2 of EMPCA. Level 2 activities are assessed, approved and regulated by DTAE, and most require an application for a permit under LUPAA. The storage, treatment and transport of controlled waste may constitute a Level 2 activity under EMPCA and be required to undergo an environmental assessment and planning and approvals process A "waste depot" is a level 2 activity under EMPCA, and is defined as:

“The conduct depots for the reception and storage of waste other than: i) temporary storage at the place at which the waste is produced while awaiting transport to another place, or ii) storage, treatment or disposal of domestic waste at residential premises; or iii) waste transfer stations - and which are designed to receive, or are likely to receive, 100 tonnes or more of waste per year”


The environmental impacts of level 2 waste depots must be assessed and regulated by DTAE. The regulatory authority for smaller landfills is the local council.

Certain controlled waste generators in Tasmania are also classed as Level 2 activities. These activities are generally larger industries, such as food processing and manufacturing, mining activities, or activities which have a greater potential to cause significant environmental harm. A large number of controlled waste generators, however, are not regulated under EMPCA and include construction or demolition sites, agricultural practices, hospitals and medical practices, restaurants, and domestic premises.

Level 3 Activities – those that have been declared "Projects of State Significance" under the State Policies and Projects Act 1993. Such activities are assessed by the Resource Planning and Development Commission.

(iv) Environmental Management and Pollution Control (Waste Management) Regulations 2000 The Environmental Management and Pollution Control (Waste Management) Regulations 2000 support EMPCA and provide for the appropriate management and disposal of controlled and general waste in Tasmania. Specific to controlled waste management, the Regulations detail general responsibilities relating to waste production, storage, treatment and disposal as well as prohibited activities at waste management facilities. Under Regulation 12 of the Waste Management Regulations, all treatment and disposal of controlled waste requires approval from the Director of Environmental Management, unless the landfill is already approved for controlled waste in their permit or an Environment Protection Notice (EPN). Approval for the storage of controlled waste under Regulation 6 is required if the facility or site where the waste is to be stored is not already a permitted facility. An environmental approval may also be required for the handling, production, receipt, re-use, recycling, reprocessing, salvage, or use for energy recovery of specified controlled wastes or classes of waste. The Regulations also provide for the establishment of Approved Management Methods (AMM). They are:

‐ The Approved Management Method for Clinical and Related Waste (DPIWE,

2005) specifies minimum standards for management of wastes from healthcare facilities and other clinical settings, including segregation, safe packaging and labelling, storage, transport and disposal of wastes. A revised 2007 Companion Document is currently being drafted by DTAE.

‐ The Approved Management Method for Biosolids Re-use (DTAE, 2006) provides the minimum legal requirements for the classification and re-use of


biosolids in Tasmania. More detailed information is provided within the Tasmanian Biosolids Re-use Guidelines 1999.

(v) Draft Environmental Management and Pollution Control (Controlled Waste Tracking) Regulations 2007

For environmental and public health reasons, it is important to monitor the movement of controlled waste from the point of generation, to the final location at an approved treatment, resource recovery or disposal facility. Tracking controlled waste in Tasmania involves specifying the category, physical nature and quantity of waste, how the movements of waste are tracked, and the information collected for each load.

The Tasmanian Government first announced the introduction of a controlled waste tracking system in Tasmania as part of the Controlling Waste Action Plan released in September 2004. Waste transport businesses are currently listed as a Level 2 activity under Schedule 2 of EMPCA, requiring controlled waste transporters to hold an Environment Protection Notice (EPN) and submit quarterly returns. The regulations for controlled waste tracking in Tasmania, the Environmental Management and Pollution Control (Controlled Waste Tracking) Regulations 2007, are in the final stages of development and are to include new requirements for controlled waste transport businesses. A proposed modification will see controlled waste transport businesses no longer having to go through a separate approval process or pay the associated fees. The requirement for EPNs will be replaced by all controlled waste transporters being required to be registered under the Controlled Waste Tracking Regulations. The requirement for quarterly returns from transporters will also be removed. Controlled Waste Tracking Certificates (CWTC) can be created for registered controlled waste handlers, including transporters, to track the movement of each load of controlled waste.

Objectives of the new Regulations, as specified by DTAE, include:

to ensure that controlled wastes are transported safely to an approved facility; to monitor and track controlled waste to prevent unauthorised discharge into

the environment; to collate information to assist Government in identifying priority waste

management issues in Tasmania; and to provide an even and competitive system for businesses that handle

controlled waste in Tasmania.

A draft copy of the Controlled Waste Tracking Regulations was made available for comment in early 2007, and stakeholder feedback was reported on by DTAE - the responsible agency for compliance and enforcement of the Regulations.

The Internet-based tracking system will supplement the new paper-based tracking process. The online facility, maintained by DTAE, entered its trial stage in September


2007 and will go live as soon as possible after completion of the testing phase. The Controlled Waste Tracking Regulations will not be gazetted until the online tracking system is fully functional. Since it is currently under development, this is expected to be towards the middle of 2008.

(vi) National Environment Protection (Movement of Controlled Waste between States and Territories) Measure 2004

The National Environment Protection (Movement of Controlled Waste between States and Territories) Measure 2004, or Interstate Waste Movement NEPM, provides a national framework for developing and integrating State and Territory systems for the management of the movement of controlled waste across Australian jurisdictional boundaries. Such management systems include:

Waste tracking systems to provide information to assist agencies and emergency services, and to monitor the movement of controlled wastes to ensure that they are directed to and arrive at appropriate treatment or disposal facilities;

Prior notification systems to provide Australian States and Territories with access to information and to assess the appropriateness of proposed movements of controlled waste in terms of transportation and facility selection; and

The licensing of transporters and regulation of generators and facilities so that waste tracking and notification functions are compatible with State and Territory requirements.

The primary objective of this Measure is to assist in minimising the potential for adverse impacts associated with the movement of controlled waste on the environment and human health. It aims to achieve this by providing a basis for ensuring that controlled wastes which are to be moved between States and Territories are properly identified, transported, and handled in ways which are consistent with environmentally sound practices for the management of these wastes.

List 1 of Schedule A in the Interstate Waste Movement NEPM identifies all waste streams or constituents of wastes for the purpose of the definition of ‘controlled waste’ in clause 3 of the Measure. List 2 identifies characteristics of controlled wastes according to the Transport of Dangerous Goods hazard classification system. List 1 and 2 are referred to within interstate legislative frameworks (as is the case in Tasmania), and are included in Appendix [1]. Schedule B in the Measure identifies the information to accompany the movement of controlled wastes and for reporting purposes.

The key legislative instruments for implementation of the Interstate Waste Movement NEPM in Tasmania are the State Policies and Projects Act 1993 and the Environmental Management and Pollution Control Act 1994. The Department of Tourism, Arts and the Environment is the responsible administrative agency. The new


Controlled Waste Tracking Regulations for Tasmania, when fully in force, will strengthen the regulatory framework for the NEPM. According to the Report to the National Environment Protection Council on the Implementation of the NEPM (Movement of Controlled Waste between States and Territories) for the reporting year ending 30 June 2006, compliance with the NEPM requirements by waste producers, transporters and receiving facilities has been very good in Tasmania. There were no discrepancies over the reporting period, reflecting a high level of awareness and compliance by Tasmanian industry. Tasmania regularly consults with other jurisdictions on NEPM matters such as issuing consignment authorisations and appropriateness of treatment/disposal facilities. Tasmania also takes part in the Implementation Working Group, a forum established to resolve issues raised by industry, waste transport companies and other agencies. Discussed in more depth in Sections 4.5 and 4.7, the Interstate Waste Movement NEPM has been reported to have been, on occasion, misused by jurisdictions to block incoming waste and hence restrict free trade between States and Territories. There therefore needs to be a continued and strengthened effort by the State Government to maintain dialogue with other jurisdictions, with a view to securing future interstate management opportunities for waste types unable to be disposed of or processed at Tasmanian facilities.

Perhaps the implementation of a national strategy could be considered by the Commonwealth, to facilitate smarter use of controlled waste management facilities. Based on the economies of scale principle, the strategy could be an important tool for encouraging new transboundary management opportunities. It would also ensure that appropriate treatment and re-use/recovery methods are applied to controlled wastes, helping to reduce the amount of waste disposed of to landfill and promote the sustainable use of resources.

(vii) Classification and Management of Contaminated Soil for Disposal, August 2006 (Bulletin 105) Information bulletin 105 defines criteria used by DTAE Environment Division for the classification of contaminated soil that requires treatment and/or off-site disposal, and outlines the management of each classification in accordance with the Environmental Management and Pollution Control (Waste Management) Regulations 2000. The bulletin is designed for use by those parties responsible for determining whether potentially contaminated soil is suitable to be disposed of at a landfill, and in assessing alternative management options. Bulletin 105 contains information and guidelines on the classification of contaminated soil; sampling and analysis of potentially contaminated soil; the development of a waste management plan for re-use or disposal; landfill disposal of contaminated


material; the approval process for soil disposal, re-use or remediation; and transport of contaminated material. The Environment Division uses four categories to classify contaminated soil: (Level1) Fill Material; (Level 2) Low Level Contaminated Soil; (Level 3) Contaminated Soil; (Level 4) Contaminated Soil for Remediation. Most controlled waste generated in Tasmania needs to be analysed to determine compliance with these levels specified in the Bulletin, prior to determining an appropriate re-use, recycling, treatment or disposal approach for that waste.

4.1.2 Key Issues with the Current Regulatory Environment

As a part of the initial investigation, stakeholder consultation and workshop process, clear and comprehensive feedback and review of the current regulatory environment was assessed. This resulted in a number of primary issues that surfaced consistently with State and Local Government, waste generators as well as waste management companies, facility operators, transporters and other associated organisations.

(i) Conflicting role of DTAE

One of the clear frustrations with all stakeholders including State and Local Government, has been the dual role DTAE has traditionally and currently plays as both regulator (responsible for compliance and enforcement of waste regulation) and facilitator (responsible for identification and implementation of waste solutions). Having no clear separation of these roles has caused significant problems for officers who have the challenge of addressing non-compliance and enforcement, while at the same time developing cooperative relationships with controlled waste generators, facility operators and waste handlers. SIA has observed throughout Tasmania:

Sentiment ranging from dissatisfaction to hostility towards the regulating body;

A lack of intent to provide accurate or meaningful data or information from generators, handlers or facilities to DTAE as this may create future compliance costs or management issues;

Conflicting roles of officers preventing them from being able to pursue proactive improvements or initiatives;

Inconsistency in enforcement of regulations due to this dual role; and Significant problems with future planning and solutions from current facility

operators, especially landfill operators. (ii) Lack of enforcement

One of the common themes received from all stakeholders was that although the State Government had invested significant resources in new regulation and


standards, (in many cases adopting best practice standards from other states) the effectiveness of this is significantly reduced as there is poor compliance policing in Tasmania. This has resulted from both a lack of officers out in the field observing controlled waste practices or facility management and also a lack of intent to penalise or fine parties known or found to be breaking current requirements. This was a consistent theme from stakeholders and resulted in the following:

A lack of interest or intent to comply with current regulations; A lack of interest or intent to invest in new or improved practices or

controlled waste facilities; Significant investment risk with establishing controlled waste infrastructure

in Tasmania; and Reducing the standards of practice to compete economically with other

waste handlers, transporters and facilities who were not complying with current standards and in many cases undercutting those who were.

(iii) Communication, education and awareness

There is a lack of general knowledge in Tasmania, particularly among the general public, in identifying the waste types and characteristics that comprise controlled waste, recognising potential environmental and human health risks involved in generation, handling and disposal, and understanding the ‘cradle to grave’ responsibility of the generator for managing controlled waste until it reaches its final disposal point. There is also a lack of information and awareness in Tasmania among waste generators (including the public) and handlers, as to what is required or appropriate standards and options for controlled waste handling, disposal or treatment. This has been a contentious issue for DTAE for two reasons. Firstly it has been difficult for DTAE to direct parties to appropriate facilities as there are often limited or no facilities that meet required best practice standards. Secondly there have been few resources allocated to managing the process of providing information to industry, stakeholders or the public from DTAE or other parties.

The lack of communication, education and awareness has resulted in the following outcomes:

Generators of controlled waste not being aware of options for disposal, treatment or sustainable alternative use of controlled waste such as re-use by other industries;

Combined with a lack of enforcement, generators and waste handlers using ignorance as a default for not complying with current required practices for handling and disposal;


Generators not being aware of those handlers or facilities that comply with current requirements or best practice; and

Parties not being aware of current standards or best practice in relation to controlled waste.

In 2001, DPIWE established the Tasmanian Waste Exchange (TWEX), which was an ambitious initiative to enhance communication between industries and minimise controlled waste volumes through resource recovery, recycling and re-use. Stakeholder comments included a general view that the system was not properly funded and, although with some limited initial success, it has not been given the opportunity to succeed. In Victoria a similar system was established which has been highly successful, utilising an electronic exchange system requiring minimal resources.

(iv) Resources

Most of the issues outlined above are primarily a result of the lack of resources dedicated to waste and specifically controlled waste management in Tasmania. Currently there is not one full-time officer dedicated to controlled waste in Tasmania in DTAE and many local councils, who are responsible for most facilities in the State, are also funded with limited resources. Without realistic resource allocation Tasmania will continue to struggle to meet basic standards in controlled waste management practices and infrastructure and will fall short of meeting current legislative requirements as well as future changes, such as the June 2009 requirements. The lack of resources dedicated to waste and in particular controlled waste will see the continuation of:

Conflicting roles of officers attempting to provide regulation and facilitation; A lack of enforcement of regulation; Inconsistency in regulation enforcement; Lack of education and awareness for all parties involved; and High risk, low incentive to invest in future waste management infrastructure.

(v) Inconsistency in regulation / enforcement – no level playing field

Due to a lack of investment in new infrastructure and issues with the enforcement of regulation, there have been very different approaches taken to specific controlled waste management facilities and waste generators, which has created confusion and distrust among many stakeholders.

Stakeholders consulted for this study reported a significant lack of consistency with enforcement of regulation across the State. If rules are not applied and enforced consistently, major problems can arise in encouraging compliance with the regulations.


This has resulted in:

Confusion and avoidance (short cuts); Lack of controls, pro-active inspections and fines; Default position often taken of the lowest standard to avoid costs; and Significant deterrent to new investment in new waste infrastructure or

improved practices. There is a strong view from most stakeholders that the specified 30 June 2009 deadline in the Landfill Sustainability Guide will result in little or no change to practices or infrastructure in Tasmania.

4.1.3 Future Regulation

(i) Future requirements

The requirement of all landfills (which currently take most of Tasmania’s controlled waste) meeting best practice standards set out in the Landfill Sustainability Guide 2004 or equivalent by June 2009 is likely to have a major impact on controlled waste management, including compliance and enforcement in Tasmania. Changing requirements set by interstate regulatory authorities or the Commonwealth Government may also carry implications for Tasmania in the future. Considerations for the effective regulation of Tasmania’s controlled waste in the future include:

More dedicated resources for compliance and enforcement; Development and implementation of a ‘Controlled Waste Management

Methods Guide’ to provide consistent and high level advice on allowable practices, transport, handling and treatment/disposal options to controlled waste generators, waste companies, facility operators and other stakeholders;

An understanding of how to firmly and consistently regulate and enforce best practice standards within the Landfill Sustainability Guide in order to achieve improvements in compliance for landfill siting, design, operation and rehabilitation, and to ensure potential harm to the environment and human health is minimised. Significant investment in new infrastructure is unlikely to occur unless regulations are applied consistently to all facilities and are fully enforced;

An understanding of how to encourage best practice and compliance among generators, transporters, facility operators and other controlled waste handlers;

Improvements in education among generators, transporters, local councils, facility managers, and the general public – including awareness of the term ‘controlled waste’ being synonymous with the term ‘hazardous waste’ (thereby emphasising the potential risks involved in its handling and management), and awareness of avoidance, re-use and recycling options;


Cooperation between Tasmanian State Government departments, for example DTAE and Workplace Standards, in improving compliance for the storage and transport of those controlled wastes listed as Dangerous Goods or workplace hazardous substances. Support and information for generators, transporters and handlers dealing with these waste types is also required;

Cooperation and reform of the legislative structure with State and Local Government to ensure consistency across the Environmental Management and Pollution Control Act 1994 and Land Use Planning and Approvals Act 1993 for waste transfer sites and to promote better infrastructure planning and controlled waste management;

Additions to the Environment Division’s website, including a functional user-friendly system with appropriate information on controlled waste requirements, options for management, treatment and disposal, and consideration of a revitalised waste exchange program in a web format; and

The implementation by DTAE of bans and restrictions on landfill permits to receive resources (including controlled wastes) which are known to have alternative management options i.e. recycling, re-use or recovery. Bans on receiving certain controlled wastes or non-hazardous materials such as waste tyres will then drive such resources towards more sustainable solutions.

(ii) Retaining the current position

A clear finding of this study is that if the current position in relation to legislative controls and enforcement does not change then this will act as a significant investment barrier to new or existing operators developing waste infrastructure to service Tasmania’s requirements. The levels of regulatory risk involved in such developments can be significant, especially when dealing with controlled waste. Not having clear or effectively enforced regulation will be a primary deterrent to new investment.


Interstate Practices An advanced identification system has been developed by Victoria’s Environment Protection Authority (EPA), designed to provide useful information on hazardous (or ‘prescribed industrial’) waste management services, encourage appropriate handling and disposal practices and hence seek to improve compliance and regulation. The Prescribed Industrial Waste Database on the EPA website (http://www.epa.vic.gov.au/waste/) assists users in locating prescribed waste treatment providers, disposers and permitted transporters operating in the State. The database allows the user to select a waste category and specific waste type(s), specify whether to limit the search results to waste treaters/disposers and/or waste transporters, and to narrow the search by specifying a postcode range. It then lists the service provider(s) and provides further details for each, including phone number and address, EPA licence number, waste types treated, disposed of or handled, and the treatment methods that the site/operation is licensed to use. The stakeholder consultation stage of this project has revealed the need for comprehensive information to be issued to waste generators, handlers, local councils and the community in relation to facilities and services for the appropriate disposal of controlled waste. Victoria’s EPA web tool is an effective way of encouraging best practice waste disposal methods, and supplying hazardous waste generators with information and details of facilities and accepted waste types.

4.2 Classification of Controlled Waste As discussed in Section 4.1.1 (iii) and (vi), Tasmania’s definition of controlled waste in EMPCA is derived from Lists 1 and 2 of the Interstate Waste Movement NEPM (Appendix [1]). The Environment Division of DTAE has listed wastes from the NEPM that apply to Tasmania. Descriptions of these wastes and their classification codes are listed in Appendix [2]. Previous reports and studies on controlled waste management have devised systems for grouping together wastes of a similar chemical or physical nature. Appendix [3] displays the format for grouping wastes into broad categories, according to their specific waste classification codes (as in DTAE’s Controlled Waste Inventory 2004-05). SIA has grouped controlled wastes in a similar fashion, however a number of waste categories have been combined where there are common handling, treatment and disposal methods. This approach aids in the analysis of treatment technologies for each waste category discussed in more depth in Section 5, and in the assessment of


options for viable treatment technologies in Section 7. Appendix [4] displays the list of waste categories and associated waste types as used by SIA. Characteristics of controlled wastes shown in List 2 of the Interstate Waste Movement NEPM (according to the Transport of Dangerous Goods classification system) provide a comprehensive system of classifying hazardous or potentially hazardous waste and indicating the risks involved in transporting, storing and otherwise handling such materials.

4.3 Present Controlled Waste Quantities

4.3.1 Data Sources Data relating to the generation, transport and tracking, storage, treatment and disposal of controlled waste has been aggregated by SIA and assessed in Sections 4 and 5 of this report. This material has been obtained primarily from the following sources:

[1] Department of Tourism, Arts and the Environment internal reports. [2] Quarterly reports to DPIWE/DTAE by commercial waste transport businesses

(WTBs) summarising controlled wastes transported in Tasmania between the first quarter of 1998 and the second quarter of 2007.

[3] National Environment Protection Council (NEPC) Report on the Implementation of the Movement of Controlled Waste between States and Territories NEPM: Annual reports for the 2001/02, 2002/03, 2003/04, 2004/05 and 2005/06 financial years.

[4] Controlled Waste Inventory: Controlled Waste Generation and Management in Tasmania, 2004-2005, undertaken by what was then DPIWE and reported on by DTAE.

[5] Quantitative and anecdotal information yielded by industry stakeholders and waste management operators (collected by DPIWE/DTAE).

[6] Questionnaire feedback and face-to-face stakeholder meetings, as part of the consultation process undertaken by SIA in 2007.

4.3.2 Evaluation of Data

In reviewing each waste type as detailed in Section 5, it is necessary to look at those factors which may affect the validity of the data and information. Some of these factors considered are listed below:

(i) Incomplete controlled waste records

SIA has aggregated data from a number of sources, however a waste audit has not been undertaken as it was outside the scope of this report. In the process of analysing historical controlled waste records, significant inconsistencies have been found. Controlled waste quantities reported each year vary significantly, possibly due


to the number of quarterly returns completed and submitted by WTB’s each year. There is also an incomplete record of waste generation in Tasmania, for example, there are significant gaps in WTB quarterly reports for 2000 and the second half of 2002.

(ii) Issues with reporting methods

From a copy of a specific WTB quarterly returns for 2006, it appears that the returns may account twice for some of the waste – once as it is transported from the waste generator and again when it is received at the landfill. This issue of double handling has been queried with DTAE in the past, but has not been satisfactorily resolved.

(iii) Inconsistency with units of measurement

There is an issue relating to units of measurement used in the reporting process for controlled waste transport and handling in Tasmania. For example, some waste generators are only able to provide an estimate of wastes in cubic metres, whereas during transport, capacity (litres) is often the charge rate. When landfilled, wastes are generally weighed in and out by mass (kilograms or tonnes). The use of different units of measurement is allowable, including in the proposed Controlled Waste Tracking Regulations where it states quantities in kilograms or litres may be given on waste transport certificates. However, care must be taken in noting where changes in units have occurred and in reconciling waste quantities so as not to skew the data collected. In some cases, units for reporting are specified as “tonnes / cubic metres”, meaning there is an assumed density ratio of 1:1 (one tonne is reported equally to one cubic metre). Problems arise where the bulk density of a waste is higher or lower than 1 tonne per cubic metre. It has been found that the numbers seem more likely when the measure is accepted as cubic metres (or kilolitres) and an estimated bulk density is applied, in order to arrive at tonnage figures, as used in this report. For example, liquid weights have been estimated on 1 tonne/m3, clinical waste on 120 kg/m3 and pharmaceutical waste estimated on 650 kg/m3. This method will, however, overestimate the weight of waste oil - which could vary anywhere from 780 to 960 kg/m3, depending upon oil grade.

4.3.3 Present Quantities

Data relating to the historical generation of controlled waste in Tasmania is shown in Appendix [5]. For each waste type, where possible, an annual generation value has been arrived at using historical controlled waste records and other estimation methods. SIA has accounted for inconsistencies and issues relating to controlled waste data measurement and reporting, by using cubic metres (or kilolitres) and applying an estimated bulk density (kg/m3) based on the properties of each waste. This gives a value in tonnes per annum (TPA).


Figure 1 illustrates SIA’s annual generation estimates for the six major controlled waste categories in Tasmania.

Figure 1

05,000

10,00015,00020,00025,00030,00035,00040,00045,00050,00055,00060,00065,000

Gen

erat

ion

(TPA

)

Waste category

Primary Controlled Waste Generation in Tasmania

4.4 Historical Stockpiles

The practice of stockpiling controlled waste is known to occur across most industries and waste management facilities in Tasmania (and Australia), for a number of reasons. Some stockpiled materials are pre-existing, that is, they are a legacy of past practice or previous land use. Such materials may include redundant plant equipment or contaminated soil. Other stockpiles are only temporary measures adopted by the waste generator, for example material awaiting transport or treatment. In all cases, without appropriate containment, security and safety precautions, controlled waste stockpiles are a potential threat to the environment and human health. The leaching of contaminants into soil or waterways is of particular concern. Reasons for the stockpiling of controlled wastes generated in Tasmania include (but are not limited to):

The waste generator is awaiting volume worth sending away for treatment or disposal;


The waste generator is awaiting funds to build an on-site treatment, recovery or recycle facility;

The present cost of transport and disposal is significant, therefore the waste generator is awaiting a cheaper solution in time, a commitment of funds, or an improvement in profitability; and

The waste generator or waste management facility recognises the potential value of the waste when a recovery process comes available.

There are a number of issues to consider with respect to controlled waste stockpiles and the primary ones are listed below. Some of these are important inputs when it comes to analysing the financial viability of any future investment in treatment technology. This is because using these stockpiles as a feedstock source may make a treatment plant viable where it would not otherwise be if the stockpile was unavailable. It is therefore important to be able to identify, quantify and analyse the stockpiles. However, it is not a given that all of these stockpiles can be accessed or are available for treatment in new facilities. Also listed below are points which refer to the responsibility of waste generators and their potential contingent liability in the treatment or storage of stockpiles.

Lack of confidence in the end result

Unreported on-site storage of controlled waste makes it difficult to accurately determine the quantities of waste material in Tasmania destined for treatment or disposal. This gives rise to uncertainty in the scale and nature of a treatment facility. Stockpiled waste volumes to be treated or used as feedstock may, on the other hand, be known and therefore accounted for in the planning of a controlled waste management facility. However, there are risks involved in designing and constructing a facility to treat or dispose of the stockpiled waste, in the event that (for whatever reason) this waste is no longer available for processing. This becomes more important if the stockpiled waste forms a large part of the total waste stream. The issue of security of supply is discussed in more detail in Sections 7 and 8 of this report.

Uncertainty or lack of understanding with regard to legislation and controls Consideration of a particular waste type for use as feedstock in an industrial process or facility requires awareness of precise operating parameters and environmental controls. For example, if a waste material is to be used as an alternative fuel source in a kiln, there must be knowledge of such factors as combustion and destruction efficiency, time at temperature, and what emission controls are in use. Operators will not accept another party’s stockpiled waste material unless they have a complete understanding of these requirements. On the other hand, waste generators have a responsibility to protect the environment from untoward effects arising from the disposal of their waste.


Off-site versus on-site responsibility If a controlled waste is stockpiled on-site, then it is the sole responsibility of the waste generator. If the waste is disposed of or ‘stored’ off-site, for example at an approved controlled waste landfill, it remains the responsibility of the waste generator but may not any longer be in his control. It is still a potential liability in so far as it could cause significant harm to the environment or human health. Often a controlled waste generator is required to hold a license to store a specified quantity of waste on-site, or may have to undertake an insurance risk assessment to ensure the stockpiled waste is not an environmental or health and safety risk.

Cradle-to-grave responsibility

The waste generator becomes the ‘owner’ of any products of the disposal or destruction process, for example ash or residues from a destruction process, and is responsible for transport and disposal costs. This is applied equally to ‘live’ waste and to stockpiled waste once it is moved off-site.

Since there is a lack of stringent requirements evident for reporting the type and quantity of waste stored on-site, the extent of controlled waste stockpiles in Tasmania is largely unknown. An opportunity exists to undertake a state-wide stockpile audit involving key industrials and waste management facilities that generate and store significant quantities of controlled waste materials (or have historical stockpiles). However, there may be an issue of commercial confidentiality, given that each generator is responsible for waste produced and stored on-site. An appropriate method to collect and store the data, and to whom the information is provided would also need to be considered.

Improved understanding of controlled waste stockpiles in the State could also be achieved by amending all existing permits to require waste producers to report on their stored wastes. Stockpiled wastes could be subject to a reporting procedure including such features as a land survey, a survey of containment or container integrity, photographic records, quantities and compositions. It might also include details with respect to reactivities to storage conditions such as fire hazard, ageing, oxidation, leaching, dusting and toxicity. By way of an environmental improvement process, it could also be subjected to periodic review of technologies and opportunities for recycle, re-use and disposal.

4.5 Future Generation Forecast

In order to invest in and develop controlled waste management facilities that meet the foreseeable needs of Tasmania’s industry and growing economy, future waste volumes generated in the State need to be considered. Security of waste supply is a critical component in assessing the viability of a waste stream and its associated treatment and disposal technologies. Although it is difficult to accurately predict the climate for controlled waste generation in Tasmania over the next 20 years


(particularly based upon limited data and information), there are a number of factors that are influential in understanding future management requirements.

Projections should consider the following elements of change in Tasmania, as illustrated in Figure 2:

The arrival of new industry in Tasmania, for example pulp and paper mills

and agriculture; Increased capacity and increased output of controlled waste, whilst retaining

existing efficiencies; Refusal by interstate authorities or processors to continue to accept

Tasmanian controlled waste for treatment and disposal; A declining and aging Tasmanian population, and impact on the health

system; The closure of aging and ‘power-hungry’ industries in Tasmania; The power scene shifting from green to brown in Tasmania, and an increase

in power prices; and Improvements in industrial efficiencies and growing awareness of the waste

management hierarchy (waste avoidance and reduction preferred over treatment and disposal).

Figure 2 Weighing up contributing factors for future controlled waste generation in Tasmania

SIA’s estimates for the future generation of controlled waste in Tasmania by waste category are shown in Table 1, based on information available and the factors listed above. It should be noted that comments included are only general, and any forecast for future generation (estimated increase, decrease or remain steady) has been made based upon limited data.

Arrival of new industry

Ageing population

Increased capacity whilst maintaining existing efficiencies

Decrease in interstate transport

Declining and ageing (working) population

Industry closures (ageing facilities)

Increasing power prices

Improving industrial efficiency


Table 1 Future Generation Forecast for controlled wastes in Tasmania

Waste Category Generation Forecast Comments

Cyanides Decrease

‐ Very small quantities generated across mining, electroplating and manufacturing operations

Acid solids and solutions Alkaline solids and solutions Laboratory/photography chemicals

Steady Decrease Steady

‐ Acid and base waste generation expected to be steady

‐ Photographic processing materials likely to decrease slightly with technological shift to digital photography

‐ Use of laboratory chemicals expected to remain constant

Inorganic chemicals

Steady

‐ Zinc compounds produced mostly by one generator, who is expected to stay in the industry for ~10-20 years

‐ Wastes from nickel, cadmium, lithium, zinc and other dry cell batteries may plateau as mobile phone usage reaches saturation point. Action to recover all batteries held in storage may result in a short-term peak

Reactive chemicals

Steady ‐ Very small quantities used and little waste generated

Paints, lacquers, varnish, resins, inks, dyes, pigments, adhesives Pesticides

Slight increase in the short-term

‐ Household Hazardous Waste program (Section 5.5.2) may encourage acceptable practice associated with the disposal of paints, pesticide residues, varnish etc and result in increased volumes managed as controlled rather than general waste

‐ Public education on paint residues handling should eliminate this liquid waste

‐ Chemclear program (Section 5.5.4) will clear the backlog

Organic solvents, organic residues

Increase by ~25%

‐ Organic solvents excluding halogenated solvents generated mainly by two sources, but a third is about to begin. One primary generator for halogenated organic solvent waste is expected to continue production. Overall increase


Increase in short-term by ~30%

‐ Considerable resource, from a large and diffuse generating base – expected to increase as collection and controls improve (principally from workshops and service stations)

Putrescible/organic wastes


‐ Very large generation from a broad range of sources, estimated to increase as controls tighten

‐ The aquaculture industry (and therefore fish processing waste) is particularly set to increase

Organic chemicals

Decrease by ~50% over next 10 years

‐ Low quantities from a handful of generators, mostly M100 PCB-related material (capacitors, oil, solvent, transformers) sent interstate – estimated decrease over time as large owners dispose of their inventory

‐ Large to very large quantities of material


Waste Category Generation Forecast Comments

Solid/sludge wastes requiring special handling


generated by a variety of sources and expected to increase only as controls tighten and production levels increase

Clinical and pharmaceutical wastes

Steady increase by ~5% per annum

‐ Aging population may contribute to a growing demand for healthcare services and hence an increase in the generation of clinical and pharmaceutical wastes

Tyres

Increase by ~25% pa over next 10 years

‐ Recovery of stockpiled waste tyres will boost future volumes, estimated quantities may be 3 times that declared

Security materials

Constant ‐ Typically 5% of the size of the clinical waste stream

Quarantine wastes

Increase by ~30% over 5 years

‐ More cruise shipping, seaports and airport improvements, and possible repatriation of Antarctic waste

There is considerable uncertainty as to whether or not interstate authorities will continue to accept Tasmania’s controlled waste for treatment and disposal at mainland facilities in the future. There have been mixed reports from stakeholders on this issue. Some perceive mainland facilities as being less accommodating, and others, including a number of Tasmanian waste transporters, have in fact experienced improved cooperation from particular jurisdictions in recent years. Action by the Tasmanian State Government to maintain open dialogue with neighbouring States and Territories is required, in order to preserve trade agreements for the transboundary movement of controlled wastes (under the Interstate Waste Movement NEPM), and secure future management opportunities at interstate facilities. However if, for whatever reason, interstate transport can no longer be relied upon by Tasmania as a management option, greater waste volumes and diversity of waste types will require appropriate treatment and disposal at Tasmanian facilities.

Interstate transport is therefore an influential factor in assessing future controlled waste volumes and the viability of certain waste streams and technologies. It is discussed in more depth in Section 4.7.

4.6 Current Facilities, Capacity and Practices

4.6.1 CONTROLLED WASTE LANDFILLS

Three categories of landfill are established in the Landfill Sustainability Guide, which classify Tasmanian landfills according to the waste types they are permitted to accept. These categories are:

Category A: Solid Inert Landfill Category B: Putrescible Landfill Category C: Secure Landfill


Table 2 is adapted from the Landfill Sustainability Guide 2004. Those waste types permitted are indicated with a tick, and those not accepted for landfill disposal with a cross. A question mark signifies the waste may be permitted but is subject to approval by the Regulatory Authority for the type of waste, and analytical testing may be required. Table 2 Landfill Classification System (Landfill Sustainability Guide, DPIWE 2004)

Waste type Landfill Category

A (Solid Inert)

B (Putrescible)

C (Secure)

Solid inert material (includes clean fill)

Potentially contaminated material

Fill material Low level contaminated soil ? Contaminated soil Contaminated soil for remediation

Putrescible waste

Controlled waste ?

Four regional landfill facilities are currently licensed and approved to accept controlled waste in Tasmania. They are Remount Road Waste Depot and Dulverton Regional Waste Depot in the north, Port Latta Landfill in the northwest and Copping Refuse Disposal Site in the south of the State. Dulverton and Port Latta are classed as Category C or ‘Secure’ Landfills, and Remount Road and Copping are Category B Landfills. These four regional landfill facilities each have basic design and operational features, including leachate drainage and containment, adequate cover material, security measures, maintenance, and recycling facilities. There is, however, a need for all existing landfill facilities to be upgraded so that they are fully compliant with best practice standards for ‘secure’ landfills, as detailed in the Landfill Sustainability Guide. Investment in controlled waste treatment, processing and recovery facilities is also a necessity, in order to treat waste streams that cannot be disposed of to landfill, and reduce volumes of those waste streams which can.

The four major landfills are reviewed in brief below, including consideration of the type of license held, and controlled wastes accepted. There are also smaller landfill facilities that receive limited controlled waste types, subject to approval, as well as privately operated industrial landfills. These are also discussed below.


(i) Remount Road Waste Depot, Launceston City Council The Remount Road Waste Depot is a regional facility located in Launceston in the State’s north. The site is operated by Launceston City Council and is licensed to receive 150,000 tonnes of waste per annum. All council deliveries are weighed at the entrance to the landfill, however there are considerable quantities arriving in private vehicles. The controlled waste component is not weighed separately. Landfill receives approximately 50% domestic waste, the other half consisting of commercial and industrial waste and construction and demolition waste. The Remount Road Landfill is licensed to accept Level 2 wastes (Category B), including:

‐ Asbestos ‐ Abattoir waste - animal effluent and residues (offal) ‐ Quarantine waste from sea ports ‐ Security disposal for commercial and industrial food wastes (out-of-code) ‐ Industrial wastes such as oily rags and spill absorbents ‐ Clinical waste (only sharps in approved containers are accepted) ‐ Waste tyres which have been ‘stripped’ i.e. cut into quarters at least (most of

Tasmania’s tyres, not including large mining vehicle tyres)

Other controlled wastes identified as being accepted in minor quantities include: organic solvents; inks, dyes pigments, paints, varnish, lacquers; domestic controlled waste; resins, latex, plasticisers, glues, adhesives; textile effluent and residues; Level 2 contaminated soil; and contaminated drums. Liquid waste is not received at the landfill; instead it is diverted to the neighbouring Wastewater (sewage) Treatment Plant, including controlled wastes such as grease trap waste, septic tank pump-outs and nightsoil. Caution should be exercised with respect to industrial liquid/sludge wastes which may contain unacceptable levels of heavy metals, which in turn might cause difficulty in managing the biosludges generated at the sewage treatment plant.

(ii) Dulverton Regional Waste Depot, Dulverton Regional Waste Management Authority The Dulverton Regional Waste Depot is a regional landfill located south of Devonport in the north of the State. The landfill is operated by contractors Shaw Contracting, for the Dulverton Regional Waste Management Authority. The site is one of two facilities in Tasmania licensed to handle Level 3 wastes (Category C), however the remaining controlled waste cell is expected to be filled by the end of 2007 and another is not planned. Controlled wastes accepted by the Dulverton Landfill include:

‐ Asbestos ‐ Animal effluent and residues ‐ Quarantine waste


‐ Contaminated soil ‐ Contaminated drums and containers

(iii) Port Latta Waste Depot, Circular Head Council The Port Latta Waste Depot is a small regional landfill on the north-west coast of Tasmania. It is operated by Circular Head Council. The landfill facility mainly receives wastes from Circular Head Council, as well as the neighbouring Waratah/Wynyard Council. The site also receives significant volumes of controlled waste from external sources. Port Latta operates under license issued by DPIWE in January 1996, and like Dulverton, it is licensed to handle Level 3 (Category C) controlled wastes. A peak day would be 300 tonnes across the weighbridge, but the average is approximately 1,000 tonnes per week. Controlled wastes accepted at the Port Latta Landfill include:

‐ Asbestos ‐ Fire Debris ‐ Chemical/pesticide/heavy metals ‐ Spadeable sewage sludge ‐ Hydrocarbon contaminated soil ‐ Other (subject to approval)

Circular Head Council expanded the landfill operation to accept controlled / hazardous wastes and to include processing of hydrocarbon contaminated soil in order to improve the cost effectiveness of the operation. Port Latta received all of the State’s clinical waste until recently.

(iv) Copping Refuse Disposal Site, Southern Waste Solutions The Copping Refuse Disposal Site is a regional landfill facility located approximately 52 kilometres east of Hobart, in Tasmania’s South East. The landfill is jointly owned by the Clarence City, Sorell and Tasman Councils, with a board of control including representatives of these councils. The Copping Refuse Disposal Site Joint Authority (Southern Waste Solutions) and their subcontractors operate the site. Copping’s first landfill cell is licensed to take Level 2 controlled waste (Category B) and will be filled within 12 months. Southern Waste Solutions currently do not accept Level 3 controlled waste. It does, however, accept untreated clinical and related waste, with a permit valid until the end of December 2007. This permit is expected to be extended to cover the period until Southern Waste Solutions has its treatment plant in operation.

(v) Other Landfill Facilities Handling Controlled Wastes

In addition to the four regional facilities, there are a number of smaller landfills that service local council municipalities throughout the State. As mentioned in Section 4.1, due to matters of efficiency, cost and liability, the number of these facilities in


Tasmania has been dramatically reduced from 99 to 17 over the past 13 years. Many remaining local landfills are becoming inert disposal sites with domestic, kerbside and controlled wastes being sent to the regional landfills, and waste transfer stations playing a larger role. Rationalisation is also often a means of reducing the environmental risk associated with smaller facilities, which operate under licenses that do not require stringent environmental controls or are unstaffed. Smaller-scale landfill facilities in Tasmania accept only limited controlled wastes, mostly subject to approval by the landfill operator or regulatory authority. Waste types accepted may include asbestos, medical sharps, and motorcycle/car/truck waste tyres. The primary landfills of this nature are listed below within each region, along with the relevant local council (Blue Environment, 2007).

North: St Helens (Break O’Day)

Whitemark (Flinders Island) Deloraine and Westbury (Meander Valley)

North West: Mooreville Road (Burnie)

Lobster Creek (Central Coast) – previously Penguin landfill Parenna (King Island) Zeehan (West Coast) – now full

South: Hamilton (Central Highlands)

Peppermint Hill (Derwent Valley) Jackson Street (Glenorchy) McRobies Gully (Hobart) Baretta (Kingborough)

Privately operated, industry-specific landfill sites also handle and dispose of controlled waste. These landfills are owned and operated by larger companies in such industries as mining and mineral processing, pulp and paper mills and pharmaceutical production. However, there is a gradual movement away from on-site landfilling and management of controlled waste. This is significant in that greater waste volumes for treatment, disposal and re-use/recycling may become available, in addition to the need for remediation of on-site landfills.

4.6.2 WASTE TRANSFER STATIONS

An important aspect of controlled waste management in Tasmania is the evolving role of Waste Transfer Stations (WTS), in line with the rationalisation of the State’s waste infrastructure. The trend of decreasing landfills is set to continue, with larger regional facilities servicing most of the State, and hence there being a growing requirement for WTS facilities to act as important links in the overall waste management network. There are currently over 73 WTS facilities in Tasmania, with further sites planned by Local Government and regional waste groups. According to Athena Waste Management’s WTS report (2006), these include:


North Western Region

Nine local government authorities collectively operate 16 waste transfer stations – in addition to 5 landfills, 2 regional landfills and 2 materials recovery facilities.

Northern Region Eight local government authorities collectively operate 24 waste transfer stations – in addition to 9 landfills, 1 regional landfill and 2 materials recovery facilities.

Southern Region Twelve local government authorities collectively operate 33 waste transfer stations – in addition to 5 landfills, 1 regional landfill and 1 materials recovery facility.

There is an increasing requirement for WTS sites to have suitable storage facilities, site design, and management practices that can safely and appropriately deal with controlled wastes. A number of innovative approaches are being adopted with respect to the storage and management of controlled waste at some WTS sites in Tasmania, and it should be an increasing requirement for both existing and new facilities to meet at least basic standards. Currently most sites do not.

Typical controlled wastes managed at Local Government WTS sites include engine oil, Liquefied Petroleum Gas (LPG) cylinders, vehicle batteries, occasionally medical sharps, an assortment of household hazardous wastes, as well as an increasing volume of commercial controlled wastes. The report produced in 2006 by Athena Waste Management, ‘A Report on WTS Infrastructure and Operations in Tasmania’, gives a comprehensive analysis of the above waste transfer station sites in each of the three regions, including details relating to location, current operating standards and existing infrastructure, resource recovery and controlled waste management. A substantial gap identified in the current controlled waste legislative framework is the fact that waste transfer stations are managed under LUPAA, which is primarily regulated by Local Government, unless significant harm to the environment is caused. They are specifically exempt from the EMPCA Schedule 2 definition of a ‘waste depot’, and therefore are not regulated under State legislation. This essentially means that a significant and growing volume of controlled waste received and handled at waste transfer stations will be managed in the future under the provision of two separate sections of legislation, promoting inconsistency and problems. It is recommended that the State Government work closely with the local councils and the Local Government Association of Tasmania in developing a strategy to help ensure those WTSs that accept controlled waste have the facilities in place that will satisfy the requirements of best practice. It is also recommended that the State Government develop guidelines for the use of the WTS operators, to inform them of the design and operation requirements to meet these standards.

A household hazardous waste (HHW) collection scheme is in the process of being developed in Tasmania, in order to divert potentially toxic household products such


as paint, motor oil, vehicle batteries and pesticides from the general waste stream. There is the distinct possibility that the HHW program’s operation and funding can be integrated with the review and upgrading of WTS facilities, as a means to improve handling and management of controlled waste.

4.6.3 OTHER TREATMENT / DISPOSAL FACILITIES There are a limited number of commercial controlled waste treatment/disposal facilities in Tasmania, often operating in niche waste management areas. These facilities will continue to play an important role in Tasmania, however, it is evident that more investment is required across all areas of controlled waste. In some instances there are opportunities to expand and diversify existing disposal/treatment facilities. Examples of licensed treatment and service providers in Tasmania include:

‐ Waste oil processing ‐ Composting ‐ Remediation of hydrocarbon contaminated soil ‐ On-site treatment within industry (e.g. the mining sector) ‐ Ex-situ treatment of industrial wastes for heavy metal fixation ‐ Cement and lime kilns (co-incineration in industrial facilities) ‐ Small-scale resource recovery operations

4.7 Controlled Wastes Currently Shipped Interstate

The majority of Tasmania’s controlled wastes are transported to management facilities within the State, primarily for land spreading, discharge to wastewater treatment plants, recovery, and disposal to approved landfills. In the absence of appropriate facilities, some controlled wastes are transported interstate for processing and disposal. At present, shipping controlled waste from Tasmania to the mainland is an acceptable (albeit costly) management pathway. There are, however, signs that in the future mainland States and Territories may not continue to support this practice (addressed at the end of this section). All movements of controlled wastes to or from another Australian State or Territory are subject to the provisions of the NEPM (discussed in Section 4.1.1 vi). The mechanisms established to implement the Interstate Waste Movement NEPM include Consignment Authorisations (CA) and Waste Transport Certificates (WTC). Generators must first apply for a CA from the receiving jurisdiction before wastes can be shipped interstate. Once approved, shipments are tracked through each stage using WTCs.

Table 3 displays Tasmanian controlled waste export data, adapted from the National Environment Protection Council (NEPC) Annual Reports on the Implementation of the Movement of Controlled Waste between States and Territories NEPM, for the 2001-


2002 to 2005-2006 financial reporting years. Exports are reported using NEPM waste groups – these groups are similar to those used by SIA in this study, apart from acids and alkalis in separate categories, as well as paints/resins/inks/organic sludges and pesticides. The ‘miscellaneous’ group combines laboratory chemicals/photographic waste materials and tyres. It should also be noted that the NEPM group ‘Industrial washwater’ has been omitted from the table as results are negligible. Figure 3 illustrates the percentage breakdown of controlled wastes exported, on average, during these reporting periods.

Table 3 Tasmanian controlled waste exports by NEPM waste group

Code Description of Waste

Quantity Exported by Tasmania (tonnes) As reported by NEPM

1 July 01- 30 June 02

1 July 02- 30 June 03

1 July 03- 30 June 04

1 July 04- 30 June 05

1 July 05- 30 June 06

A Plating & heat treatment 0.00 0.00 0.30 0.00 0.00

B Acids 54.56 56.30 44.20 36.75 23.38

C Alkalis 0.22 0.52 1.30 0.34 1.02

D Inorganic chemicals 4190.48 4230.69 6673.46 6944.06 6061.63

E Reactive chemicals 0.00 0.49 0.72 0.64 0.73

F Paints, resins, inks, organic sludges 36.18 4.08 94.03 34.74 4.71

G Organic solvents 165.05 240.65 136.36 71.51 329.19

H Pesticides 45.30 5.00 0.24 0.71 5.71

J Oils 1284.60 97.93 80.10 649.19 599.76

K Putrescible / organic waste 0.00 23.00 0.00 0.00 0.00

M Organic chemicals 616.38 93.31 500.23 148.57 171.96

N Soil / sludge 0.00 0.00 0.00 0.00 4.00

R Clinical & pharmaceutical 25.00 25.04 0.80 12.15 18.00

T Miscellaneous 6.15 1.13 1.78 3.39 6.71

Total (tonnes) 6423.92 4778.14 7533.52 7902.05 7226.80


Figure 3 Annual average controlled wastes transported interstate from Tasmania

Table 4 summarises current interstate transport practices for each waste category. Percentages have been calculated from annual Tasmanian exports by NEPM code, as listed in the NEPC Annual Reports. Comments on each waste category have also been made by SIA. Evident in Figure 3 above, inorganic chemicals dominate interstate transport from Tasmania, followed by oils and organic chemicals. Shipments from Tasmania are primarily destined for facilities in Victoria and New South Wales; however South Australia, Queensland and the Australian Capital Territory also receive a number of shipments each year.


Table 4 Overview of controlled waste transport from Tasmania

Waste Category % Total Interstate Transportfrom Tasmania (by NEPM group) Comments

Cyanides Plating & heat treatment <0.1%

It is estimated that negligible quantities, if any, are transported interstate. Readily destroyed on-site by a natural process or chemical oxidation.

Acid solids and solutions Alkaline solids and solutions Laboratory/photography chemicals

Acids Alkalis Miscellaneous

1% <0.1% <0.1%

Very small quantities and more likely to be economically worked out in conjunction with larger volumes interstate.

Inorganic chemicals

Inorganic chemicals Primarily zinc compounds from one source; small amounts of lead compounds, mercury and mercury compounds and nickel cadmium batteries

83% Mainly exported to minerals processing plants for their metal values. The mercury waste is being managed by fixation and secure landfill/storage by a specialist company in NSW. Batteries go to specialists with overseas recycle outlets.

Reactive chemicals Reactive chemicals <0.1% Minimal if any transport due to waste characteristics.


Paints, resins , inks, organic sludges Pesticides

<1%

<1%

Could be chemically fixated at a landfill specialising in such treatment.


Organic solvents Majority are organic solvents excluding halogenated solvents and the remainder are halogenated organic solvents

3% Majority to Victoria and remainder to NSW. Very few solvent re-distillers available - a specialised business. Only option would be a small batch distillation unit for each generator.


Oils Majority waste tarry residues, remainder waste mineral oils unfit for original intended use

8% The tarry residue has value to the recipient. Most sent to Victoria and also NSW.

Putrescible/organic wastes Putrescible/organic waste <0.1% Minimal if any transport due to

waste characteristics.

Organic chemicals Organic chemicals Majority PCB-contaminated materials, remainder surface active agents or surfactants

5% To Victoria, ACT and Queensland. The treatment provider in Qld is a resource used by all eastern states.

Solid/sludge wastes requiring special handling

Soil/sludge <0.1% Minimal if any transport due to waste characteristics.


Clinical & pharmaceutical Two thirds acids, corrosive liquid, cytotoxic waste, lab chemicals and pharmaceuticals; remainder waste pharmaceuticals

<1% Requires high temperature thermal destruction only available now in NSW, Queensland and South Australia.

Tyres Miscellaneous <0.1%

Tyres for retreading will have to go to a specialised manufacturer but there is scope for this in Tasmania, and for rubber recycle and re-use.

Security materials N/A Interstate transport for those materials requiring incineration.

Quarantine wastes N/A -


There is always the possibility that interstate regulatory authorities and commercial operators may in the future refuse to continue to accept some components of Tasmania’s controlled waste for recovery, treatment and disposal. Possible reasons for this include:

Changing attitudes and policies with respect to controlled waste

management in Australian States and Territories; Increasingly stringent controls on controlled wastes accepted at interstate

treatment, disposal and processing facilities; Commercial reasons for treatment/disposal facilities interstate to not

accept specific wastes or closure of business or facilities; Approved landfill facilities are reaching full capacity; and A lack of certainty that any products such as ash, residues or inert

material can be sent back and disposed of at Tasmanian landfills.

Waste types that are dependent on interstate transport and therefore particularly vulnerable to a decrease in shipments to the mainland include inorganic chemicals, specific waste oils, organic solvents, organic chemicals, cytotoxic and pharmaceutical wastes, and laboratory chemicals. There may also be the prospect of additional costs imposed for Tasmania’s controlled waste that is shipped interstate, such as rising State waste levies in Victoria, which could add to the financial burden of some controlled waste generators.

As previously mentioned, it has been reported that compliance with the Interstate Waste Transport NEPM requirements by Tasmanian waste producers, transport companies and receiving facilities has been good, with no discrepancies over the most recent reporting period. Tasmania’s new Controlled Waste Tracking Regulations and transport certificates will help to strengthen the regulatory framework for the NEPM and provide for the effective management and monitoring of controlled wastes sent interstate.

According to discussions with waste transporters, some jurisdictions have been known to use the NEPM approval process to block incoming waste. In effect, this is restricting trade between states, which is a constitutional issue. Tasmania’s right to trade with other jurisdictions should be kept intact and the NEPM implemented through appropriate negotiation.

For this reason, it is imperative that the Tasmanian State Government maintains open dialogue with other States and Territories, to ensure a frequent exchange of information regarding facilities, policies and issues on the transboundary movement of controlled waste under the NEPM. There needs to be an understanding by other jurisdictions that Tasmania is a small generator of controlled waste by mainland standards, and with a lack of resources or capacity to effectively cater for all waste types (the economies of scale principle), management assistance may be required in


the future. This would apply to controlled wastes which can be treated, re-used or recycled, without adding solid residuals to landfill.

4.8 Current Cost of Disposal

The cost of disposal is an influential factor in the management of controlled wastes in all Australian States and Territories. This becomes more relevant for Tasmania, as many wastes are transported within or between mainland states at efficient freight rates. Limited options for treatment and disposal in Tasmania and the cost of transporting across Bass Strait create additional issues for Tasmanian industry and waste generators. Transport and handling are a major part of the cost of waste treatment and disposal. Therefore, future infrastructure solutions need to account for travel distances and other efficiencies. Outlined in Figure 4 are disposal cost ranges, some inclusive of transport and handling costs, for a selection of controlled waste types discussed in this report. The data is based on best estimates from a variety of web-based, industry and literary sources; however distinctive variances may occur with some waste types and be outside of these ranges. As a comparative tool, disposal cost ranges for controlled wastes have been sourced from other States. It is important to note that most interstate treatment/disposal facilities operate to higher environmental standards than those operating in Tasmania. In many cases, the cost of disposal includes levies applied by State Governments such as those applied in Victoria, New South Wales and Western Australia.


Figure 4 Estimated disposal cost ranges in Tasmania and other States for a selection of controlled wastes

-200 300 800 1300

Cyanide-contaminated solids

20% cyanide solution

5% cyanide solution

Acid solids and solutions (10%)

Acid solids and solutions (4%)

Alkali solids and solutions (10%)

Alkali solids and solutions (4%)

Inorganic chemicals (20%)

Inorganic chemicals (5%)

Reactive chmicals (20%)

Reactive chemicals (5%)

Oil (dirty & wet but recyclable)

Oily wastewater

Oil emulsions

Putrescible (animal) wastes

Offensive putrescible waste

Organic chemicals (non-scheduled)

Solid waste (asbestos)

Solid waste (asbestos)

Sludges

Sludges requiring special handling

Grease trap waste

Low level contaminated soils

Clinical waste

Pharmaceutical waste

Tyres (average for all sizes)

Tyres (small to medium)

Tyres (shredded rubber VIC)

Tyres (shredded NSW)

$ /tonne

Was

te T

ype

Other states

Tasmania


Figure 5 Additional disposal cost ranges for a selection of controlled wastes

0 5000 10000 15000 20000 25000

Paints, lacquers, varnish etc

Dyes, pigments, adhesives


Pesticides

Organic chemicals (bulk PCB oils)

Organic chemicals (small PCB volumes)

$ /tonne

Was

te ty

pe

Other states

Tasmania


5. ANALYSIS BY WASTE TYPE

The following section addresses each controlled waste category individually, and discusses significant factors relating to generation, handling and disposal. This includes listing and defining the waste components using specific waste codes, discussing volumes, current practices and facilities (including interstate transport), stockpiles, primary generators and industries, costs, re-use, recycling and recovery opportunities, and options for treatment and disposal. Undertaking this process for each of the 14 waste categories highlights the complexity and difficulty involved in considering and incorporating an assortment of controlled waste streams into a state-wide management strategy. It is important to recognise that any future management and investment in controlled waste facilities is required to deal with many different waste types, from a variety of generators, and not necessarily generated consistently on an annual basis (or accurately recorded). Each waste type requires different management methods according to its physical and chemical properties. The possibility of a state-wide industry waste audit in the near future may help to gain a better understanding of controlled waste in Tasmania.

The technology section at the end of each waste category displays, in table format, some of the options for appropriate treatment/disposal in Tasmania. The table includes a brief description of the technology, examples of application, strengths and weaknesses, estimated capital and operating costs. Some of these technology solutions are outlined in further detail in Section 7 of this report.

Data Sources

For the purpose of delivering the outcomes of this report, it is necessary to arrive at a base figure for the tonnage of each waste type. It is necessary to have this base so that capital and operating costs of the required treatment solution can be determined in order to allow a business case to be formulated. Sensitivity analysis can then be applied to the economic model around waste tonnages, capital and operating costs. In order to come up with these base waste tonnages we have analysed the existing data and other estimating sources at our disposal including those sources as stated in Section 4.3.1. The base figures are shown in Appendix [5].


5.1 Cyanides (inorganic) 5.1.1 Description / Definition

Considers: A100 Waste resulting from surface treatment of metals and plastics A110 Waste from heat treatment and tempering operations containing cyanides A130 Cyanides (inorganic)

Cyanide is a widely-used industrial chemical with significant chemical properties. It is used in the mining sector as a leaching agent for removing gold and silver from ore, and is also used in industrial processes such as steel hardening/metal finishing, plastics production, and manufacture of goods such as adhesives, computer electronics, fire retardants, cosmetics, dyes, nylon, paints and pharmaceuticals. A130 ‘Cyanides (inorganic)’ include residues and other contaminated materials from the mining and minerals processing industries.

5.1.2 Waste Volumes and Future Generation Forecast For data relating to present waste generation volumes, please refer to Appendix [5]

Generation and use of inorganic cyanides is estimated to decrease in the future. Very small quantities are produced or used across mining, electroplating and manufacturing operations.

5.1.3 Current Practices and Facilities

Practices in Tasmania Cyanide wastes rarely require disposal. In gold and silver mining, the contaminated wastewater (tailings) is retained in dams whilst the cyanide decomposes naturally by exposure to sunlight and air. Chemical destruction is another option whereby wastewater is treated with alkaline substances and hypochlorite to rapidly destroy cyanide, releasing products of the reaction (carbon dioxide and nitrogen) safely into the atmosphere. Solid wastes contaminated with cyanide are stored on-site pending disposal by ‘burning’ in a cement kiln or similar. In time, the cyanide content reduces by natural oxidation, however it must be stored dry to avoid leaching. It is understood that spent cell liner from an industrial operation is currently being stored in northern Tasmania, awaiting disposal in the cement kiln at Railton – and this is likely to take place in 2008. This waste stream is representative of many industrial waste streams (cyanide and non-cyanide) that could be processed through a cement kiln.


Interstate Transport As there is low cyanide waste generation in Tasmania, and solid waste or wastewater containing cyanide is treated and disposed of in Tasmania (for example, in tailings dams), negligible interstate transport has been recorded or is likely to occur in the future. On average, 0.05 tonnes (<0.1%) of controlled wastes transported interstate from Tasmania by NEPM group between 2001 and 2006 were wastes from plating and heat treatment.

5.1.4 Stockpiles

Electroplating waste is as dilute wastewater, chemically treated on-site for cyanide destruction (to carbon dioxide and nitrogen) before wastewater discharge to sewer. More concentrated plating solutions are always returned to the chemical suppliers for recovery of metal values. Solid cyanide-contaminated waste from aluminium smelters is associated with carbon and refractory (electrodes) and is destroyed when these wastes are combusted. Whilst in storage the solid wastes must be protected from leaching to the water environment.

5.1.5 Waste Generators

‐ Mining industry (gold and silver operations) ‐ Industrial processes (aluminium smelters) ‐ Metal finishing (electroplating) ‐ Manufacturing ‐ Heat treatment and tempering operations (cyanide used as a nitrogen source

for nitriding) ‐ Food production (produce organic natural cyanides)

5.1.6 Current Cost of Disposal

Waste Type Estimated cost per kilogram (CN-) +/- % Explanation

A100 Waste resulting from surface treatment of metals and plastics

$20 /kg 30% By hypochlorite treatment.

A110 Waste from heat treatment and tempering operations containing cyanides

$20 /kg 30% By thermal destruction of waste containing 5% cyanide.

A130 Cyanides (inorganic) $5 /kg 30% By thermal destruction of waste containing 2% cyanide.

5.1.7 Opportunities for Re-use, Resource Recovery or Waste Exchange

Nil, except for the recovery of precious metals from concentrated plating solutions.


5.1.8 Treatment Options

Neutralisation and oxidation (dilute solutions, wastewater)

Description: The plant comprises at least two storage tanks (acid and alkali) with corrosion resisting linings, pumps for transfer and mixing of the waste fluids, agitated reaction tanks of corrosion resistant materials, dosing pumps and chemical storage and measuring tanks, pH (acid and alkali level) and Oxidation Reduction Potential (ORP) controls. Examples of Application: Electroplating rinse water treatment before discharge to sewer. Strengths:

• Common process with no toxic by-products, only carbon dioxide and nitrogen gas emitted and additive saline solution to sewer.

Weaknesses: • Produces increased salinity in wastewater.

Est. Capital Cost Est. Operational Cost

+/- % Explanation

$ 125,000 $15,000 p.a. 30% For plant treating 10m3/day at 500ppm CN-

5.2 Acid solids and solutions Alkaline solids and solutions Laboratory / photography chemicals

5.2.1 Description / Definition

Considers: B100 Acidic solutions or acids in solid form (with pH value of 4 or less) C100 Basic solutions or bases in solid form (with pH value of 9 or more) T100 Waste chemical substances arising from research and development or teaching activities including those which are not identified and/or are new and whose effects on human health and/or the environment are not known T120 Waste from the production, formulation and use of photographic chemicals and processing materials

5.2.2 Waste Volumes and Future Generation Forecast

For data relating to present waste generation volumes, please refer to Appendix [5].

The production and use of acid and alkaline solids and solutions is expected to be steady, as with laboratory and photographic processing chemicals. (There may be a slight decrease in photographic processing materials with the shift to digital photography).



Practices in Tasmania Apart from shipment interstate, current management practices in Tasmania for acidic/basic substances, photographic chemicals and processing materials, and laboratory chemicals include pre-treatment (neutralisation) and disposal to landfill, transport to a wastewater treatment plant, or on-site management. Individual reports from the industry survey conducted by DPIWE in 2005 also included immobilisation/solidification, incineration (for photographic papers and films), recovery and recycling. Interstate Transport According to NEPM records for outgoing interstate movements of controlled wastes between 2001 and 2006 (by NEPM waste group), on average, acids comprised 1% of movements (43 tonnes), alkalis comprised <0.1% of movements (0.7 tonnes) as did laboratory/photographic wastes in the ‘miscellaneous’ category (4 tonnes).

Acid and alkaline solids or solutions are not widely transported interstate from Tasmania. Treatment and disposal to landfill appears the most favoured solution. All T100 and T120 category waste shipped interstate is sent to Victoria for treatment. According to the Controlled Waste Inventory (DTAE, 2004/05), approximately 69% are laboratory chemicals (T100), and the remainder is photographic waste (T120). Waste contractors take most of the laboratory chemicals to Victoria for treatment. Interstate transport of this nature is vulnerable to changes in policy by EPA Victoria. In the near future, Victoria may refuse to accept shipments of laboratory wastes, unless residues produced in the treatment or destruction process are brought back to Tasmania for landfill disposal.

5.2.4 Stockpiles

Stockpiles of chemical substances in this category are primarily of a temporary nature, awaiting interstate transport for disposal or recovery.


‐ Mining sector ‐ Heavy industry ‐ Laboratories and research institutes ‐ Businesses in the ‘personal and other services’ sector e.g. photo developers ‐ Health and community services ‐ Education sector ‐ Government administration e.g. local councils ‐ Australian Antarctic Territory



Waste Type Estimated cost per kilogram +/ - % Explanation

B100, C100, T100, T120 Acids, bases, laboratory/ photography chemicals

$6 - $9 /kg - Includes transport and handling to mainland.


Acids and alkalis can be used for other waste treatments, for example neutralisation, precipitation and oil/water separation (emulsion breaking). Silver can be recovered from photographic chemicals.


Neutralisation and precipitation

Description: The plant comprises at least two storage tanks (acid and alkali) with corrosion resisting linings, pumps for transfer and mixing of the waste fluids, agitated reaction tanks of corrosion resistant materials, dosing pumps and chemical storage and measuring tanks, pH (acid and alkali level) and Oxidation Reduction Potential (ORP) controls. Examples of Application: Blending of wastes to adjust pH and effect precipitation. Strengths:

• One plant can handle most wastes. • Small volumes involved, and many and variable waste compositions.

Weaknesses: • Expensive due to technical process requirements. Could be combined with an analytical

laboratory.

Est. Capital Cost Est. Operational Cost +/- % Explanation

$200,000 $160,000 p.a. 30% 1 man laboratory plus tankage 1 full-time operator

Incineration

Description: Silver recovery for photographic papers and film only, not suited to chemicals. Almost total volume reduction. A small incinerator in a highly secured area/building, where paper and film can be burnt off at modest temperature, leaving behind an ash containing the silver, for recovery. Examples of Application: Small manually loaded incinerator can handle 100 kg/day, ~20 tonnes p.a. Strengths:

• Silver recovery (silver is toxic in landfill). Weaknesses:

• Cannot generally be economic.


$150,000 $35,000 p.a. 30% Half-man operation Needs to be combined with other operations


5.3 Inorganic chemicals 5.3.1 Description / Definition

Considers: D100 Metal carbonyls D110 Inorganic fluorine compounds excluding calcium fluoride D120 Mercury; mercury compounds D130 Arsenic; arsenic compounds D140 Chromium compounds (hexavalent and trivalent) D150 Cadmium; cadmium compounds D160 Beryllium; beryllium compounds D170 Antimony; antimony compounds D180 Thallium; thallium compounds D190 Copper compounds D200 Cobalt compounds D210 Nickel compounds D220 Lead; lead compounds D230 Zinc compounds D240 Selenium; selenium compounds D250 Tellurium; tellurium compounds D270 Vanadium compounds D290 Barium compounds (excluding barium sulphate) D300 Non toxic salts D310 Boron compounds D320 Phosphorus compounds excluding mineral phosphates D330 Inorganic sulphides D340 Perchlorates D350 Chlorates



The production of inorganic chemicals in Tasmania is expected to remain steady. Zinc compounds comprise the majority of interstate shipments in this waste category, and are produced by one metal products manufacturer, therefore, generation is expected to remain consistent provided this party continues with its zinc production.

Generation of nickel cadmium batteries may plateau as mobile phone usage reaches saturation point. However, it is thought that large numbers of mobile phone batteries are held in storage by consumers and therefore generation may peak in the future if national action is taken to recover these.



Practices in Tasmania Excluding interstate transport, current management practices in Tasmania for inorganic chemicals include on-site management through recycling and other forms of re-use at major industrial sites (for example hydro-metallurgical metal salts recovery and pyro-metallurgical metals recovery).

Interstate Transport The majority of wastes classed as inorganic chemicals are transported from their point of generation in Tasmania to interstate facilities for recycling/reprocessing. According to NEPM records for outgoing interstate movements of controlled wastes between 2001 and 2006 (by NEPM waste group), on average, inorganic chemicals comprised 5620 tonnes or 83% of movements. This is mainly inter-industry.

According to DTAE records of WTCs indicating transport of inorganic chemicals between 2002 and 2005:

‐ Approximately 97% by quantity of all inorganic chemicals transported interstate

are zinc compounds (D230), originating from a Tasmanian metal products manufacturer in the form of zinc dross. This material is sent to NSW for re-use, and there is no current indication of refusal by the facility to accept it in the future. However, alternative options may have to be considered.

‐ Approximately 3% of inorganic chemicals transported interstate are lead

compounds (D220), originating primarily from one manufacturer. The lead dross is shipped to South Australia for reprocessing and there is no indication that this will not continue. Other Tasmanian manufacturers produce minor quantities of lead acid batteries, and garnet blasting abrasive and paint flake waste, which is transported to Victoria.

‐ A very small proportion of shipments comprise mercury and mercury compounds

(D120); cadmium and cadmium compounds (D150, mainly nickel cadmium batteries); selenium compounds (D240); sodium metabisulphite, sodium bisulphate and non hazardous chemicals (D300 or ‘non toxic salts’); and silver nitrate and oxidising agents (D340 or ‘perchlorates’).

‐ Lead acid batteries are recycled in Victoria and batteries are exported to New Zealand for recycling. All Australian States and Territories are dependent on these facilities for battery recycling, and this should continue. Nickel cadmium batteries are recycled in Victoria and New South Wales. Again, Tasmania has no alternative option. However, there have been past concerns regarding the Victorian plant’s storage capacity.


5.3.4 Stockpiles

There is temporary on-site stockpiling of inorganic chemicals - often stored between collection dates (mainly batteries) and then shipped interstate for recovery, treatment and disposal.


Production of inorganic chemicals in Tasmania is dominated by one generator. However, this stream is not regarded by the industry as waste, rather by-products. There are also various generators of batteries from domestic and industry (e.g. mining) vehicle servicing, electrical equipment, personal computers, and mobile phones, as well as local councils and the Australian Antarctic Territory.


Waste Type Estimated cost per kilogram +/- % Explanation

D100 - D350 Inorganic chemicals $6 - $9 /kg - Includes transport and handling to mainland.


According to information provided to DTAE when Consignment Authorisations (CAs) are sought, nearly all material (97%) classified as inorganic chemicals is destined for recycling. This takes place at processing facilities in Victoria, New South Wales, South Australia and on occasion New Zealand. Recycling of batteries:

‐ Lead-acid (mainly from vehicles) are recyclable in Australia ‐ Lithium-ion (electrical equipment, personal computers, and mobile phones)

are recyclable overseas ‐ Nickel-cadmium (rechargeable, medium to long-life) are recyclable overseas ‐ Mercury (medical use, long-life) are recyclable overseas ‐ Zinc (disposable, domestic and industrial use) are primarily landfilled but

could be recycled



Hydro-metallurgical metal salts recovery processes

Description: Metals recovery as precipitated compounds and elimination of leachate issues. Potential for some minor effluent management requirements, such as waste liquors requiring sewer access, or a final wastewater treatment facility. Plant comprises corrosion resistant tankage, reaction (neutralisation) vessels, transfer pumps, and chemical storage, measuring and dosing vessels and pumps, together with process controls, such as level, pH and ORP instruments. Examples of Application: Process waste streams are neutralised, metals are precipitated either as neutral hydroxides, oxides or insoluble salts, and filtered or thickened for recovery, prior to discharge of the treated wastewater as trade waste. Strengths:

• On-site treatment. • Possible metals recovery.

Weaknesses: • Variable results if not supervised. • Potential for some small effluent issues.


N/A N/A N/A Part of the on-site process

Pyro-metallurgical metals recovery processes

Description: Metals recovery by roasting oxidation, smelting reduction, in small batch or continuous furnaces, producing metals or metal oxides for recovery at main production facilities, with potential for some air pollution. Examples of Application: Slags and dusts recovery on-site or at co-operative sites. Strengths:

• Eventual disposals are then low contaminant level ashes and slags. Weaknesses:

• Potential for some air pollution (dust, fume and vapours – heavy metals). • Long-term storages between or until economics allow commercial exploitation. Otherwise too

expensive. Est. Capital Cost Est. Operational

Cost +/- % Explanation

N/A N/A N/A On-site or at co-operative sites

5.4 Reactive chemicals 5.4.1 Description / Definition

Considers: E100 Waste containing peroxides other than hydrogen peroxide E120 Wastes of an explosive nature not subject to other legislation




Generation of reactive chemicals is expected to remain steady. Very small quantities are used and little waste is generally produced.


Practices in Tasmania None specified but will be typical. Interstate Transport Negligible interstate transport of this waste category occurs due to its hazardous characteristics. According to NEPM records for outgoing interstate movements of controlled wastes between 2001 and 2006 (by NEPM waste group), on average, reactive chemicals comprised <0.1% (0.5 tonnes) of movements.

5.4.4 Stockpiles

The stockpiling of reactive chemicals is largely unknown in Tasmania, perhaps on-site (and secure) storage of unused or out-of-date materials in drums and containers.


‐ Quarry and mine operations (explosives) ‐ Industrial waste water treatment plants - organic peroxides used as chemical

additives 5.4.6 Current Cost of Disposal


E100, E120 Reactive chemicals $6 - $9 /kg -

Includes transport and handling to mainland.


Under carefully controlled conditions, specialised disposal companies employ some waste oxidant streams (hypochlorite and peroxide) in the treatment of heavy metal wastes. They can also be safely disposed to sewer under controlled conditions.



Peroxides other than hydrogen peroxide

Description: Unused chemicals may be returned to supplier, otherwise disposed via specialised waste contractor (interstate). Volumes too small and contents too variable for local operation. Examples of Application: Oxidants in original containers can be used by waste processor in precipitation and chemical destruction processing of other waste. Strengths:

• Mostly re-used in the disposal process with some value. Weaknesses:

• Safe packaging, transport and storage can be expensive.


N/A N/A N/A Volume too small. Could combine with Section 5.2 for a Tasmanian facility.

5.5 Paints, lacquers, varnish, resins, inks, dyes, pigments, adhesives Pesticides

5.5.1 Description / Definition

Considers: F100 Waste from the production, formulation and use of inks, dyes, pigments, paints, lacquers and varnish F110 Waste from the production, formulation and use of resins, latex, plasticisers, glue and adhesives H100 Waste from the production, formulation and use of biocides and phytopharmaceuticals H110 Organic phosphorus compounds H170 Waste from the manufacture, formulation and use of wood-preserving chemicals



Residues from a wide variety of Tasmanian industries, commercial operations and households, generally in small volumes and containing a wide range of toxic and hazardous compounds, will continue to be generated at present rates. There may be a slight increase in the short-term, as a result of the Household Hazardous Waste program being developed in Tasmania. This may encourage acceptable practice associated with the disposal of domestic controlled wastes such as paints, pesticide residues, varnish etc. and hence result in increased volumes managed as controlled rather than general waste.


5.5.3 Current Practices and Facilities Practices in Tasmania Collected contaminated containers are often left to dry out, and then cleaned (dry) and baled for scrap. Larger quantities of liquid residues are transported off-shore for recovery into waste oil fuels. There is no such facility in Tasmania. However, there are local tip-shop, commercial and individual industry efforts to re-use paint waste. There are also reports that off-specification paints are sometimes mixed and sold in bulk at a lower cost to avoid waste. Interstate Transport According to NEPM records for outgoing interstate movements of controlled wastes between 2001 and 2006 (by NEPM waste group), on average, paints, resins, inks and organic sludges comprised <1% of movements or 35 tonnes. Pesticides also comprised <1% of interstate movements (11 tonnes) over this period.

5.5.4 Stockpiles

The ‘Chemclear’ program should effectively clear stockpiles. The industry-funded national scheme was launched in 2005 and has taken over the collection of unwanted farm chemicals from the previous ‘Chemcollect’ initiative.


‐ Domestic premises - generating household hazardous waste e.g. paints, glues, varnish etc, in small quantities and in small containers. This would also include commercial operators such as painting contractors, carpet cleaners and those dry-cleaners which have converted to non-chlorinated organic solvents.

‐ Manufacturing industries - those making paints and adhesives, and those using these materials.

‐ Agricultural sector - using chemicals now generally supplied in returnable containers which are cleaned and re-used by the chemical suppliers.



F100, F110, H100, H110, H170 Paints, lacquers, varnish, resins, inks, dyes, pigments, adhesives; Pesticides

$2 - $9 /kg - Includes transport and handling to mainland.


There are enterprising operators in the paints and coatings industry who produce low-cost primer and undercoat by blending compatible paint residues. As previously mentioned, paints are also re-used through tip shop and recovery operations.


Some suppliers of pesticides and herbicides will accept returned containers, even with residues. Many are making it a requirement that containers be returned for cleaning and re-use next season. The ‘drum-muster’ program operates successfully throughout Tasmania. This requires triple rinsing of the containers prior to depositing at a council collection point where they are inspected before being collected for crushing and baling for recycle.


Solidification (chemical fixation) and landfill

Description: Water-based non-volatile organic substances are fixed within a cement like matrix to reduce or eliminate leaching and evaporation. The process involves solidification with cement powder and mineral additives such as fly-ash and sand, allowed to dry and set and are then landfilled. Equipment usually comprises a front-end-loader, a cement mixer, a concrete pad on which to tip the cement treated slurry to set and be broken up and loaded into skip or truck for disposal of the fixated residues at a landfill. Examples of Application: Water-based paints and polymer emulsions, oil emulsion coolants and some pesticide and herbicide residues. Strengths:

• Cheap disposal where volumes and contents too variable for recycle or re-use. • Relatively inert or stable residue, unlikely to contaminate leachate.

Weaknesses: • Increases volume for disposal.

Est. Capital Cost

Est. Operational Cost +/- % Explanation

$180,000 $60,000 p.a. 30% 250 tonnes p.a. facility (Much cheaper if incorporated into a landfill operation)

On-site disposal for pesticides

Description: Application to boundaries, access tracks and drainage banks, to empty spray tanks and rinsings from containers. Facility includes storage tanks, usually of polymer construction, water rinsing spray nozzle(s) and pressure pump. The tanks are designed for very complete emptying, with good drainage into small pump suction wells. With minimal residual fluid the spray tanks are then rinsed intermittently (spray and drain-down) with high pressure sprays inserted or installed in the top of the tanks, and then towed back out onto the site and the diluted fluids applied to the ground, turf and vegetation. This can be repeated for further dilution rinsing if necessary. Examples of Application: Residual golf course chemicals sprayed out onto fairway rough and paths. Strengths:

• Nature is capable of destroying most of these chemicals, by sunlight and oxidation, by exposure to the atmosphere.

• There is a synergy in using these chemicals in areas surrounding target areas of primary application.

Weaknesses: • Extra time for men and machinery to get back into the field with the diluted residues, easier to

tip them down the drain.


$ nil Additional 15 to 30% of first cost of application

- Rinsing and draining via the regular spraying tank and equipment


5.6 Organic solvents, solvent residues 5.6.1 Description / Definition

Considers: G100 Ethers G110 Organic solvents excluding halogenated solvents G150 Halogenated organic solvents G160 Waste from the production, formulation and use of organic solvents


For data relating to present waste generation volumes, please refer to Appendix [5]. An overall increase in annual generation of organic solvents and solvent residues in Tasmania is expected, with two primary organic (bio) chemicals manufacturers in operation and a third about to start up. The primary generator for halogenated organic solvent waste is also expected to continue production.

5.6.3 Current Practices and Facilities Current Practices

Organic solvents and solvent residues are either processed on-site by generators, stockpiled awaiting further management (such as re-use by blending into waste oils for use as fuel in a cement kiln), or transported interstate for treatment and recovery processes.

Interstate Transport According to NEPM records for outgoing interstate movements of controlled wastes between 2001 and 2006 (by NEPM waste group), on average, organic solvents comprised 3% of movements or 189 tonnes. Victoria is the primary destination for these shipments, with the remainder sent to New South Wales. Shipment of organic solvents is vulnerable to changes in policy by interstate regulatory authorities such as EPA Victoria. According to the Controlled Waste Inventory (DTAE, 2004/05), Tasmanian WTB reports between 1998 and 2005 indicated around 75% of organic solvents/solvent residues are transported interstate. Transport of this nature is dominated (78% by quantity) by G100 waste (organic solvents excluding halogenated solvents) which is primarily generated by one organic chemicals manufacturer. Approximately 54% of this material is destined for recycling and 39% for energy recovery.


Common descriptions for waste within the G100 category that is shipped interstate are:

‐ Ethyl Acetate ‐ Cyclohexane ‐ Toluene ‐ Non-halogenated solvents ‐ Hydrocarbon solvents such as hexane ‐ Thinners ‐ Methylated spirits ‐ Extraction tars ‐ Glycols

The majority of remaining material (around 13%) is classified as G150 or ‘halogenated organic solvents’. This waste type is mostly generated by one manufacturer, and nearly all of the material is destined for recycling. Some descriptions for waste in this category include:

‐ Butyl chloride ‐ Chlorinated solvents ‐ Chloroform ‐ Dichloromethane ‐ Hydrocarbon waste ‐ Mixed halogenated solvents ‐ Perclean (halogenated solvent) ‐ Trichloroethylene

5.6.4 Stockpiles

Small quantities of organic solvents and solvent residues have been recorded by WTBs (1998-2005) as being stored, pending further management options.


- Manufacturing sector - Education sector - Health services sector - Motor vehicle retailing - Personal services sector e.g. dry cleaning

The generation of non-halogenated organic solvent waste (G110) in Tasmania is dominated by two or three organic (bio) chemicals manufacturers, however smaller quantities are generated by education and research institutions as well as some manufacturers. Large volumes are recovered and re-used on-site very efficiently.

One manufacturer generates the majority of halogenated organic solvent waste (G150), with small quantities also produced by dry cleaners. There are industry


changes taking place that will replace these with non-halogenated solvents even in the short-term.


Waste Type Estimated cost per litre +/- % Explanation

G100, G110, G150, G160 Organic solvents/ solvent residues

$3 - $4 /L ($3300 - $4450 /t) - Includes transport and handling to

mainland.


According to DTAE, the majority of solvent waste is employed for energy recovery, particularly by a Victorian solvent-based fuel supplier. Some waste was earlier recycled by a security recycling and destruction plant, also in Victoria. The latter is no longer operating and the nearest solvent re-distiller would now be in New South Wales. Because of the cost of such services, there is apparently much of this waste stream being ‘lost’ or ‘hidden’. Practices such as tipping solvents and light fuel slops into waste heavy oil and lube-oils, are apparently common, there may even be some of this waste stream being purposefully blended (cut-back) into fuel oil on a commercial basis. One collector does a precautionary test for low flash-point for bulk oil collections and for LEL (lower explosive limit) for all collections. Presumably this caution and any additional charges will act against them where a waste generator is practising with deception. There are difficulties in arranging transportation of these highly flammable and somewhat toxic fluids. Management of these wastes is vulnerable to policy shift by EPA Victoria. There have been discussions about processing residues that need landfilling and shipping waste interstate for landfill, in that EPA Victoria has a policy of not accepting waste material from interstate for landfill in Victoria. The trend for generation is expected to be affected by industries looking for 'cleaner' alternatives yet may increase over time as new industries are developed (e.g. the pulp mill).

There is cause for concern in other states that the national levy/benefit scheme aimed to encourage the recycling of waste oil into higher value products, such as lube-to-lube and lube-to-diesel, will absorb a large proportion of the waste oil blending feedstock. For example, the value of lube-to-lube recycling is ten times greater than its use, simply for its energy value. This could significantly reduce the capacity to treat solvent waste by blending with oil for destruction in and fuelling of cement kilns. With the small scale of Tasmania’s waste oil business and the high cost of interstate marine transport, it is unlikely either of these options will be on offer for Tasmania. What it may mean is that Tasmania’s waste oil may be attractive to recyclers, as a blending stock for waste contaminated light oil and solvent disposal, in Tasmania.


According to one Tasmanian operator in the field, while the incentive of a rebate is high for lube-to-lube products through the levy system, it is unlikely the technology will be taken up to the point where waste oil volumes will be affected.


Co-disposal for fuel value with waste oil

Description: Small proportions of non-chlorinated solvents are blended into waste oils for use as fuel for cement kilns, boilers and other process plant capable of burning liquid fuels. The resulting fuel oil blend must meet appropriate industry specifications. Examples of Application: Applicable where there are sufficient quantities of waste oil, engine oils from maintenance workshops and tank bottoms, and sufficient consumers for the waste oil fuel. Strengths:

• This can be a good resource recovery exercise where there is sufficient market for the fuel produced and this would seem to be the case in Tasmania with lime kilns, a large cement kiln and greenhouse heating, outlets.

• Blending solvents can enhance the fuel performance. • Safe disposal of flammable waste.

Weaknesses: • Requires careful control with good laboratory services. • Relies on balancing the quantities of solvent wastes. • Solvent value sacrificed for low value fuel outcome.


$200,000 $100,000 p.a. 50% 250 tonnes p.a. organic solvent into 5,000 tonnes p.a. waste oil stream

Solvent recovery

Description: On-site in-process solvent recovery and recycle usually by distillation processes. Examples of Application: As operated by several Tasmanian organic chemical producers. Strengths:

• On-site and solvent specific, high-efficiency recycle. Weaknesses:

• Limited by quality of recovered solvent, particularly due to process contaminants. • Solvent recovery and refining is energy intensive.


N/A N/A N/A Large quantities are recycled in this way and all the costs are incorporated into the manufacturing cost


Distillation

Description: On-site processing for recovery and recycle/re-use (high volatility, flammable solvents). Distillation processes requiring careful segregation in collection and storage, often by a tolling arrangement (return to sender). Examples of Application: Printing solvents, eg. photo-gravure process. Cleaning solvents for parts washers in machine shops and machine maintenance and servicing facilities. There are small electrically heated batch distillation units commercially available, providing opportunities for on-site recovery of high quality (minimum contamination) solvent. Strengths:

• Good quality solvent recovery is assured. Weaknesses:

• For off-site services the added transport and re-processing costs have to be weighed against low priced imports of fresh solvent.

• On-site use of distillation plant is a venture into non-core business and regarded as too difficult in many cases.


$125,000 imported unit

$30,000 p.a. (power, spares and disposables, not including labour)

30% 10 TPA on-site batch solvent distillation unit. This is a break-even case, larger capacity will be more remunerative.


$450,000

$100,000 p.a. (power, spares and disposables, and including labour)

30% 50 TPA on-site or off-site centralised batch solvent distillation unit.

5.7 Oils, hydrocarbons, emulsions 5.7.1 Description / Definition

Considers: J100 Waste mineral oils unfit for their original intended use J120 Waste oil/water, hydrocarbons/water mixtures or emulsions J160 Waste tarry residues arising from refining, distillation, and any pyrolytic treatment


For data relating to present waste generation volumes, please refer to Appendix [5]. The volume of these wastes is expected to grow into the future, in line with economic and population growth. Tasmania has a large and diffuse waste oil generating base.



Practices in Tasmania A Tasmanian oil recycler claims to handle approximately half of Tasmania’s waste oil and this goes to fuel the local lime kiln, a chipboard manufacturing plant, and seasonally for greenhouse heating. Only small quantities are collected via the council-operated waste transfer and recycle stations. An analysis by DTAE of WTB reports found that approximately 35% of reported material was recycled or reprocessed, 28% was converted to energy and 20% was stored. The proportion reprocessed, such as lube-oils, is generally filtered and dried for re-use. The proportion stored must eventually report as fuel which would confirm the Tasmanian oil recycler’s claim of 50%.

Interstate Transport According to NEPM records for outgoing interstate movements of controlled wastes between 2001 and 2006 (by NEPM waste group), on average, oils comprised 8% of movements (approximately 542 tonnes). The majority of wastes in this category transported interstate were sent to Victoria, and the remainder to New South Wales.

According to the Controlled Waste Inventory (DTAE, 2004/05), the majority (77% by quantity) of interstate transport within this waste category is liquid coal tar classified as J160 or 'waste tarry residues arising from refining, distillation, and any pyrolytic treatment'), primarily generated by one company within the electricity and gas supply sector. All J160 material is destined for recycling and reprocessing.

It appears the coal tar waste is recorded by WTBs as J200 material, for which there is recorded 820 TPA average over 2005/6. There is only 32 TPA generated on average for the J160 category, which may represent tarry wastes from the botanicals business (for example, alkaloids). The remaining shipments (22% by quantity) is classified as J100 or ‘waste mineral oils unfit for their original intended use' and includes hydrocarbon waste, lubricant oil and water contaminated fuel.

5.7.4 Stockpiles

Tankage and drummed waste awaiting quantity sufficient for economic collection.


‐ Automotive service stations (lubricant oils and slops) ‐ Machine shops and machinery service facilities ‐ Oil terminals (tank bottoms) ‐ Shipping/marine/ports bunkering services ‐ Mining and industrial sites



Waste Type Estimated cost per litre

+/- % Explanation

J100, J120, J160 J200 Oils, hydrocarbons, emulsions and tars

$0 - $0.31 /L (up to $350 /t) - Includes transport locally.


Present Tasmanian usage for recovered oil is primarily for fuelling the lime kiln, chipboard plant, and greenhouse heating. This could be extended to other oil-fired equipment such as metallurgical furnaces and boilers if the oil quality is upgraded. The separated water is presently discharged to sewer but contains high residual oil levels (trade waste limit is generally 30 ppm), and would be better re-used at co-composting plants, which might also take the sediment sludges produced by the oil/water separation process. The water would be beneficial, the solids inert, the heavy metals content small and both of little consequence, the small amount of residual oil readily absorbed by the compost and biodegraded. These sludges are presently rendered suitable for landfill by remediation, including cement fixation. This is a more secure method of disposal for toxic contaminants than composting, however is wasteful of several resources, for example cement and its large energy component, and landfill space. It will be a matter of economics and will require some testing, but the alternative should be considered.

A question has been raised regarding treatment via composting, that in the case of oily sludges, this is contrary to the requirements of Bulletin 105 (which does not permit treatment by dilution of contaminated solids or soils). However, in the case of water and sludges recovered from waste oil treatment, the factors of water recovery and biological treatment are conservation issues worthy of consideration. Co-composting is a better solution than land-farming (spreading) in that it makes a quality controlled product with market regulation and specifications that ensure soil application is capable of adequate control. There is an operation in the state’s North West that effectively remediates oily sludges, along with hydrocarbon contaminated soil, by land-farming. So long as contaminant build-up, such as heavy metals content of the soil, does not become an issue, this is surely a valuable treatment facility for the N120 contaminated soils category and with capacity for the sludge products arising out of the processing of J100 category oily wastes. Whilst the opportunity for re-use has been discussed, there is always the possibility that any industry with the capability to use recovered oil could convert their fuel source to natural gas. However, each industry will undertake an economic analysis to determine the feasibility of this which would include not only the cost of the gas ($/GJ) but the gas interconnection costs and boiler conversion (typically cheap). It may


mean an economic incentive of some kind is necessary to those industries still willing to use recovered oil when the use of gas is more economic without such an incentive.


With Australian lube-oil production declining in favour of cheaper imports, there is little chance that lube-oil recovery by reprocessing will be a consideration, unless there is government intervention. It is approximately cost neutral but offers significant environmental and ecological benefits in terms of energy saving and resource conservation. The process is not a simple one, from the waste oil collection which needs to be in a segregated and well husbanded fashion, through a full re-distilling process, to the marketing of quality controlled and branded products. It could only be contemplated on a scale much larger than the Tasmanian market place and would thus involve interstate shipping.

Some lube-oil can be recycled as an upmarket product for low grade lubricant by simple dewatering and filtration, but the waste collection must be managed so as to ensure effective segregation and quality control, and sale of the product into a small and particular market, for example as a mould release agent. This degree of recycling is already practised in Tasmania, probably to the extent the market may allow. The alternative is the recycling of lubricants with other waste oils, recovered as fuel oil. Even this can be complicated if the fuel oil is to be suitable for general distribution, requiring a degree of chemical refining for advanced dewatering and heavy metals reduction. Throughout 2006, without the Invermay facility, the other Tasmanian waste oil recycle facilities were at full stretch and unable to expand. Storages were quickly filled and there was an urgent need for new processing capacity. Shipment interstate was the only short-term solution. The Invermay operator has since established a new gravity separation and filtration operation, and the situation is resolved at present. In the longer term, Government initiatives and possibly incentives will be needed to attract a new operator or to encourage expansion by the existing operators. Besides being financially demanding, there are environmental and social issues to be negotiated, especially if the new capacity includes production of an upgraded product.


Heating and chemical separation

Description: Advanced waste oil processing by heating and chemical/acid water separation treatment. Plant comprises storage, batching and treatment tanks, with pumps for transfers and tank agitation, some with in-tank heating coils, otherwise with external heat exchangers, and an electric or fuel fired hot oil or steam boiler to supply the heat. Also, chemical dosing tanks and pumps, temperature, flow and level controls. Also requires a simple on-site laboratory to determine, case-by-case, the treatment requirements for each batch. Examples of Application: Production of a generally acceptable burner fuel oil for use in all types of industrial furnaces, boilers and heaters. Strengths:

• A wider market for the recycled fuel product. • A less polluting fuel.

Weaknesses: • Cost of the recycle fuel is similar to the cost of ‘new’ burner fuel oil. • Heavy metal sludges are produced which require treatment and secure disposal.


$2,750,000

$225,000 pa not including waste collection and sales and marketing costs.

30% 2000 TPA, 1500 litres per hour x 12hrs/day x 5.5 days/wk processing plant

5.8 Putrescible / organic wastes 5.8.1 Description / Definition

Considers: K100 Animal effluent and residues (abattoir effluent, poultry and fish processing waste) K110 Grease trap waste K120 Industrial grease interceptor waste K130 Sewage sludge and residues including nightsoil and septic tank sludge K140 Tannery wastes (including leather dust, ash, sludges and flours) K190 Wool scouring waste



There is likely to be a growth in waste from intensive animal husbandry. This will yield increases in abattoir waste volumes requiring increased rendering capacity. However, rendering capacity has been reducing in Tasmania over recent years, resulting in more offal sent to landfills. It is essential that this trend be reversed or that alternative disposal methods are encouraged.

It is likely that there will be growth in Tasmania’s aquaculture industry in the near future, and therefore an increase in fish processing waste.


5.8.3 Current Practices and Facilities Practices in Tasmania According to DTAE’s Controlled Waste Inventory (2004/05), land farming, irrigation or spreading accounted for 38% of material putrescible/organic material reported, with a further 30% sent to wastewater treatment plants and 15% sent to landfill. With the lack of rendering capacity, some abattoir waste appears at landfills and some may go to land-farming, both of which are far from ideal. Meat rendering plants are expensive to build and to operate, and require onerous environmental considerations. Government initiatives may well be required. The markets for rendering products, tallow and meal, are not generally very attractive and much of the cost must be borne by the meat producers and is passed on to their markets. A good portion of the fish plant waste goes to one composting operation and is a beneficial raw material for producing compost. Additional composting capacity is required in the State, and this could provide a resource for handling expected increased volumes of fish processing waste. There are two fish oil plants in the state, one being a large fish rendering plant processing whole fish. This plant apparently has additional capacity that might be applied to fish processing waste. There would be requirements for quality control, to bring waste streams into the whole fish processing stream. The production of fish oil for a large and expanding international market would be a much better value-adding solution than composting. The fish meal market could no doubt be expanded to accommodate the increased production. Some fish processing waste is presently processed into pet food. This is on a small scale and requires the use of selected wastes only. There will be a commercial economics issue if another added value option is introduced such as rendering.

Poultry processing waste is a suitable feed for meat rendering plants, and with special plant and equipment, this can also include feathers which produce a high protein meal. Fallen stock from poultry farming is presently handled in part by the same composter as is using the fish waste. The largest poultry farm in Tasmania has its own rendering plant, and another farm uses the Devonport Abattoir rendering plant at neutral cost, that is, there is no gate fee and no return. Besides offal, some fallen stock is accepted at the rendering plant, so long as it is fresh. Other dead birds are buried or sent to a composter. Feathers require special rendering facilities which are not available, so they go to landfill.

Biosludge is either tankered or dewatered and trucked away for land-spreading. Some dewatered sludge is also received at landfills. Because of the pathogen hazard and potential for heavy metals build-up, in some cases this is far from ideal. Managed in accordance with the established guidelines, land-spreading should be a viable disposal method, with some commercial value and an acceptable level of risk.


However, it is not easily monitored and this leaves room for error. Co-composting of biosludges reduces these risks and makes better use of the water and nutrient values.

Interstate Transport On average, 5 tonnes (<0.1%) of controlled wastes transported interstate from Tasmania by NEPM group between 2001 and 2006 were putrescible/organic wastes. However, shipments were only recorded in the 2002-03 financial year. There is generally no interstate transport due to the characteristics of wastes in this category.

5.8.4 Stockpiles

Storage of putrescible/organic wastes can only be done by refrigeration and so is not economically feasible and is not practised. This does not apply to biosludges, which are stockpiled in earthen bunds where necessary. This can give rise to odour and pest issues.


Abattoirs and fish and poultry processors generate much of the solid wastes in this category, about 20,000, 10,000 and 2,700 TPA respectively. Sewage treatment plants generate the bulk of the sludges. This amounts to approximately 25,800 TPA, taken as dewatered filter or centrifuge cake, retaining approximately 86% water. Commercial and domestic grease trap waste accounts for a further 3,500 TPA, mostly water contaminated with oils and fats, and organic solids. Most of this is presently transported to sewage treatment plants. A similar amount of septic tank sludge and nightsoil rightly ends up at sewage treatment plants.


Waste Type Estimated cost per cubic metre +/- % Explanation

K100 Animal effluent and residues $30 - $100 /m3 - -

K110 Grease trap waste - - - K130 Sewage sludge and residues including nightsoil and septic tank sludge

- - -


Rendering is by far the best solution for the disposal of meat abattoir and poultry waste, and provides high value products in the case of fish processing wastes, but may well require Government intervention to achieve the required increased capacity for the State. Direct land application is really only feasible for the liquid wastes, wash-


waters and blood, and for paunch manure. The bone and offal solids can only be rendered or buried and the latter is a waste of a resource. For fish processing waste and poultry fallen stock, composting is an alternative treatment and such facilities will have adequate buffer zones for odour and dust management. For fish processing waste the value adding due to rendering is quite exceptional. The fish oil market is healthy but not well served and should be lucrative. Biosludges should all be dewatered and chemically or thermally treated for pathogen reduction before use on the land. Subsequent land use needs to be supervised to ensure heavy metal soil contamination is avoided in a controlled manner. Operation to the applicable Approved Management Method (AMM) and guidelines for land application, should overcome the health, safety and environment objections; but there is little opportunity for monitoring such operations and they are not without significant risk. The suggestion by one major operator that solar UV exposure would provide disinfection of these soils indicates a case of misinformation. UV disinfection is fine for water (clear water), but requires light penetration which does not occur in solids. The cheapest thermal treatment is composting, and the high water content of these wastes is beneficial to the composting process. There has been tendered the argument that co-composting with green waste and other organic (carbonaceous) wastes is effectively only unacceptable dilution of the heavy metal contamination that is present in some biosludges. In comparison with the current practice of land spreading where the contaminants are ‘diluted’ directly with soil, putting it through a further pre-dilution, before the soil, would seem to have value. In addition, composting takes place under controlled conditions at a few registered locations and offers the opportunity for close and accurate monitoring of quality and quantity. An alternative that may be worth considering is sludge drying. This produces a dry pellet product and the water is recovered for return to the sewage treatment plant. The pelletised product is suitable for storage and therefore for seasonal use as soil conditioner, or as a solid fuel.

Grease trap and some other pit wastes are generally suited to composting, so long as they are blended with sufficient green-waste. Their water content is also beneficial to the process. According to the Environmental and Pollution Control (Waste Management) Regulations 2000, green and organic waste includes wood sawdust, shavings and chips from untreated and uncontaminated timber; untreated and uncontaminated timber; paper; agricultural materials of vegetative origin; silvicultural materials of vegetative origin; tree debris and stumps; diseased trees; grass; and weeds.

Septic tank sludges and nightsoil must continue to go to sewage treatment plants. Return to the past practice of direct land spreading, in view of the health and environmental risks, would be considered retrograde.



Rendering – meat abattoir and poultry processing wastes

Description: Offal, feathers and blood are delivered by closed truck and tanker to the rendering plant. They are received into hoppers and tanks and processed within the day they are delivered. The entire rendering plant needs to be securely housed and the equipment, operations and building ventilated to suitable odour emission control systems. The rendering processes are major consumers of heat energy and require several stages of fat/oil water separation and purification. The solid residues, called meal, are dried for sale as animal feed and fertiliser, also requiring considerable heat energy. Examples of Application: Products of the rendering process are tallow and various meals that are sold for animal feed and fertiliser. Where the tallow has insufficient value and is not processed for improved value it is burnt as fuel for the plant boilers. Due to animal health concerns much of the tallow and meal produced overseas is now burnt as power station fuel. Strengths:

• Effective use of nutrients and organic carbon by return to the soil. • A product from a waste treatment process, with some added value, meal, as animal feed.

Highly refined tallow is a component of many medical, pharmaceutical, cosmetic and toiletry products but the majority goes to soap and detergent manufacture.

• Control of pathogens, disease vectors, odours and putrescibles. • Production from waste of valuable products such as fish oil and tallow.

Weaknesses: • An expensive operation with relatively low return unless the tallow is valued, which is presently

the case in Australia, where we are free from the highly dangerous animal diseases that have crippled their production and use in Europe.


$4.5M for plant and buildings, including extensive emission controls

$1.8M p.a. for fuel and other consumables, operating labour, overheads and equipment maintenance

30%

12,000 TPA offal, bone and feathers, producing 6,000 TPA meal and 600 TPA of tallow at a value of about $4.2M pa including gate fees of $125/tonne

Rendering – fish processing waste A similar scenario would exist for a rendering plant for fish processing waste, but the return would be greater because of the high value of the fish oil extracted. Although it is a high value product, the oil yield is lower (about two fifths of that from meat waste/offal), however, under current market conditions the economics should be more than favourable.


On-site dewatering, chemical disinfection

Description: Biosolids, sewage sludge, treated on-site by dewatering to spadeable consistency and treated for disinfection, for example by treatment with quicklime, for landfill or for use as soil amendment, as 'dry' solid waste. It considerably reduces the health and environmental risk associated with direct handling of pathogenic materials. Dewatering is by filtration with pressing (belt press filter), or by centrifuging (continuous decanter centrifuge), to about 15% dry solids level (85% water content). Examples of Application: Sewage sludge from an activated sludge aerobic treatment process is thickened and dewatered, employing flocculating and coagulating chemicals, using a belt filter or decanter centrifuge. The dewatered sludge, containing still approximately 86% water (14% dry solids content is usual) is further stabilised and is disinfected, by treatment with quick-lime. The resulting solid waste is then suitable for use as a soil amendment in agriculture, particularly on acidic soils, provided testing and record keeping is employed to control ‘plant available’ heavy metals build-up. Strengths:

• Effective use of nutrients and organic carbon by return to the soil. • A product from a waste treatment process, with some added value • All accomplished safely before the resulting solid waste goes off-site

Weaknesses: • Requires off-site control of the soil conditioner by a statutory or other regulatory body (for heavy

metals).


$1.2M

$160,000 p.a. not including sludge dewatering and off-site disposal

30%

7,500 TPA dewatered sludge (1000 TPA dry basis) stabilising and disinfecting chemical sludge treatment for a 125,000EP STP already practising dewatering.


On-site dewatering, off-site co-composting

Description: Biosolids / sewage sludge is treated on-site by dewatering to spadeable consistency and carted off-site for co-composting with other putrescibles and green-waste. Examples of Application: Sewage sludge from an activated sludge aerobic treatment process is thickened and dewatered, employing flocculating and coagulating chemicals, using a belt filter or decanter centrifuge. The dewatered sludge, containing still approximately 86% water (14% dry solids content is usual) is trucked (covered and non-draining skip or tray) to a composting plant. The composting plant may be of the intensive fully enclosed type in which case it can handle the sludges with minimum green-waste addition, or an open windrow facility where the sludge is a minor component of the feed. Some STP’s do not have sludge dewatering facilities and it would be possible to provide a portable dewatering service that would visit several plants. The sludge can be readily stored between service visits in an aerated sludge digestion lagoon or tank. Strengths:

• Co-composting is a safe and secure disinfection process, provided the raw sludge is handled in a suitably controlled fashion.

• Any heavy metals content of the sludge is diluted with other organic carbon contributions. • The use of compost on the land brings with it the expectation that the farmer is employing

nutrient and other soil condition testing which can readily include heavy metals tracking. • Water is more beneficially used in composting than in direct land spreading where the water

may or may not be needed at the time and in the quantities applied. • Compost improves water retention in the soil, another water conservation measure.

Weaknesses: • Transport and processing of dewatered but otherwise untreated biosludge has an attendant

environmental and health risk that requires good management.


$3.2M including cost of 2.5 ha rural site, road access, weighbridge, buildings & equipment, & a mobile dewatering unit at $0.85M

$0.8M p.a. including labour, fuel and power, but not transport to and from the site

30%

Co-composting of 7,500TPA biosludges, 1,500TPA grease trap waste and 20,000TPA greenwaste. Gate fees = $1.5M p.a., compost value 19,000TPA at $40/t. Including provision of the dewatering service.

On-site dewatering service


$1.2M mobile sludge dewatering unit and trailer, plus sludge cake truck/trailer-mover

$0.4M p.a. labour, power, fuel and equipment maintenance

30%

To produce 1.2 t/hr (2,500 TPA) dewatered biosludge, trailer mounted unit with two persons operator/driver. Charge $25 per tonne of dewatered sludge, delivered to composting plant assuming 100km round trip.


Sludge drying – thermal process

Description: Biosolids – particularly sewage treatment plant sludges are generally dewatered on-site, either mechanically, as discussed earlier, or on open-air sludge drying beds. The latter are becoming less acceptable so that the sludges produced are now mainly just dewatered (14% solids) rather than dried (85% dry solids). There are drying processes, as simple as solar drying on huge drying ponds or ‘beds’ and as complex as the drying and pelletising plant being constructed at the Barwon Water sewage treatment plant in Victoria. The Barwon drying and pelletising process is in two trains each comprising a natural gas fired heat transfer oil heater and a multi-disc dryer. The dried material is recycled to be mixed with more wet dewatered sludge and builds up to small hard pellets, without dust and odour free, which are cooled before storage. Off-gases are scrubbed and condensed and the extracted water returns to the STP. The scrubbed condenser off-gas and the pellet cooler exhaust, via a bag-filter dust collector, are then destroyed (odour control) in a regenerative thermal oxidiser (afterburner with heat exchanger for heat recovery). Scrubber/condenser cooling water is tertiary treated sewage and is simply returned to the STP for reprocessing. There are other drying processes of a similar nature, the important aspect is the production of a hard, dry, none-friable pellet that is safe to store, transport and use. Examples of Application: On-site (STP) solar drying is generally being phased out because of site contamination and odour and fly nuisance issues. Off-site land farming has taken over, but that further complicates the issue of land contamination (HM’s). The harvested dried sludge still requires disposal and still contains HM’s and pathogens although the latter are considerably reduced by solar exposure. The intensive thermal drying and pelletising process used at Barwon Water will produce a sterile material suitable for storage and use as soil amendment or fuel, ALCOA’s Anglesea brown coal fired power station fuel in the case of Barwon. Strengths:

• The pellet product can be stored more readily on-site or carted off-site (reduced volume, sterile and easy to handle) as a feedstock for further processing.

• It has value as a fuel and is nearly energy neutral with the drying energy about 1,3 times the resultant fuel energy recovered.

• It has value as a soil amendment applied direct (carbon and minor nutrients) or as a bulking or blending agent for fertilisers.

• It is a cheaper process than most other ‘satisfactory’ sludge management options where these values can be realised.

Weaknesses: • Sludge drying in any form cannot compete if direct land application or landfill disposal, locally

or within easy access, are acceptable and available. The usual driving forces are environmental and the cost of long distance haulage of dewatered (86% moisture) sludge.


+/- % Explanation

N/A N/A N/A N/A


Anaerobic digestion

Description: A process which comprises - maceration of solid wastes and sludge preparation and blending, followed by anaerobic digestion to produce methane rich fuel gas. Residual sludge is then more readily dewatered and can still be composted, with resulting wastewater going to sewer or for use in composting. Much higher energy recovery than with landfill gas collection, and therefore compares favourably even with the minor energy consuming aerobic composting. Examples of Application: [a] On-site anaerobic digestion of primary separated sewage solids and waste activated sludge (sludge digestion) at the STP. [b] Anaerobic composting in covered windrows or in steel or concrete fabricated ‘fuel cells’ to produce fuel gas much more efficiently than by landfill gas gathering. Strengths:

• Energy recovery and improved energy recovery efficiency (landfill gas gathering is a very low efficiency procedure and takes a long time to achieve stabilised waste condition.

• Rapid utilisation of energy component of the wastes. Applicable to sewage sludges, primary and secondary, and to bio-solids, food and vegetable processing wastes, but not to abattoir wastes (protein nitrogen generates too much ammonia for most applications).

Weaknesses: • Requires on-site or over the fence energy utilisation or expensive low efficiency energy

conversion to electric power.


$4M including cost of 2.5 ha rural site, road access, weighbridge, buildings and equipment

$0.8M p.a. including labour, fuel and power, but not transport to and from the site

30%

Anaerobic co-composting of 7,500TPA biosludges, 1,500TPA grease trap waste and 20,000TPA greenwaste. Gate fees = $1.5M p.a., compost value 19,000TPA at $40/t, energy recovery as electric power from a gas turbine $0.4M p.a.

5.9 Organic chemicals 5.9.1 Description / Definition

Considers: M100 Waste substances and articles containing or contaminated with polychlorinated biphenyls (PCBs), polychlorinated naphthalenes (PCNs), polychlorinated terphenyls (PCTs) and/or polybrominated biphenyls (PBBs) M150 Phenols, phenol compounds including chlorophenols M160 Organohalogen compounds including chlorophenols M170 Polychlorinated dibenzo-furan (any congener) M180 Polychlorinated dibenzo-p-dioxin (any congener) M210 Cyanides (organic) M220 Isocyanate compounds M230 Triethylamine catalysts for setting foundry sands M250 Surface active agents (surfactants), containing principally organic constituents and which may contain metals and inorganic materials M260 Highly odorous organic chemicals (including mercaptans and acrylates)



For data relating to present waste generation volumes, please refer to Appendix [5]. Low annual quantities from a handful of generators, mostly M100 PCB-related material such as capacitors, oil, solvent, transformers sent interstate. There is an estimated decrease over time as large owners dispose of their contaminated oil.


Practices in Tasmania According to DTAE’s Controlled Waste Inventory (2004/05), the dominant methods reported for the management of organic chemicals were interstate transport (73% by quantity), landfilling (15%) and storage on-site (8%). Interstate Transport According to NEPM records for outgoing interstate movements of controlled wastes between 2001 and 2006 (by NEPM waste group), on average, organic chemicals comprised 5% of movements (approximately 306 tonnes). The majority of shipments were capacitors, oil solvent, transformers and other material contaminated with polychlorinated biphenyls (PCBs) or code M100. The DTAE Controlled Waste Inventory reports that more than half of M100 waste is destined for energy recovery in Victoria, and the most of the remaining waste is destined for recycling facilities in the Australian Capital Territory and Victoria. A small percentage is destined for chemical/physical treatment at a treatment provider in Queensland (which will continue to occur, as it is the only treatment plant for high-concentration PCBs in Australia).

Other organic chemicals that are sent interstate include cleaning compounds, flocculants, surfactants and water treatment chemicals (categorised as M250). This material is transported to Victoria for energy recovery or chemical/physical treatment.

5.9.4 Stockpiles

Minimal, mainly temporary storage of PCB-related material awaiting interstate transport for treatment, or use as an alternative fuel source.


‐ Mining sector (electrical equipment containing PCBs) ‐ Electricity generators and distributors



Waste Type Estimated cost +/- % Explanation

M100 PCB (scheduled) waste

$15 - $25 /kg small loads e.g. capacitors -

Includes transport and handling to mainland. Chemical, biological or thermal destruction, or re-use in management of other wastes.

Category M non-scheduled waste (organic chemicals)

$650 /t drummed waste

- Includes transport and handling to mainland (Weight for charging includes containers).


Small quantities of a variety of chemicals mean that these wastes in general will have to go into a larger stream or market, interstate. One local possibility is to incorporate these wastes into a cement kiln as feedstock, or to inject them as a liquid stream or a gas entrained stream at the firing (high temperature clinkering) end of the kiln. This is an added complication for the cement plant and will require some incentive or collaboration with a waste management company to take the responsibility for producing and applying the injectant in an acceptable form. We are advised that depending upon the volumes, compatibility, and contents of PCN, PCT and PCB waste, some of these materials should already be able to be incorporated into the solvent based fuel manufactured for cement kilns. When firing of solvent-based fuel begins at the cement kiln in Tasmania, it will be under a permit for only extremely low PCB content; however, there should be review of these limitations as the process proceeds. Cement kilns are capable of destroying reasonably high PCB levels. This would involve an extensive series of trials or demonstration with appropriate stack testing – a complicated process because of the dioxin testing which would be involved.



Cement kiln injection

Description: Very high temperature thermal destruction, applicable to low level PCB waste streams and other organo-chlorine compounds, such as pesticides. Fuel value is of benefit to the kiln, water is a considerable handicap. Examples of Application: Injection of low level (less than 5ppm) PCB-contaminated oil as supplementary kiln fuel. Note that in some states, such contaminated oils can also be blended down with other waste/recycled oils to below 2ppm PCBs and then used as fuel in industrial boilers and metallurgical furnaces as well as in cement kilns. Strengths:

• Good, safe and assured destruction of these organo-chlorine compounds. • Also suited to destruction of other organic and inorganic waste streams with some fuel value.

Weaknesses: • Water is a hindrance. • The most lucrative (most highly contaminated) waste stream is slowly reducing in volume and

PCB content so that the market is a declining one. • There remains in Tasmania very little of these wastes and they are not consistent in quantity or

composition but the same process could be applied to any oily wastes and to those with excessive heavy metal contamination.


$1.2M assuming free on-site access at the kiln for the plant and storages

$250,000 pa operating costs plus kiln access charges of say $100,000 p.a.

50%

500 TPA of phenolics, and organo-chlorine compounds including say 20% of PCB-contaminated oil, worth $2.3M p.a. (at present PCB contaminant levels) for destruction

Processing or blending for dilution and biological treatment

Description: Often the last stage of treatment using injected bacteria culture or worms or by land-farming, but may also be a liquid suited to some form of bio/sewage treatment (for non-oily and water soluble wastes) on-site, or offsite at an existing sewage treatment plant. Examples of Application: Wastes with low toxicity level, or dilute, or pre-treated (for on-site values recovery) wastes, reduced to low concentration in water. Strengths:

• On-site simple and robust operation if properly applied to a consistent waste stream (hardly the case in Tasmania).

• Diluted with general sewage if disposed of at a STP making these streams then easier to treat biologically.

Weaknesses: • Where the waste streams are variable it can become a much more complex process often

requiring services of a laboratory. • Very little of these wastes and not consistent in quantity or composition, so not considered in

any more detail at this stage, but certainly requiring further consideration even if only with respect to interstate transport.


+/- % Explanation

N/A N/A N/A N/A


5.10 Solid / sludge wastes requiring special handling 5.10.1 Description / Definition

Considers:

N100 Containers which are contaminated with residues of substances referred to in this list N120 Soils contaminated with a controlled waste N140 Fire debris and fire washwaters N150 Fly ash N160 Encapsulated, chemically-fixed, solidified or polymerised wastes N190 Filter cake N205 Residues from industrial waste treatment/disposal options N220 Asbestos N230 Ceramic-based fibres with physio-chemical characteristics similar to those of asbestos



Large quantities of solid/sludge waste material requiring special handling are generated by a variety of sources, and these quantities are expected to increase in the short-term on as controls tighten and production levels increase.


Practices in Tasmania Based on the characteristics of waste materials in this category, landfilling appears to be the dominant management method in Tasmania.

According to the Landfill Sustainability Guide, asbestos must be transported and disposed under strict conditions. All sites used for the disposal of asbestos waste are required to have permits for this purpose, and removal, transport and disposal must be in accordance with relevant environmental and occupational health guidelines. Presently, chemically contaminated containers can be deposited at council facilities only if triple rinsed. This is surely difficult to control. They are then shredded and/or baled for collection and eventual recycle of the plastic. This is an imposition on the waste generator who is inclined not to bother, but to dispose of the containers without rinsing, to a landfill. This represents a significant environmental and conservation (waste of resource) issue. Contaminants range from pesticides, hydrocarbons, antibiotics, fuels and chemicals.

An operation in Tasmania’s North West currently treats level 3 and 4 hydrocarbon contaminated soil, using a bioremediation technique using a bacterial process to make the waste safe for landfill disposal. The facility treats a large portion of the


State’s hydrocarbon contaminated soil from sources such as industrial sites, fuel storage areas, service stations. A small volume of the waste received is PCB-contaminated and requires higher level treatment at a Queensland facility.

Interstate Transport Solid and sludge waste is generally managed within Tasmania. According to NEPM records for outgoing interstate movements of controlled wastes between 2001 and 2006 (by NEPM waste group), on average, soil/sludge waste comprised <0.1% of movements (approximately 0.8 tonnes).

5.10.4 Stockpiles

There are several large stockpiles of items such as filter cake from chemical and metallurgical processes, contaminated containers, soils, concrete, asphalt and demolition waste. These appear to be well documented and they are in process of being evaluated for disposal options. Some may take a long time to manage simply because of the volume, expense or degree of difficulty involved, but, so long as they are securely stored this should not be a major problem. There will always be a time when the disposal option becomes more favourable than the storage option; positive drivers such as - land value, re-development opportunity, and negative drivers like containment problems, leachate and ground-water issues and site management costs.


‐ Manufacturing sector ‐ Mining and minerals and metals processing ‐ Government administration (local councils) ‐ Agriculture sector ‐ Health services


Waste Type Estimated cost per tonne +/- % Explanation

Category N Solid/sludge waste requiring special handling

$30 - 350 /t - Chemical fixation and secure disposal.

N220 Asbestos $50 - $120 /t - Delivered double bagged and buried securely at landfill.


Where there are metal values involved there will come a time when the value exceeds the storage maintenance cost, or where these costs become too expensive to bear and it is better to realise some value rather than incur further cost. Metal values fluctuate, sometimes wildly, and caught at the right time today’s waste may well be tomorrows ‘ore’.


Some wastes have value as a bulking or blending agent. There are synergies with respect to the co-disposal of wet (say filter cake) and dry (damp asbestos) wastes, possibly with a further addition such as cement powder or fly-ash to reduce contaminant leaching to a satisfactory extent.


Asbestos – wet and bagged

Description: Handled and transported wet and double bagged, immediately buried, away from disturbance in the landfill and kept covered and secure. Examples of Application: Usually a part of demolition waste but separately handled, delivered and disposed to maintain integrity of containment (not puncturing the plastic bags either during the handling, transport and burial processes). Strengths:

• Inert and quite safe in a landfill provided it is handled with adequate caution and care. • This is present practice and needs little improvement, just tighter control. • However, there could be better ‘use’ made of this inert mineral waste, by incorporation into

other waste stream management options. Weaknesses:

• The danger will come if it ever has to be un-earthed. It should be identified by records and markers for such a future eventuality, but generally is not.

• This is a significant future danger, but this can be overcome by incorporating this waste into other waste streams that would benefit from blending with an absorbent, and the asbestos may be thus incorporated into a more dense and stable form that would not present a danger in the event of future disturbance.


+/- % Explanation

N/A N/A N/A N/A


Metallurgical process residues

Description: Highly toxic heavy metal process residues, eg cadmium and mercury. Return to process or ship to other processor, is the preferred option every time. There are concerns about providing wastes containing these metals for recovery of the metals because they are both hopefully being phased out of production because they are so hazardous to human health. Examples of Application: Mercury wastes shipped interstate in high security containers for treatment and disposal at a secure site. Cadmium containing residues shipped overseas to cadmium ore processing plants, or to other (larger) cadmium waste generators for on-forwarding when quantities are sufficient. Strengths:

• Takes the mercury (toxic heavy metal) out of circulation • It is securely encapsulated, entombed and is traceable for future reclamation if desired,

perhaps when safe applications and processes are available. • Tasmania could have a suitable site, away from surface water and significant groundwater

sources, with a clay reserve for lining, readily secured and geologically stable. • Wherever these wastes are transported they must be securely packaged so sea-freight should

not be an obstacle. • With a local source of waste requiring secure disposal such as metallurgical wastes, and with a

backlog and/or a continuing source, this should be regarded as a real business opportunity. Weaknesses:

• There is always going to be some transport risk. • Long-term security maintenance requirement. This must be included in all technical and

financial planning.


$4M with site purchase, development of roads, fences, and drains and excavation & stockpile of clay

$0.75M p.a. 50%

Repository for 10,000m3 of waste (say 1 ha of secure landfill area with 2 ha of secure perimeter, accepting 250m3 pa of waste, occupying 500m3 with packaging, worth about $1.5M p.a. With access to laboratory and geo-hydro-civil consultants.


Preserved and otherwise contaminated timber

Description: Chemically treated wood and other contaminated timber. Creosote, copper and arsenic impregnation is leachable and as such the wood must be disposed in a controlled landfill. Or recycled or re-used as a preserved timber. Examples of Application: Some larger objects can be machined into new smaller products requiring preserved timber e.g. fence posts. There should be opportunity for hogged (aggregate sized) wood of this type to be incorporated into polymer bonded products where the preservatives will be of some value and yet will be chemically or mechanically bonded to reduce leachate issues or other spread of the contaminants. Strengths:

• Good secondary use for treated wood which is otherwise difficult to dispose of and requires high level secure landfill, and where there is always the potential for a fire which would release these contaminants into the environment in a hazardous manner.

Weaknesses: • Highly toxic to plant personnel who must be fully protected in the processing operations. • Contaminated residues/sawdust and discards must be safely disposed (usually requiring

fixation) – because with the much increased surface area they will leach at a faster rate when stockpiled.

Est. Capital Cost Est. Operational Cost +/- % Explanation N/A N/A N/A N/A

5.11 Clinical and pharmaceutical wastes 5.11.1 Description / Definition

Considers: R100 Clinical and related wastes R120 Waste pharmaceuticals, drugs and medicines R140 Waste from the production and preparation of pharmaceutical products

‘Clinical and related waste’ is defined by the Approved Management Method for Clinical and Related Waste (DPIWE, 2005) as being a collective term applied to materials generated by the health care industry and other clinical settings, and which have the potential to cause infection, injury or public offence. It comprises a number of subcategories, each with their own handling and/or treatment and disposal requirements.

‘Clinical waste’ includes infectious or potentially infectious waste, further categorised as: pathology and sampling waste; anatomical waste and body fluids; animal tissue and carcasses; and other infectious waste. It also includes sharps.

‘Related waste’ includes: cytotoxics; pharmaceuticals; chemical waste; radioactive waste. Cytoxic waste refers to material that is contaminated with a cytotoxic drug (i.e. one that is capable of impairing, injuring or killing cells) during the preparation, transport or administration of chemotherapy.


‘Pharmaceutical waste’ includes antibiotics, endocrine disrupters, medications, whether in vial, ampule, tablet, inhaler or capsule form arising from: pharmaceuticals returned by patients or discarded by the public; pharmaceuticals past their expiry date; pharmaceuticals discarded by the manufacturer due to failed quality control specifications or contaminated packaging; pharmaceuticals no longer wanted or required by the facility; waste generated during pharmaceutical manufacture or administration and; waste otherwise contaminated by pharmaceuticals.


1998 DTAE

1999 DTAE

2001 DTAE

2002 DTAE

2003 DTAE

2004 DTAE

2005 DTAE

2006 DTAE

2407 4837 4766 2096 6134 6866 7290 6087

It is apparent from discussions with waste transport businesses that the above figures are not tonnes from weighbridge reports, but volumes (kL or m3) estimated from vehicle capacities. We have therefore applied bulk density estimates in order to arrive at a tonnage estimate for the purposes of this study, as follows – Clinical and related wastes 6689 m3 pa based on the average of 2005 and 2006 figures

120 kg/m3 bulk density allowing for bagging and binning

803 TPA at 0.47M population = 1.7 kg/capita/annum Pharmaceutical waste 4.3 m3 pa (average of 5.6 and 3.0 m3 pa for 2006/7) 650 kg/m3 bulk density, stacked packaged containers 2.8 TPA average over these two years. The clinical and related waste quantities have been compared with clinical and related waste generation data for several other Australian States, for example – 1.2 kg/capita/annum for Victoria 2001 1.1 kg/capita/annum for Perth city 2004 Using this data, an average of 1.1 kg/capita/annum is used to arrive at a figure of - 517 TPA for a comparative figure for Tasmania Compared with the national average of 2.4 beds per 1000 population, there are 3.4 beds per 1000 in Tasmania which would suggest a weighting factor of 1.4 might be applied to this figure giving –

730 TPA as a corrected figure for clinical and related waste for Tasmania

Depending on the hospital policy with respect to the use of disposable versus reusable instruments, and the related packaging, the waste per occupied bed figure


for Australia varies from 1 to 1.25 kg/bed/day, with about 1600 hospital beds in Tasmania and assuming occupancy of 100% this equates to 1,600 kg/day to 2000kg/day or about 580 to 730 TPA Clinical and related waste quantities (R100) are not by any means solely related to hospitals, medical and dental clinics, aged care facilities and animal health and research facilities also contribute significant quantities. However, these facilities would generally generate waste in proportion to the population with similar corrections for ageing. It is proposed that for the purposes of this study the annual waste generation rate for clinical and related R100 waste for Tasmania be taken as 800 TPA. There is no evidence to suggest a decrease in generation in Tasmania in the future, as clinical and pharmaceutical waste is likely to increase due to both an increase in the demographic proportion of aged people in Tasmania and the increasing use of health care services for a broad range of applications. However, it is worth recognising that while total volumes may increase in the future, the capacity may also become available to reduce the contamination of clinical waste with uninfected materials by improved education in health care establishments. Waste audits and training programs in hospitals and other large generators of clinical and pharmaceutical waste is required.


Practices in Tasmania According to the Controlled Waste Inventory (DTAE, 2004/05), approximately 89% of reported clinical waste is sent to landfill at the current four landfills with Category 2 status, throughout the State. The remainder, liquid wastes such as body fluids and cytotoxic wastes and body parts, are handled appropriately by discharge to sewer, transfer to interstate destruction facilities, and cremation. It is doubtful that pharmaceutical wastes in the main would be going to landfill, but rather would be handled in the same way as cytotoxic wastes being transported interstate for thermal destruction. It should be noted that all clinical and related wastes should be managed in accordance with a method approved by the Director of Environmental Management. Guidance for suitable management of such wastes is provided in the “Approved Management Method for Clinical and Related Waste” (DPIWE, 2005). Copping Landfill: Southern Waste Solutions is contracted to take all of the Tasmanian Department of Health and Human Services’ (DHHS) waste employing a disinfection process they have independently developed and which has been accepted by the DHHS and is approved by DTAE and covered by their Approved Management Method.


A chemical disinfection plant will be constructed at the Southern Waste Solutions transfer station at Lutana and is scheduled to be on-line by June 2008. In the interim the Copping landfill is accepting untreated clinical waste, with approval, and is burying this in holes excavated within the municipal waste fill.

Remount Road Landfill: Clinical waste does not come to this site anymore. In all instances body parts should be and are being destroyed at a crematorium. Port Latta Landfill: This landfill took all of the clinical waste until recently when DHHS contracted this to the Copping Landfill operator. Dulverton Landfill: This facility does not accept clinical and related waste but as with Port Latta the site and its development, and the licensing, would allow this landfill to take the waste.

Interstate Transport According to NEPM records for outgoing interstate movements of controlled wastes between 2001 and 2006 (by NEPM waste group), on average, clinical and pharmaceutical waste comprised <1% of movements (16 tonnes).

Only a small volume of this waste group (3%, based on waste transport certificates 2002-2005) is transported interstate for treatment or disposal. Presumably this is the 2.4 TPA (2005/6 average) of pharmaceuticals listed in the WTB returns plus the cytotoxics which, based on Melbourne clinical and related wastes, would be about 1.5% by weight of the R100 waste stream or about 12 TPA. These shipments are destined mainly for incineration.

5.11.4 Stockpiles

There are limited reports of stockpiling of clinical and pharmaceutical waste in Tasmania. The majority of waste of this kind is disposed to landfill, and the remainder, presumably the pharmaceutical and cytotoxic portions, is shipped interstate for thermal destruction. The remaining waste stream must be disposed without delay as it would require refrigerated storage and none is available. The Approved Management Method for Clinical and Related Waste (DPIWE, 2005) contains standards applying to storage areas within a healthcare facility or collection premises where clinical and related waste is accumulated awaiting collection by a contractor, and treatment and disposal facilities. Off-site bulking/transfer facilities accepting more than 100 tonnes per year of clinical and related waste for storage must be referred as Level 2 activities under EMPCA.



Hospitals These vary from large public and private hospitals with operating theatres and emergency wards, to smaller local community facilities. There are approximately 1600 beds total, ranging from 501 at a major hospital in Hobart to 96 at a regional hospital in Latrobe. Medical centres and clinics There are medical clinics and centres all over Tasmania that generate small volumes of clinical and pharmaceutical wastes. These generate waste that is included in the clinical and related category, infectious or likely to be so. Veterinary surgeries There are veterinary surgeries in most parts of Tasmania that generate very small volumes of clinical and pharmaceutical wastes. These surgeries can also generate wastes that are infectious, or likely to be so. Other sources Commercial, educational and industrial-based first aid stations, blood banks, universities, tattooists, mortuaries, and testing and research laboratories also generate these wastes. The growing home health care sector is another source of clinical and pharmaceutical waste, which may be disposed into the general waste stream. Pharmaceutical wastes are generated throughout all of these facilities, mainly out-of-code stock. These are small quantities compared with those generated in the manufacturing sector, where quality control rejects including empty, surplus and out-of-date packaging must be destroyed for commercial and security purposes.


Waste Type Estimated cost per cubic metre +/ - % Explanation

R100, R120, R140 Clinical and pharmaceutical wastes

$50 - $65 /m3

At 120 kg/m3 = $420 - $550 /t At 90 kg/m3 = $560 - $720 /t

- -

5.11.7 Opportunities for Reduction, Re-use, Resource Recovery or Waste Exchange

Opportunities for re-use and resource recovery of clinical and related waste are particularly limited, due to the potential for infection. Waste reduction mainly involves reusable items which require high level disinfection. Hospitals use autoclaves and sterile containers for this. It is very labour intensive and therefore expensive compared with the use of disposable items supplied in disposable sterile packaging.


The disposable items which have the potential for replacement with reusable ones include:

‐ Blueys’ (plastic liners) ‐ Dressings trays/ suture trays ‐ Suction systems ‐ Drainage bottles ‐ Disposable theatre wrap ‐ Plastic aprons ‐ Bed pans ‐ Serviettes ‐ Tray covers ‐ Disposable batteries ‐ Paper hand towel

There are also significant opportunities for health care facilities to recycle non-contaminated waste otherwise destined for landfill, such as glass, plastics, and metal containers.

Non-contaminated wastes from health care facilities such as glass, plastics, paper and ferrous and non-ferrous (aluminium) metal containers should be separated from the total waste stream at source and segregated for recycling where possible. However, where contamination may have occurred, these items must be managed as clinical and related waste. Education is the key to promoting sustainable management of the clinical and pharmaceutical waste stream, as well as waste audits and on-site ownership.



High temperature incineration

Description: Modern thermal destructors with high efficiency fluegas scrubbing (wet or dry) to tight world class emission limits should be a first consideration. In the past every hospital had its own incinerator but with the advent of tighter emission limits and greater controls small units could not be economically upgraded or replaced. The scale of operation even for one facility for the waste of the whole of Tasmania is still small and plant and operation will be expensive (no economies of scale benefits). The modern process achieves 95% volume reduction, only ash and residues need to go to controlled landfill with sewer discharge or encapsulation for a small amount of scrubber residues. Examples of Application: A single dedicated Best Available Control Technology (BACT) equipped incineration facility could be envisaged for Tasmania in view of the fact that a single processing and landfill situation is already contemplated. It would generate very little NOx and other public health or environmentally sensitive emissions. Strengths:

• Volume reduction of waste is >95%. • Weight reduction is >90% • Reduced greenhouse and ozone depleting emissions compared with landfill, (almost zero

methane and one twentieth of the equivalent CO2) • To put the emissions question into context - Less CO2 emission than 3 cars doing

20,000km/year and less NOx emission than 4 medium size diesel trucks doing 100,000km/yr • BACT technology for emissions such as acid-gases, PAH’s and dioxins. • Can handle all of the quarantine and security waste as well as the clinical, cytotoxic and

pharmaceutical waste. Weaknesses:

• Difficult to site because of ill-founded environmental concerns. • Higher cost for smaller capacity is a problem for Tasmania. • Increased road transport to a single facility, but this is the same as is contemplated for the

accepted Southern Waste Solutions proposal, may be less by being more central.


$1.6M $1.01 per kg 30% 1500TPA, 250kg/h, 5.5 dpw, 24 hpd, 87% availability

Autoclave sterilisation, shredding and landfill

Description: 30% volume reduction, poor compaction. Needs controlled assurance of heat penetration, requiring automated controls, insertion of probes and attachment of temperature and moisture sensitive tags, control sampling and laboratory analysis, and manual inspections. Generates considerable odour and some liquid reject (to sewer). Examples of Application: For biomedical waste only, not for cytotoxics or pharmaceuticals. May be suitable for some quarantine waste. Strengths:

• Lower cost than incineration for some wastes. Weaknesses:

• Generates considerable odour, even in the disinfected waste going off-site. • May not be suitable for some quarantine waste. • Not suitable for cytotoxics and pharmaceuticals.


+/- % Explanation

$1.1M $0.60 per kg waste 30% 1000 TPA, 200kg/h CRW but not cytotoxics or pharmaceuticals, some quarantine waste maybe.


Microwave sterilisation, shredding and landfill

Description: 30% volume reduction, poor compaction. Needs controlled assurance of heat penetration, requiring automated controls, insertion of probes and attachment of temperature and moisture sensitive tags, control sampling and laboratory analysis, and manual inspections. Generates considerable odour and some liquid reject (to sewer). Examples of Application: For biomedical waste only, not for cytotoxics or pharmaceuticals. May be suitable for some quarantine waste. Metallic objects must be screened-out. Strengths:

• Lower capital cost. Weaknesses:

• Generates considerable odour, even in the disinfected waste going off-site. • Not be suitable for some quarantine waste. • Not suitable for cytotoxics and pharmaceuticals.


$1.2M $0.60 per kg 30% 750 TPA, 150kg/h CRW but not cytotoxics or pharmaceuticals, some quarantine waste maybe.

Shredding, chemical disinfection and landfill

Description: Shredding, chemical disinfection and landfill, with rejected liquids to sewer. Waste is then readily compactable for disposal. 40 to 70% volume reduction on compaction, some emission and effluent issues. Hypochlorite, or lime +/- hydrogen peroxide (Matrix Process) are used. Examples of Application: For biomedical waste only, not for cytotoxics or pharmaceuticals. May be suitable for some quarantine waste. Requires considerable ongoing sampling and laboratory testing to ensure satisfactory performance. Achieves only a partial kill of pathogens, reducing health and environment risk to what is today regarded as a sufficient degree and these are moving goal-posts. Strengths:

• Lowest cost. Weaknesses:

• Not suitable for some quarantine waste. • Not suitable for cytotoxics and pharmaceuticals. • Chemical residues in the waste going to landfill, and some leachate may be objectionable.


+/- % Explanation

$1.0M $0.45 30% 1000 TPA, 200kg/h CRW but not cytotoxics or pharmaceuticals, some quarantine waste maybe.


5.12 Waste tyres 5.12.1 Description / Definition

Considers: T140 Tyres

Includes waste tyres generated from public, commercial, transport and industrial use.



The Waste Transport Business (WTB) tracking and reporting system in Tasmania yielded an average figure of 1,200 TPA for this category. However, this is far short of the estimates developed from the NEPM submitted quantities for other Australian States, based on population and mileage statistics, which yields a figure of 3,540 TPA or 354,000 tyres at an average of 10kg each. Tyre waste from mining and other heavy industries is not included in the figures above. These very large tyres require separate consideration and certainly, to-date, are mainly stockpiled on operating and abandoned mine-sites. Some are used on-site as road furniture (for example, road markers, traffic islands, giant bollards for equipment protection). Most tyres of this nature can be retreaded several times, provided the carcass is undamaged.


Practices in Tasmania There is either a $5 levy on the purchase of new tyres or a disposal charge (at depot) for disposal of used tyres. Depending on just how this is managed it may be an incentive or disincentive for responsible disposal. If the $5 is applied to the management of this waste steam, then it can be in part applied to their cartage and temporary but long-term storage, whilst awaiting a satisfactory end use. The remainder might be best banked for a fund to assist any future recycle innovation. The existing levy system is not catering for a large proportion of the commercially traded tyres, unaccounted for at landfills, suggested to be two thirds of the total waste tyres. A more efficient procedure is certainly warranted, including the encouragement of competition because this will assist in establishing an honest and equitable process. Current practice, involving one licensed operator, involves stripping out the cord and cutting each tyre into at least four pieces so that they can go to landfill. If this is consuming the $5 per tyre charge, presumably including the gate fee at the landfill, then the money might be better spent in other ways.


Launceston’s Remount Road Waste Depot appears to be taking the majority of the tyres arriving at a final disposal facility, but this accounts for only about 10% of the waste stream. Apparently there is a need for a structure that will encourage the more complete collection of tyres.

Interstate Transport Except for the retreading stream, it is unlikely that used tyres from Tasmania will find a use in other Australian States and Territories. Interstate facilities already have large volumes to manage.

5.12.4 Stockpiles

With only about one third of the waste tyres (excluding those from mining sector) being processed to go to landfill, there must be significant volumes stockpiled around the State, at best estimate, up to 2,400 TPA or 240,000 tyres per annum. Users of whole tyres such as pony clubs, marinas and farms are near saturation, but the embankment and retaining wall applications will continue. Significant volumes are often stockpiled because the cost of appropriate treatment and disposal e.g. shredding is too expensive.

According to the Landfill Sustainability Guide, waste tyres may be stockpiled and managed separately provided the number does not exceed 500 and stored in individual lots of 150 or less. Disposal of tyres is allowed only at landfills that have approval from the Regulatory Authority.


‐ Mining industry ‐ Motor vehicle retailing ‐ Public consumption ‐ Transport industry


Waste Type Estimated cost +/- % Explanation

T140 Tyres

car/motorcycle $3.50 - $8.50 /tyre light truck/4WD - $5.50-$7 /tyre truck - $11-$22 /tyre heavy vehicle $16-$33 /tyre tractor $26-$55 /tyre shredded $45-$60 / tonne

%30 -


Significant opportunities exist for the recycling and reprocessing of waste tyres and tyre waste in Tasmania:


Re-use: No doubt there is further scope for tyre re-use by retreading. One issue is that some imported tyres are cheaper than retreads, however, these tyres at the end of their ‘first’ life are often not acceptable for retreading. To have a quality passenger vehicle tyre retreaded is around 20% cheaper than purchasing a quality new tyre and the life is the same (the tread is the same in profile and material). A good tyre casing can be retreaded 3 to 5 times, making economic sense. Truck tyres are more often than not retreaded, and in this case, the cost saving can be more like 30%. Recycle: There is apparently only one company involved in collection, transport and disposal of waste tyres throughout Tasmania. Disposal is to the Remount Road Landfill. Current controlled waste treatment/disposal facilities in Tasmania are not entirely satisfactory and it appears that much of this waste stream is not arriving at the disposal site. While tyres are a controlled waste, the shredded and chipped rubber derived from tyres should not be so labelled. There is a federal classification for ‘Tyre derived products’. Tyres processed to this stage should be exempt from the ‘controlled’ tag and be available for engineering and other useful purposes. Civil engineering uses for whole tyres such as reef and breakwater construction would take a reasonable volume of tyres out of the controlled waste stream. This should be examined to see if there is a commercial opportunity that might be taken up in the future. There is no doubt a future opportunity for tyre rubber will become available, and it should be maintained as a potentially valuable asset. At this stage, it may not be economically viable to fully process scrap tyres in Tasmania, but this will not always be the case. The storage of tyres is relatively simple and can be engineered to be low risk; storage for future reclaim would be simply banking a resource.

The split between recoverable rubber and steel is about 80:20, with a very small weight fraction of ‘fluff’ from the reinforcement fabrics.

Australia’s largest tyre recycler claim to handle 7 million tyres per annum or about 70,000 TPA and to produce 10,000 TPA of crumb rubber and 2,500 TPA of recovered steel. Of the 10,000 TPA of crumb produced, some is still landfilled, but the bulk of it goes into tyre manufacturing, road repairs, soft fall surfacing, horse arenas, brake pads, tile adhesives, insulation purposes and sporting surfaces. This tonnage includes industrial waste such as off-cuts and rejects from the tyre manufacturing industry itself. The remainder, approximately 57,500 TPA of tyre waste, goes to other uses such as civil engineering projects, fuel for energy recovery systems and drainage aggregates.


Stripping and shredding tyres for the small Tasmanian crumb market is unlikely to be economic, unless a large volume use such as kiln fuelling is included to affect an economy of scale. Whole tyres for large volume users such as a cement kiln with the capacity to take whole tyres as fuel has been reported to be problematical at the Australia cement kilns which have followed this path. As stated elsewhere in this report, this would be even more difficult at the Railton kiln. Application of shredded tyre rubber to cement kiln firing would not necessarily require removal of steel and other structural materials from the rubber, but the chipped material would need to be free-flowing and work would be needed to determined how this would achieved and how this might be integrated with a crumbed rubber production operation. There are processes for recovery of ‘virgin’ rubber from tyres, however these are in their infancy and at projected costs it is proving difficult to compete with imported natural and synthetic rubber. These processes are presently only applicable to small volume throughputs and a specialty industry may be possible in the future, making limited quantities of highly specialised products such as adhesives. More likely is the process of recovering liquid fuels and valuable chemicals from rubber, by pyrolysis. There is for example a diesel product that could be a very useful fuel for Australia and for Tasmania, in particular given the amount of mining and landfill fuel used. The reason for this is that the raw fuel derived is generally not suitable for use in smaller engines or for on-road use. Both the pyrolysis liquids and gases produced can also be used as fuel for industry - this might be an easier way to get fuel into the cement kiln at Railton. The chemicals that can be produced include high value solvents, for example, limonene as used in essential oils extraction and indene as used in adhesives manufacture. If recovery options for waste tyres are not immediately available, the practice of ‘mono-filling’ (burial of a single waste type in a specified area) should be encouraged. Potential resources are presently being lost through ‘co-filling’ i.e. burial of multiple waste types in the same area. If landfilling of tyres is segregated and the location noted, it is possible for the tyres to be unearthed when options for recycling become available.


5.12.8 Treatment Options Storage for future development of recycle opportunities

Description: Establishment of a landfill facility exclusively for used tyres. Examples of Application: Similar to a landfill but not necessarily buried. Stacked about 2m high would require 1ha per 3 years allowing for earth walls around every 25,000 for fire risk control. This is not in accordance with present restrictions on tyre stocks. Strengths:

• Storage pending economical solution. • Resource for a future industry. • Immediate solution.

Weaknesses: • Fire smoke pollution risk. • Perception of leaving the problem for another generation.


Land value + $0.35M

$210,000 p.a. ($0.75 / tyre) 30%

Loader and man for about 5 days per week, fencing and excavated soil

Fuelling for cement kilns

Description: Whole tyres are used as fuel at a cement kiln in Victoria. It is understood that shredded tyres are or have been used for their fuel value in other cement kilns in NSW and Queensland. The Railton Tasmania cement kiln is coal fired and there must surely be potential for some fuel replacement with shredded tyres. There would be technical problems to overcome but the main issue seems to be cost. The cement plant owns its own coal mine and the economics (gate fee) will dictate the outcome. Examples of Application: Tasmania’s road vehicle tyre component would contribute less than 5% of the fuel requirement of the Railton cement kiln. It should be feasible to incorporate this proportion into the coal firing system. The sulphur content of the tyre rubber is not an environmental issue in a kiln which is processing such highly alkaline materials, nor a product quality issue where the product already comprises a high proportion of sulphate as gypsum. Strengths:

• Effective destruction of any pollutants, tyres are chemically complex. • Consumption of a voluminous waste, releasing landfills from this burden. • Recovery of fuel value of the tyres, a much better solution than land-filling which consumes

energy in preparing the tyres and fuelling the earthmoving machines. Weaknesses:

• Loss of the considerable chemical resource of the tyres. Est. Capital Cost Est. Operational Cost +/- % Explanation

$2,2M

Should be cost neutral; value of fuel replacement ($125,000 p.a.) plus gate fee, to cover operating cost of about $200,000 pa plus capital charges.

50%

A particular shredded size will be needed and an injector to feed the rubber into the firing end of the kiln. Access at the feed end is not available with the present pre-heater arrangement. Capital is an estimate for shredder, conveyors and feeder. Assumes coal value is $25/t delivered, $1/GJ.


Pyrolysis – liquid fuels production (and potential for chemicals recovery)

Description: Practised in many places in USA, e.g. Chicago where tyre rubber is pyrolysed to produce the diesel fuel for landfill and quarry equipment. This fuel would also be suitable for open cut mining equipment. Recovery of liquid fuel (diesel grade) and a relatively inert carbon/ash residue that may have use as a filler back into new tyres. Greater than 95% volume reduction. Examples of Application: For road vehicle tyres it is only a matter of removing the bead and shredding the rubber for feed for a continuous pyrolysis retort, there are several designs available and the plant is relatively simple to build and to operate. For giant mine vehicle tyres it would be possible to use a batch type pyrolysis unit that can take 3-6 tyres at a time, in essence it cooks them using non-condensing gases from the diesel condenser as the fuel. Feasible but has not been done to date and some development work would be needed. Strengths:

• Recovery of at least the energy values of the tyre rubber in a higher grade more versatile liquid fuel form.

• There are several lower temperature processes at the research and development stage, for recovery of recyclable tyre chemicals (e.g. de-vulcanised rubber).

• Technology is available and processes are in operation at least for shredded rubber. • Whole tyres may be a possibility with batch and semi-continuous European processes used on

other waste streams. • There are batch pyrolysis processes in commercial operation in Europe that might be adapted,

with some size reduction of the tyres, or a simpler batch pyrolysis furnace might be developed for whole tyres.

• The increasing price of oil with little prospect for even long-term decrease. Weaknesses:

• In simplest case the loss of chemical values. • Limitations on use of the motor fuel, requires obtaining of environmental and Occupational

Health and Safety approvals specifically for Tasmania. • Need for relatively high cost shredding. • Mine vehicle waste tyres are approximately 1 tonne each and cannot be so easily shredded so

that a process may be needed which can handle whole tyres.


$4.5M including building, process plant and emission controls, installation and services.

$0.8M p.a. for labour, energy and equipment maintenance.

30%

A plant to process 3,500 TPA of passenger vehicle and road truck tyres using a 1000kg/h medium temperature continuous retort, producing 1.5 million litres per annum of liquid fuel and 750 TPA of carbon black separated from 250 TPA of relatively inert residues (for disposal), plus 650 TPA recycle steel.

Est. Capital Cost Est. Operational Cost +/- % Explanation – with chemicals recovery

$7.5M including building, process plant and emission controls, installation and services.

$1.2M p.a. for labour, energy and equipment maintenance.

30%

A plant to process 3,500 TPA of passenger vehicle and road truck tyres using a 1000kg/h high temperature continuous retort, producing 200 TPA of high value chemicals ($10 to $20 per kg), 1.1 million litres per annum of liquid fuel and 750 TPA of carbon black separated from 250 TPA of relatively inert residues (for disposal), plus 650 TPA recycle steel.


5.13 Security materials 5.13.1 Description / Definition

Security materials, currency notes, contraband, and confiscated drugs. Not classed as controlled waste but is required to be treated in the same way as say clinical and quarantine wastes.


This is a small but important waste stream in that most of it can only effectively be disposed of by burning, to the extent that where an incinerator is not available it has to be burnt in a bonfire. At existing medical waste incinerators in other states, this waste stream can amount to a 2 - 4 hour burn per month (0.5% of the total waste throughput).


Practices in Tasmania Practices include storing, shredding, burning and burying, with some of the material being transported interstate for incineration along with medical waste.

5.13.4 Stockpiles

This material is always stockpiled until the volume is sufficient to warrant transport to the incinerator. The chief expense is the necessary security measures and armoured truck service.

5.13.5 Waste Generators The police and defence forces, various government departments including border security, banks and operators of commercial security services.



Security materials - - Escorted transport and supervised burning and burial.

5.13.7 Opportunities for Re-use, Resource Recovery or Waste Exchange Nil. 5.13.8 Treatment Options

High temperature incineration – see Section 5.11.8 ‘Clinical and pharmaceutical wastes’ for more detail.


5.14 Quarantine wastes 5.14.1 Description / Definition

Primarily wastes from international shipping and aircraft, as well as wastes repatriated by the Australian Antarctic Division from the Australian Antarctic Territory settlements and research stations.


There is an expectation that shipping wastes from cruise liners will increase significantly, potentially to as many as 30 dockings and 100 TPA of municipal waste. This waste has the potential to introduce exotic plant materials and diseases into Tasmania. By comparison, the Darwin Port Authority incinerates approximately 300 TPA of quarantine waste and has the capacity to incinerate 6 tonnes per day. Reasonably large amounts can occur in one incident, and may require rapid treatment rather than lengthy secure refrigerated storage.

5.14.3 Stockpiles It is generally undesirable to stockpile quarantine waste, either because it is putrescible and requires refrigerated storage, or because it requires a high security storage facility. From stakeholder discussion, there is potentially 40,000 - 100,000 tonnes of Australian Antarctic waste that could require repatriation. If this waste was to be transported from the Antarctic to Australia, specifically Tasmania, it would then be treated as quarantine waste. The waste has accumulated in the Antarctic over many years and is mainly contained in contaminated sites or landfills, including significant quantities of contaminated soils. It will likely take many years to recover and ship such an amount to Tasmania.


Shipping and air transport, including interstate transport, generates quarantine waste for an island state with strict quarantine regulations. This includes wastes discharged by naval and Antarctic shipping and fishing fleets. There is the additional accumulated waste from the Australian Antarctic Territory sites, as well as the ongoing generation of waste at these sites.


AQIS Requirements and Practices

According to the Australian Quarantine and Inspection Service (AQIS), quarantine waste in Tasmania is required to be packaged, handled, stored and transported under the same conditions as for mainland Australia. Quarantine waste must be


stored in both primary and secondary containers. Secondary storage containers must be solid, durable, and leak and vermin proof, and have secure closures to prevent loss of contents under normal transport conditions. Storage containers must be clearly marked with the words ‘Quarantine Waste’ using black letters on a yellow backing. Galley waste and perishables like fruit and vegetables can be stored for a maximum of 48 hours prior to disposal or alternatively they can be stored at a maximum temperature of 3°C. All other quarantine waste may be held for no longer than 21 days at ambient temperatures prior to disposal. Vehicles must be suitably equipped to deal with spillage of quarantine waste. They must be constructed and secured to prevent any loss of contents that might be caused under normal transport conditions. Quarantine waste transporters must have signed onto an AQIS Compliance Agreement. In terms of regulation and compliance, the Quarantine Act 1908 and subordinate legislation provides the basis for the management of quarantine waste in Tasmania (as in other Australian States and Territories). Quarantine waste generators, transporters and disposers/facilities will need to be either a Quarantine Approved Premises (section 46A of the Act) or signed with an AQIS compliance agreement. The latter outlines roles and responsibilities of transporters and is outlined in section 66B of the Act. Quarantine Tasmania is the body responsible for ensuring services and facilities in Tasmania meet the legislative requirements, on behalf of the Commonwealth.

Both quarantine waste generators and facility operators are subject to regular audits by AQIS to ensure that they continue to meet AQIS standards. Facility operators are required to keep records of when quarantine waste was destroyed, and copies of the destruction parameters used. Practices and Facilities in Tasmania

The high temperature incinerator at Macquarie Port in Hobart was decommissioned in the last decade. Currently, there are incinerators located at the sea ports at Bell Bay and Burnie. The facilities are owned and operated by TasPorts (previously the Tasmanian Ports Corporation) and dispose of shipping waste, including small amounts of quarantine waste. The incinerator at Burnie is relatively close to the city centre, whereas the Bell Bay facility operates adjacent to a major Tasmanian industrial estate. The expected lifetime of both incinerators cannot be estimated, however the age of the facilities, proximity to residential and urban areas, and increasingly stringent emission control guidelines, are influential factors adding to the uncertainty of their long-term future. Much of Tasmania’s quarantine waste is currently disposed of to landfill, with the McRobies Gully site in South Hobart receiving the vast majority of this waste.


Remount Road Waste Depot in Launceston and Dulverton Waste Depot in the north are the regional landfill facilities currently receiving small quantities of quarantine waste on an annual basis.

The short remaining life of many urban landfills, particularly McRobies Gully, is gradually becoming evident as facilities restrict the types of materials accepted. The current concern raised by stakeholders is that as urban tip sites close or become limited as to the type of waste they receive, the need to transport quarantine waste through rural production areas will present a very real biosecurity risk.

As highlighted in Section 5.14.8 below, specialised facilities are required for the disposal of quarantine waste. Currently, the management of quarantine waste in Tasmania does not involve treatment or disposal at best practice facilities, nor does it provide adequate protection to human health, the environment, or industries such as agriculture.



Quarantine waste Up to $100 /t - Inclusive of transport.


This is a case where there will be little or no opportunity for such activities.

5.14.8 Treatment Options National Requirements for Treatment / Disposal

AQIS does not require the testing of quarantine waste prior to destruction. It is to be segregated from domestic waste, either by separate storage facilities or by enclosed storage receptacles such as lined skip bins or lidded and lined waste bins. Any waste that comes into contact with quarantine waste is then considered to be quarantine waste and must be disposed of as such. According to AQIS, the current acceptable treatment options for quarantine waste are:

- Deep burial; - High temperature incineration; - Autoclave; and - Gamma irradiation

High temperature incineration is a treatment considered effective for all streams of quarantine waste, with the exception of waste water. Acceptable operating parameters for incineration include a minimum operating temperature of 900°C and


the resultant product is to be a fine ash. AQIS requires all operators to be compliant with applicable State and Commonwealth legislative requirements, such as the monitoring of stack emissions. For regular quarantine waste, meaning waste from ports, harbours and airports, as well as any annual repatriated Antarctic waste, incineration would be the more usual approach. A state-of-the-art facility (like that proposed as a replacement in Darwin) could additionally treat the entire Tasmanian clinical and related waste stream. This issue is discussed in the clinical and relate waste considerations in Section 5.11.

In terms of disinfecting treatments, alkaline chemical treatments such as lime are used in isolated cases, mainly for the treatment of sediment from washbays. However, this process is currently under review by Biosecurity Australia, and based on preliminary discussion, the use of alkaline chemical treatments may be discontinued for all waste streams. Thermal disinfection includes the use of autoclave, which is suitable for all streams of quarantine waste. Presently autoclaving of quarantine waste is conducted at either 121°C for 15 minutes or 121°C for 30 minutes; however these controls are also under review.

All quarantine waste streams may be disposed of through landfill. The landfill facility must be able to bury the waste to a depth of 2 metres, achieved by either a 2 metre-deep pit, or alternatively the quarantine waste can be placed at the tip face which is then pushed over the waste. Quarantine waste sent to landfill must be covered immediately, and the earth moving equipment is not to come into contact with the waste material. In addition, the burial location should be recorded to avoid the excavation of quarantine waste at a later time.

This section references current and future quarantine waste requirements, though it should be noted that AQIS’s requirements can be subject to change on advice from Biosecurity Australia.

Treatment / Disposal Options in Tasmania Tasmania's capacity to effectively manage quarantine waste is expected to continue to diminish. With the loss of incineration capacity in the State’s south, the uncertain long-term future of the Bell Bay and Burnie incinerator sites, below-standard landfill facilities and practices, and increasingly stringent environmental controls, it is apparent that new or upgraded facilities for the treatment and disposal of quarantine waste in Tasmania is required. A co-ordinated and consistent approach to quarantine waste management in Tasmania is necessary, from the major air and sea ports, to regional locations where aircraft and vessels arrive from interstate. Improvements in handling, transport and storage practices are also essential.


There are various risks associated with the handling, transportation and disposal of quarantine waste. Some of these risks are included below: Burial at Landfill: In view of the long life (often years) of some bacterial and viral infectious substances, and the viability of many seeds and bacterial/fungal spores in the soil environment (and the potential for these to be wind and water-born), the practice of burial of quarantine waste at a landfill can be inadequate, even potentially hazardous.

Autoclave Processing: To follow the lead of mainland States and Territories, Tasmania would need to establish urban based autoclave facilities that have the ability to affect broad spectrum sterilisation of the quarantine risks likely to be present in quarantine waste. This means multiple autoclave facilities across the State, established near to the waste generator, for example port facility, in order to avoid transportation through the urban environment. Autoclave sterilisation requires that all waste be bagged in secure autoclave-able (porous) bags, which must in turn be contained in stable drip-proof bins, in secure containment (vehicles similar to those used for biomedical waste and bunded building areas). This requires manual or mechanised transfer from shipboard or aircraft type containers into bags, in a suitable secure facility, with appropriate procedures. Some wastes require extended sterilisation times, timber and densely packed, bundled or baled matter, and water retaining material such as animal carcasses and animal bedding. Some of these are not recommended for autoclaving at all and are better destroyed by incineration. Most waste is plastic bagged and double bagged to help reduce puncture issues, such plastic film must be shredded before re-bagging for the autoclave and even then the plastic film can act as a barrier to steam passage and as a containment for fluid, to the extent that quite large volumes of the load may be inadequately treated. This represents double handling and it is certainly a hazardous procedure. There is a belief that autoclaving will eliminate the full spectrum of biosecurity concerns from bacteria, virus, fungal spores, weed seeds and live insects in a single process, the waste material then loses its ‘subject to quarantine’ status and ongoing management of the material under quarantine regulations can cease. It is certainly a contender if it eliminates the risk of releasing pests and diseases into the Tasmanian environment, and would be the process of choice. Although autoclave sterilisation is regarded as economically competitive with chemical treatment and incineration for some bio-medical waste, in the case of quarantine waste, where the aim is to eliminate waste transportation through rural areas, requiring multiple facilities, this would be a most expensive approach.


There is no doubt autoclave sterilisation can achieve a substantial degree of the biosecurity requirement, but it is recommended that such treated material should still be regarded as hazardous to the environment and health, and should be handled and disposed of accordingly. Careful consideration needs to be given to the degree of disinfection/sterilisation of which autoclaving is capable, and the operating conditions required to achieve these levels. Residual risk must be evaluated. There are many cases in the health industry where double treatment is required so as to reduce the risks to an acceptable degree, these include chemical, germicidal, radiation, UV and thermal options. A similar two-step approach would be appropriate in the case of quarantine waste. Overseas much biomedical waste is autoclaved at source and then incinerated. Here the autoclaving provides for safer downstream handling for transportation and at the off-site incineration facility. With autoclaving at or near source, mainly ports and airports, the onus for sterilisation falls upon several facilities, each of which must be supervised, tested, trained and audited. Any such facility must be sized for the worst case scenario and then operates most of the time significantly below capacity, on reduced hours, at substantially increased cost, at low efficiency and at risk of engendering a casual and careless attitude. A fleet of highly secured, well engineered, transport vehicles, handling waste in its original containment (bags), in secure bins designed and maintained (and cleaned) for the purpose, from source to treatment/disposal, is a much better option for AQIS. The facilities can be owned and operated by competing contracted service providers, tightly supervised by AQIS.

Transport: Transport and handling of quarantine materials presents risks that must be addressed no matter where they occur, that is, not just in the rural environment. There are too many pathways and incidental avenues for transmission. Adequate buildings, vehicles, enclosures, containers, washings, disinfections and procedures can be engineered to overcome this. Refrigerated storage and transportation for putrescible wastes should be considered where delays beyond 24 hours before treatment and disposal are possible. Incineration: The risks associated with the handling of quarantine waste are generally similar to those associated with bio-medical waste and the same rules for collection. Storage and transportation could be applied. The bins used are closed and secured throughout this process and are only opened at the disposal site. They are usually mechanically handled and the contents and plastic liner are together tipped into the receiving hopper or chute which feeds the waste into the facility. The trucks used are designed for safe handling and containment of the closed and secured wheeled bins.


By far the most secure approach, and the one followed in most ports for many years past was to have the disposal or destruction facility at or adjacent to the port or other waste generating facility, with an on-site buffer storage, such as a refrigerated shipping container and/or a rodent proof storage room, to take up the slack. Usually port facilities are very secure and space could be made available for an on-site facility such as an autoclave or incinerator. The problem with incineration is chiefly perception, but also that such a facility, designed to the latest emission control standards, would be expensive and have only intermittent use and would thus not be cost effective. It is suggested that closure of such incineration facilities, for environmental reasons, ignores the very real public health and safety values they afford. There may be a way out of this impasse. Incinerator emissions of most concern are acid gases and carcinogens and their precursors, such as dioxins and polyaromatic hydrocarbons. Incinerators equipped with high temperature afterburners and rapid quench scrubbers are able to meet the tightest emission limits. These are relatively large combustors so that they can handle materials up to pallet size and are therefore capable of taking batch loads that can then be combusted in a controlled fashion over an extended period, such as one batch per 12 hours. Ash - For a port-based facility with ready access to seawater, a very simple and cheap option would be to use a high efficiency particulates scrubber followed by an absorption tower, both using copious quantities of seawater. The discharge would be readily and safely dispersed back into the harbour. The high temperature afterburner provides a high level of destruction, the rapid quench avoids the reformation of dioxins from the pre-cursors, the scrubbing removes particulates which are otherwise carriers and catalysts for the generation of carcinogens, and the tower scrubber offers an effective acid gas removal. The contaminants returned to the harbour, particulates and dilute acids, offer no environmental hazard. The materials of construction for high temperatures and seawater operation are readily available nowadays.

Gamma Irradiation: This process has been applied to medical waste but the technology is primarily used for sterilisation of high value products such as rubber goods and sterile dressings for medical applications. The risks associated with this process are operational rather than any potential for residual infection or continuing pathogen viability. It is an expensive process, requiring significant building and shielding mass, but very applicable to small items that can pass through a radiation zone on a conveyor belt. There are also ‘room’ type facilities where large objects can be sterilised, but these require large gamma ray sources and are very expensive.


Other Treatments: Treatments such as lime treatment (chemical disinfection) are applicable to certain wastes but are not generally acceptable for quarantine waste because of the variable nature of such. Dense materials requiring penetration of the disinfectant, such as wood, leather and foodstuff, would require vacuum and pressure impregnation procedures and preferably the use of gaseous rather than liquid disinfectants.


6. AUSTRALIAN ANTARCTIC TERRITORY

Investment in new controlled waste treatment and management facilities requires a sustainable quantity of waste over a number of years to be commercially viable. As discussed in this report, the historical waste stockpiles in and around Tasmania are regarded as being particularly important in developing a viable business case for seeking investment in new facilities. It is in this context that the wastes, currently stockpiled in the Australian Antarctic Territory, may be an important waste stream to be considered. This is also an important issue from the point of view of meeting Australia’s commitments under the Madrid Protocol (see the box below for more information). As much of this waste originates from Tasmania, it is logical that it should return for disposal. Leaving such waste in the pristine Antarctic environment is not best practice if it cannot be removed in a controlled manner without causing more environmental harm. Segregated exotic (foreign) components, building and demolition wastes including asbestos, and scientific laboratory type wastes should be managed as controlled wastes and some of this would be subject to security and quarantine action.

At the time of preparing this report, the Australian Antarctic Division was holding discussions with AQIS and Biosecurity Australia about the requirements to be granted an import permit for the repatriation of some controlled wastes currently stockpiled in the Australian Antarctic Territory. SIA understands that there has been no decision in this regard and that the discussions are continuing. From a commercial point of view, should a waste treatment and disposal operator seek to offer a service to collect and manage controlled wastes located in the Australian Antarctic Territory, it will be necessary for the operator to apply to AQIS for an import permit. Additionally, AQIS may need to seek advice from Biosecurity Australia in regards to the conditions of the import permit and the appropriate treatments of the waste. As this waste stream may have some synergies with the establishment of facilities for the future management of quarantined wastes, SIA recommends that the State Government explore this in more detail, particularly to quantify and characterise the controlled wastes present in the Australian Antarctic Territory, to assist in providing advice to any potential investors that may be looking to investigate the Antarctic as a potential source of stockpiled, quarantined waste.


SIA Initial Thoughts The historic Antarctic waste stream may require treatment before disposal to landfill. It would be reasonable to assume a bulk density of 1000 kg/m3 for disturbed (exhumed) aged landfill, so for a figure of approximately 70,000 tonnes, this amounts to around 70,000 m3. By comparison, the annual quantity of clinical and related waste for Tasmania is 6,000 to 7,000 m3, so that the Antarctic waste would be compatible with the clinical and related waste stream if handled over a period of some years. We are advised that the issue with exhumed landfill material based on the Thala Valley experience is that the material is heavy metal impacted. Bio-security risks are low. The ‘fuel’ value of this waste is likely to be low compared with bio-medical waste and also compared with municipal solid waste, so that direct incineration may not be the best option. Ash or residues from an incinerator, thermal destructor or thermal desorption unit generally requires at least secure landfill disposal, which can satisfactorily manage the heavy metals contamination. Another way of handling this would be to ship a transportable treatment facility to Antarctica, together with treatment chemicals, and treat the waste in situ. The waste could then be shipped to Tasmania in its treated state. For example, intensive lime treatment followed by covered windrow storage for a stabilisation period, during which the lime and moisture react to produce a disinfecting temperature - and any free moisture is bound. This will yield a material that can be compacted into 30 m3 shipping containers for the journey to Tasmania, at a rate of about 250 containers per year. Because of the soil content, it may be more suitable to use specially built enclosed bins or skips, and of a size that is more readily handled in the Antarctic. Advice received suggests that this is unlikely to be practicable and it is more likely that the Australian Antarctic Division will have to resort to in situ treatment with tight monitoring of the outcomes. The newly established scheduled flights may make for easier access for sampling and testing operations.


Protocol on Environmental Protection to the Antarctic Treaty (The Madrid Protocol) The Madrid Protocol was adopted in 1991 to ensure that the wide range of provisions relating to the protection of the Antarctic environment could be assembled in a comprehensive and legally binding form. According to the Australian Antarctic Division, the Protocol: - designates Antarctica as a 'natural reserve, devoted to peace and science'; - establishes environmental principles for the conduct of all activities; - prohibits mining; - subjects all activities to prior assessment of their environmental impacts; - provides for establishment of a Committee for Environmental Protection, to

advise the ATCM; - requires the development of contingency plans to respond to environmental

emergencies; and - provides for the elaboration of rules relating to liability for environmental damage. The Protocol is also accompanied by Annexes that detail specific measures and procedures. Annex III relates specifically to waste disposal and waste management, specifying wastes that may be disposed of within Antarctica and wastes that must be removed. It also provides rules relating to the disposal of human waste and the use of incinerators. Particularly harmful products such as PCBs, polystyrene packaging beads and pesticides are prohibited in the Antarctic.


7. FUTURE DEVELOPMENT OPTIONS AND OPPORTUNITIES

7.1 Business Case Assessment One of the key components of this study is to undertake a business case assessment of controlled waste treatment options. This primarily involves the development of a financial model to assess the economic viability of building new infrastructure, or expanding on existing infrastructure, for the treatment and disposal of controlled waste. The study has considered many factors, as detailed in the previous sections, in determining which technologies could be used to manage the various waste streams. As a first step, a purely financial assessment can then be undertaken as to whether or not a specific technology could be economically viable. Given the range, volumes and changing landscape associated with all the waste streams identified in this report, it is not possible to find one or two solutions for the treatment of all waste streams. Following identification of those financially viable solutions, it is then possible to add a little more rigour around each of these with a view to the non-financial aspects of the project, such as location, regulation, and stakeholder desire, as well as commercial issues and barriers to investment. The final outcome is then SIA’s recommendations for further work, action or due diligence. It is hoped that these recommendations increase the interest levels of developers/investors in taking some of the options further, in the knowledge that there may be a financially attractive project.

Financial Model

A detailed financial model was used to assess the economic viability of the options that were considered. The model can assess this viability over differing terms or contracted life, but typically a 20 year life was assumed as this provides for the best opportunity of making the project viable whilst meeting the asset life expectation. There are a number of variables and model inputs that affect the financial viability of privately financed waste treatment projects and the key ones are shown in Section 8. In summary, the main inputs are:

Engineering, Procurement and Construction cost of the plant Development costs Operation and Maintenance costs Financing structure and costs Contract term Depreciation schedule Waste volumes Gate Fee (driven by owners Return on Equity requirement) Other revenue sources, such as sale of residual product


Whilst the fundamentals of a financial model are the same from one to the next, each developer/investor will usually use their own and this may contain variations which will impact their view on the economic viability. Hence, the results presented in this report are a guide to informing any developer that a more detailed due diligence step may be worth taking.

Return on Equity (RoE) and Net Present Value (NPV) Developers use their own metric for determining whether or not a project meets their

investment criteria. It is not the intention here to compare the merits of one against the other and so for this analysis the metric used is RoE invested. This has been based on a nominal, post tax figure using the free cash flow stream over the 20 year term.

Again, whilst each developer will have their own RoE requirement, a minimum of 18% was used in the analysis to set the gate fee. In some instances, the RoE is higher than 18% where it is believed that the gate fee(s) is set at a market price. The NPV figures shown below for each of the possible solutions is based on a 20 year term using a discount rate of 10%.

Capital costs estimates

The figures used in the analysis for the engineering, procurement and construction of the plant represent budget estimates for the purpose of making an initial economic evaluation. It was not within the scope of this study to do any detailed design or seek third party quotes which would allow for margins of approximately +/- 30%. This would require a significant amount of design work in order to produce functional specifications and then go to manufactures and suppliers for quotes. The estimate of the Development Cost (see Section 8) is based on SIA’s experience of developing privately financed infrastructure assets.

Operation and Maintenance (O&M) cost estimates The figures used in the analysis for the O&M of the plant represent budget estimates for the purpose of making an initial economic evaluation. It was not within the scope of this study to do any detailed analysis on the exact breakdown of the fixed and variable O&M costs. This would require a significant amount of work (following the work to establish the plant design) and then receive quotes from O&M contractors.

Development Costs The estimate of the Development Cost (see Section 8) is based on experience of developing privately financed infrastructure assets. The quantum is heavily


dependent on the willingness of all stakeholders to make the project happen and to minimise long and protracted commercial discussions.

Quarantine Waste

Section 5.14 summarises the situation on quarantine waste. Whilst some of the technical solutions proposed have the capability to treat quarantine waste, their economic viability is mainly reliant on securing the quarantine waste volumes. At this moment in time, there is still no resolution as to whether or not waste generated and stockpiled in the Australian Antarctic Territory (potentially the largest component of quarantine waste) will be allowed back into Australia for treatment and disposal. Equally so, there is no resolution as to whether other non-Australian Antarctic Territory waste would be available for treatment. Currently quarantine waste is largely disposed of at one or two landfills in Tasmania. However these facilities have a limited life and there is some question as to whether the operators will consider the investment required in order to meet the 30 June 2009 deadline to be able to continue to accept quarantined waste for disposal. The incineration facilities located at the Bell Bay and Burnie ports also have an uncertain long-term future.

7.2 Economic Analysis of Solutions 7.2.1 Main Assumptions

It is necessary to use some primary assumptions for all the solutions analysed. Some of these will change over time as, hopefully, more work is undertaken on the recommendations and the financials and commercial assumptions start being firmed up. The main assumptions common to all solutions analysed are as follows:

i. Gate fee pricing as of 1 December 07. ii. Construction start as of January 2009 with full commercial operation January

2010. iii. Financed using 100% equity (see Section 8.5 for detailed discussion of

financing structures). iv. All equipment is sourced in Australia and therefore there is no foreign

exchange risk or import duties. v. CPI at 2.5%. vi. 20 year asset life and return on equity analysis. This indeed could change

depending on the specific project undertaken and the stakeholders involved. vii. 20 year depreciation schedule. viii. 10% discount rate for NPV calculation.


ix. No land purchase but a long-term lease agreement starting at $10,000 per annum escalating at CPI. Clearly, this will be project and stakeholder specific.

x. Council rates of $10,000 per annum. xi. Plant insurance during both construction and operation included. xii. Capital and operating cost: budget estimates for the purpose of making an

initial economic evaluation. xiii. Company Tax rate of 30%. xiv. When considering the use of pyrolysis and the sale of any liquid fuel we have

assumed that no tax is applied on the sale of this fuel. xv. Development costs included. These are non construction costs and comprise

things such as: - Construction insurance - Initial spares holding - Commissioning costs - Developers engineering - Legal and tax costs - Environmental, local council and government costs - Ad hoc consultancy fees - Developer’s internal and overhead costs - Contingency

7.2.2 Autoclave Disinfection, Shredding and Landfill

Waste types: R100 (less some particular types) and quarantine waste Total waste volume: 1180 tonnes per annum, including 800TPA of R100, plus

180TPA quarantine, plus 200TPA from the 20 year Antarctic stockpile Total capital costs (construction plus development costs): $1.45m Total operating costs: $700K per annum $50/tonne landfill gate fee plus $20/tonne cartage fee for residue No transport costs included for waste reaching the plant

Note: This particular analysis is for a single plant treating the total waste stream volumes above. This does not take into consideration Quarantine Tasmania’s concern to avoid long-haul transport of quarantine wastes. This would require multiple autoclave installations across the State, the economics of which would be less attractive. A key consideration is that an autoclave has to be large enough to take the largest waste item, and to accommodate large incidental deliveries, for example, the birthing of a large cruise ship can render each regional facility largely under-utilised.

Tariff: Clinical and related waste (R100): Quarantine waste:

$850/tonne $1100/tonne

Return on Equity: NPV:

18% $1.04m


7.2.3 Shredding, Chemical Disinfection and Landfill

Waste types: R100 (less some particular types) and quarantine waste Total waste volume: 1100 tonnes per annum (includes total quarantine waste

of 300TPA). Total capital costs (construction plus development costs): $1.35m Total operating costs: $495K per annum $50/tonne landfill gate fee plus $20/tonne cartage fee for residue No transport costs included for waste reaching the plant

7.2.4 High Temperature Pyrolysis

Waste types: Tyres (removing the bead and shredding the rubber) Total waste volume: 2500 tonnes per annum at an average of 10kg per tyre

(assuming the capture of two thirds of total volume). This does not include tyres at mining operations.

Total capital costs (construction plus development costs): $8.6m Total operating costs: $1m per annum $50/tonne landfill gate fee plus $20/tonne cartage fee for inert residues No transport costs included for tyres reaching the plant

Tariff: Clinical and related waste (R100): Quarantine waste:



18% $863,000

Tariff:

Tyres $5/tyre (this is consistent with retaining the existing levy) Revenue: Liquid Fuel: Carbon Black: Recycled Steel: High Value Chemicals:

$1.20/litre (based on 790 litres generation) $150/tonne (based on 540 tonnes generation) $150/tonne (based on 460 tonnes generation) $7000/tonne (based on 140 tonnes generation)


21% $7.5m


7.2.5 High Temperature Incineration

Leaving aside the discussions around the stakeholders desire to develop such a facility the main inputs for the economic analysis are:

CW (not including Quarantine waste)

Waste types: G160, J160, R100, R120, T120, security waste Total waste volume: 900 tonnes per annum Total capital costs (construction plus development costs): $1.35m Total operating costs: $900K per annum $50/tonne landfill gate fee plus $20/tonne pre-treatment fee for residue No transport costs included for waste reaching the plant

CW (including Quarantine waste)

Waste types: G160, J160, R100, R120, T120, security waste and quarantine waste

Total waste volume: 1300 tonnes per annum (includes regular amount of 180TPA quarantine waste plus provision for 200TPA for 20 years from stockpiled amount in Antarctic, if this waste is able to be repatriated ashore in Tasmania).

Total capital costs (construction plus development costs): $1.95m Total operating costs: $1.29m per annum $50/tonne landfill gate fee plus $20/tonne pre-treatment fee for residue No transport costs included for waste reaching the plant

Tariff: Clinical and related waste (R100): All remaining waste types:



18% $866,000

Tariff: Clinical and related waste (R100): Quarantine waste: All remaining waste types:

$1375/tonne $1400/tonne $800/tonne


18% $1.3m


7.2.6 Cement Kiln Injection

PCB (low level) contaminated waste only Waste types: M100 Total waste volume: 200 tonnes per annum Total capital costs (construction plus development costs): $1.6m Total operating costs: $292K per annum No transport costs included for waste reaching the plant

PCB (low level) contaminated waste plus quarantine waste Waste types: M100 plus quarantine waste Total waste volume: 500 tonnes per annum (includes 300TPA quarantine

waste) Total capital costs (construction plus development costs): $1.6m Total operating costs: $400K per annum No transport costs included for waste reaching the plant

Tyres only

Waste types: tyres Total waste volume: 2500 tonnes per annum Total capital costs (construction plus development costs): $2.7m Total operating costs: $350K per annum No transport costs included for waste reaching the plant

Tariff: M100: $3300/tonne


18.5% $1m

Tariff: M100: Quarantine waste:



18.5% $1m

Tariff: Tyres: (this is consistent with retaining the existing levy)

$5/tyre


30% $4.5m


7.2.7 Co-Composting Facilities

The analysis was based on establishing 4 regional co-composting plants located in the Central, Southern, North and North West regions. The primary objective is to incorporate biosludges into co-composting, along with green waste and a number of other controlled wastes, and for this purpose, each region would also have its own mobile sludge dewatering unit and trailer, plus sludge cake truck/trailer mover. Economics per regional plant:

Waste types: K100 (animal effluent and residues and fish processing

wastes), K110 (grease trap waste), K120 (pit sludges), K130 (dewatered biosolids/sewage sludge and biosludge), green waste

Waste volumes: 30,000 tonnes per plant, including 15,000 tonnes of green and forestry waste, making a total of 120,000TPA for 4 plants.

Total capital costs (construction, development costs, land, road access, weighbridge and mobile sludge dewatering unit): $3.6m

Total operating costs: $900,000 per annum No transport costs included for waste reaching the plant Rendering of abattoir effluent done by existing plants (costs included in

model) Pre-treatment of pit sludges for gross oil removal included

7.2.8 Rendering Plant – Abattoir Waste

Waste types: K100 (animal effluent and residues) May include poultry and feathers; feathers requiring additional processing equipment but producing a similar meal

Total waste volume: 12,000 tonnes per annum (portion not presently rendered)

Total capital costs (construction, development costs, and extensive emission control): $5.3m

Total operating costs: $1.8m per annum No transport costs included for waste reaching the plant

Tariff: All waste streams: Revenue: Compost:

$50/tonne $20/tonne (based on 19,000 tonnes)


19.5% $2.9m


7.2.9 Neutralisation, Precipitation and Solidification Plant

The analysis was based on a combined plant consisting of neutralisation as a pre-treatment for precipitation and then solidification (cement stabilisation) and landfill. The precipitation plant is used to process acids and alkalis (B100, C100), whilst the solidification plant is used to treat paints, lacquers, varnish etc. (F100).

Waste types: B100, C100 and F100 Total waste volume: 600 tonnes per annum (B100 and C100), 230 tonnes per

annum (F100) Industry related waste: concentrations unknown for B100 and C100 Total capital costs (construction and development) $500,000 Total operating costs: $380,000 per annum No transport costs included for waste reaching the plant Costs includes the purchase of a bulldozer

Tariff: All waste streams: Revenue: Tallow: Meal:

$70/tonne $4,500/tonne (based on 600 tonnes per annum) $200/tonne (based on 6000 tonnes per annum)


42% $14m

Tariff: B100 and C100: F100:



18% $445,000


7.2.10 Economic Summary of Various Solutions Below is a summary of the findings obtained from financial analysis of the potential development options, including SIA’s assessment as to whether or not a project warrants investment or further investigation.

1. Autoclave disinfection, shredding and landfill

Based on the estimated cost of treatment (primarily due to the high operating cost), SIA believes this may not warrant further investigation at this time. Additionally, the project is only viable if additional quarantine waste, as from the Antarctic, is secured. The use of regional autoclaves has been raised. This is certainly possible, and whilst the financial analysis has not been undertaken on regional facilities, it is expected that the cost of disposal would be in excess of $1000 per tonne for all waste types. There may be desire to pursue this option further, even taking into consideration the relatively high disposal cost.

2. Shredding, chemical disinfection and landfill

SIA believes this should not be pursued at this time due to the viability being contingent on quarantine waste being secured. If it can be secured, then the gate fees are such that the project would warrant further analysis.

3. High temperature pyrolysis

SIA believes this is a project that should certainly be investigated further. The project benefits greatly from the additional revenue stream primarily from the sale of liquid fuel and high value chemicals. Further work would be required on firming up the prices and long-term demand for the fuel and chemicals, in addition to securing purchasers, and this would be one of the barriers to entry. We believe that any developer would not view the risk of tyres being unavailable as a barrier to further due diligence.

4. High temperature incineration

SIA believes this should not be pursued at this time due to the high gate fees. This is primarily due to the high operating costs. From a regulatory and approval point of view it would also be a difficult project to get stakeholder buy in. However, this exercise also shows the cost of implementing this solution even if it was considered.

5. Cement kiln injection

SIA believes this is a project that should be investigated further. The project benefits from using an existing asset and therefore there is a reduction in development costs. Some of the waste streams, such as oil and tyres provide fuel to the kiln and therefore there is an avoided cost to the kiln which assists the economics. However, there are some technical issues to further analyse and resolve in order to obtain maximum benefit from the use of this asset. Any investor would want to do due diligence on the use of third parties for waste-to-fuel preparation, in additional to the life of the cement operation and the factors that Cement Australia use in assessing its Railton facility. Any risk in this regard would potentially mean stranded pre-treatment assets.


6. Co-composting of biosludges

SIA believes that projects for co-composting food waste (e.g. fish processing waste), biosludges (dewatered sewage sludge), with green waste, should be investigated further. This would involve the use of mobile dewatering units. This means establishing co-composting facilities and mobile dewatering services across four regions, namely Central, North, North West and South. Effort will be required in identifying and securing the green waste required, however, with the volumes available in each region, it is believed this is possible. The site locations need to be in areas where there will be minimal or no odour complaints, but not too remote such that the costs of transport limit the viability of the plant. The main barriers to investment are, firstly, securing the waste streams and understanding that in adding value, the waste generator becomes the raw materials supplier and is likely to anticipate that his “product” has worth, rather than his waste attracting a cost. Secondly, making sure that there is a long-term market for compost, identifying purchasers and locking in short-term purchase agreements. The technology risk is low, but maintaining quantity and quality is the key.

7. Rendering plant Whilst the economics of establishing rendering facilities appears very attractive, this needs to be analysed in the context of the existing facilities for meat, poultry and fish wastes, and the global markets for quality tallows and fish oils, and local markets for the produced meals. It would be worthwhile looking further into establishing another rendering plant including contemporary emissions control equipment and how, if at all, it would fit in with the existing rendering facilities and alleviate the need for disposal of abattoir waste, fish processing waste, and poultry waste to landfill and composting facilities.

8. Neutralisation, Precipitation and Solidification (NPS) plant

This is a relatively small project, however could be attractive if sited next to or on the site of a sewage treatment plant, as the effluent from the NPS plant would need to go to sewer and this would be the ideal location. Being a small plant, the economics are sensitive to small movements in waste volume and price, and it will be necessary for the owner to get comfortable with the security of waste supply. The other barrier to entry is ensuring that the plant will have long-term access to the sewer, regardless of what happens to the sewage treatment plant.

7.2.11 Landfill

As summarised in this report, there are a number of permitted landfills taking various forms of controlled waste. The desire and willingness to continue to do so is dependent on numerous factors such as profitability, long-term liability, adhering to best practice, additional capital requirement and site life. However, as with any landfill


option, the issues that need to be addressed are adhering to best practice, leachate control, road access, security and long-term liability considerations.

7.3 Technology Review

The intent of this section is to briefly introduce the technical solutions that have been mentioned in the recommendations as requiring further work or due diligence to gain a better understanding of the technology and economics. Tyre Pyrolysis

There have been several proposals for such plants in Australia, though to-date none has proceeded, generally because of the market/supply condition, difficulty in selling the liquid fuel and in securing tyre supply, both in the face of entrenched competition. There is, however, a pyrolysis plant currently undergoing a feasibility study in Adelaide to process 6000 commercial truck tyres per month. The developer secured a $567,000 grant as part of the project cost. Commercial operations exist in many countries but our experience is in the USA and in particular two plants in Chicago. In these plants the tyres are mechanically stripped to remove and recover the bead steel content, and shredded to about 30mm shards. A certain amount of ‘fluff’ is generated from the fabric content of the tyre carcase and this is either left with the rubber or removed by suction and baled for fibre recovery. From the shredded rubber storage hoppers a bucket elevator and conveyor continuously load the rubber into the rotary contactor type retort. This is like a large screw conveyor with heated jacket and screw. The operating temperature of the retort is sufficient to melt and volatilise the rubber, yielding a hot stream of pyrolysis gases. These pyrolysis gases are cooled to condense pyrolysis liquid fuel and the un-condensed gaseous fuel is used to fire the hot oil heater which provides heat for the retort. For a cold start the heater is fired by natural gas. This is a moderate temperature pyrolysis process which yields a liquid fuel that can be used as a diesel replacement for powering heavy equipment, or as a furnace fuel replacing fuel oil. Since tyre rubber contains sulphur, a vulcanising additive, the fuel produced is not in the same category as the diesel fuel it replaces. Sulphur dioxide emissions arising from the combustion of such fuel should not be a concern on a mine site and would certainly not be an issue with a cement kiln where the sulphur oxides are effectively trapped in the product cement, with no product disadvantage. With present technology a single retort plant can handle up to 1.2 tonnes per hour of tyre rubber, or about 160 tyres per hour. Such a plant needs to be operated 24 hours per day, at least 5 days per week and 45 weeks per year, giving a capacity of 6,500 TPA, about double the size presently needed for Tasmania. A smaller plant is a possibility, but any plant would need to cater for a large back-log and possible future


increases due to the processing of rubber from scrapped mining vehicle tyres and conveyor belting. Some plastic wastes can also be processed in the equipment.

Cement Australia – Railton kiln

The Cement Australia operation at Railton, like most cement plants, has had numerous upgrades for capacity increases and improved performance over many years. The kiln capacity has been increased in large increments by addition and augmentation of its pre-heaters and is understood to be processing about 4-5 times its original design throughput. These additions have greatly restricted access at the feed end of the kiln and made it difficult to incorporate much, if any, solid waste feed at this, the cool end of the kiln. Kiln firing is carried out at both the clinkering hot end of the kiln and in the precalcining pre-heating section. Being a solid fuel fired kiln, using ‘local’ company produced coal, it may be possible to co-fire with solid waste that has fuel value, but there will be the usual problems with putting waste fuel through the coal mills or blending milled waste into milled coal. Kiln firing is tightly regulated to ensure clinker quality, and fuel variability would be a big problem. Moisture additions to the kiln, (variability is inherent with any waste stream) are limited and costly with respect to both fuel consumption and kiln capacity. Use of this plant as a waste management tool could be difficult, but the operator appears willing to consider all options for waste management using the kiln. The major issue would be pre-treatment and blending into a consistent fuel. Cement Australia has its own expertise when it comes to the use of liquid-type wastes, and no doubt can extend this to the consideration of solid waste. An issue with a third party operation might be the loss of custody and control of the waste, after all, their core business is cement manufacture and not waste disposal. Consideration could include replacement of the existing two stages of pre-heating, and a new pre-heating system could incorporate any preparation, pre-drying or pre-heating requirements for several solid waste feed streams. There is always potential for employment of wastes with fuel value via an external gasification or pyrolysis route, producing a gaseous or liquid fuel, from tyres for example. This would be a potential business for a stand-alone contractor with an ‘over–the-fence’ approach, thereby keeping the waste management business separate from cement manufacturing. This is very convenient for the cement producer, however adds another operating step.

Co-composting of Biosludges

Current composting plants in Tasmania are processing a variety of food industry wastes, including chicken processing, abattoir and fish plant wastes, together with green (municipal and domestic) and agricultural (manure) wastes. What is proposed


is that biosludges from sewage treatment plants (STP’s) and industrial operations be co-composted with the existing green waste compost stream. This requires special precautions for personnel protection and to contain odours and aerosol emissions. If windrows are used then some degree of covering and forced or induced aeration may be needed, to avoid windrow turning during the early staged (weeks) of the lengthy (months) composting process. In general, composting operations are net users of water – the process generates heat, and this evaporates water which is lost and has to be replaced. Hence, the addition of sludges has potential to replace some of that water. These sludges are generally dewatered and/or dried before disposal to landfill, or to beneficial uses such as in agriculture and land remediation, as soil conditioner or fill. With these materials, pathogens are a concern and composting is a natural process that is capable of their thermal disinfection. Heavy metals are another concern where the sewage is in part from heavily industrialised areas. This can adversely affect the usefulness of the compost product, but this is not expected to be a concern in most of Tasmania. The main concern is transport. Rather than expensive road tanker style transport it is proposed that the sludges be dewatered, to what is called ‘spade-able consistency’, a state where water is not any further mechanically expressed, during handling, storage and transport. This is done by pressure filtration or by centrifugation. Belt press filters are fine for fixed plant situations but many of the STP’s are too small to warrant their own sludge dewatering installation and those that have employed open pan sludge drying facilities are under pressure to close these due to environmental concerns (for example, odour). It is proposed that several mobile centrifuge equipped facilities would better serve these STP’s and some of the industrial biosludge generators, and that these services might be provided by the co-composting plants or by the waste transport companies. Most plants will have capacity for aerobic storage of sludges for several days between visits from the mobile sludge dewatering units. These units would be trailer mounted, towed by the sludge transport truck, and could visit one or two STP’s per day, once or twice a week for example. Such units are already in operation in other states, primarily for handling shutdowns and other maintenance and unscheduled situations. Rendering

1) Additional rendering capacity for abattoir and poultry wastes would eliminate this loss of meat protein and the waste of landfill space.

2) Fish processing wastes have even more valuable meal and oil products and therefore rendering should also be considered for these wastes.


Whole fish rendering is being carried out already in Tasmania – producing very high value fish oils and it is believed this plant was designed with greater capacity than is presently being utilised, therefore there may be an opportunity to bring fish processing wastes to that plant. There are also prospects of major increases in fish farming capacity in the State, and there may well be room for a new rendering plant to cater for fish processing wastes. Fish oil recovery also provides opportunities for even greater value-adding by preparation of pharmaceutical grade Omega-3 intermediates and perhaps even commercial products.

Chemical Waste Treatment Facilities

Acid, alkali and other chemical wastes, solid and liquid, are treated by neutralisation and precipitation, with the resulting solids and sludges being stabilised by addition of fixation and solidification reactants such as Portland cement. The resulting ‘inert’ solids are then tested for any leachate issues and suitably disposed of, generally at a landfill. A single facility could handle all such wastes generated in Tasmania. Liquid wastes would be transported to the facility in tanker trucks or in tanks, drums, barrels or pallet containers of suitable materials. Solid wastes would be delivered in skips or bins. Every waste delivery needs to have a detailed description of source, contents, concentration and chemical composition and each container needs to be sampled and the sample checked for comparison with this description, and then suitably stored pending satisfactory completion of the chemical treatment process. With this information a suitable tank can be selected for on-site storage pending treatment. The facility will have many such storage tanks. As far as practicable acid wastes are used to neutralise alkali wastes, reductants to counteract oxidants, alkalis to precipitate metals and acids to split oils from water. Commercial grade acids and alkalis are also used where needed to achieve or adjust these neutralisation and precipitation reactions. Mixing and reaction tanks and pumps and pipe work of suitable materials are used for these purposes. All bulk storage tanks and container stores are fully and adequately bunded to contain spills, breaches and overflows. Precipitated sludges are dewatered and blended with fixation chemicals and are then deposited on a sealed and bunded pad where solidification, breaking and recovery of dried solid inert waste takes place, ready for transport to disposal facilities. At this stage the solid residues are sampled and tested to ensure they meet all requirements for disposal.


The treated liquid waste is sampled and tested prior to disposal to sewer or to storage pending secondary treatment. This latter may include oil emulsion breaking and oil and fat separation. The facility needs access to a robust sewer, one which offers plenty of dilution and delivers to a STP with capacity to handle trade waste. The entire facility can be outdoor or housed within a shed to avoid interruptions due to inclement weather. The main equipment comprises, a sufficient number of tanks, ponds or pits of special construction for safe containment of wastes pending testing and treatment, reaction tanks, pumps, blowers, piping and valves, instruments and controls and special chemical resistant surfaces, and all the necessary personal protection gear for safe operation of the facility, and a laboratory in which can be performed all of the testing to meet environmental and safety requirements and to perform trials of treatment reactions.


8. BUSINESS RISK ASSESSMENT

Section 7 looked in detail at the various technical solutions for the differing waste streams. The economic viability of the technical options was presented together with any assumptions made as to the commercial and financial structure. Notwithstanding whether any or none of the recommendations in this report are adopted, it is useful to be aware of the general principles when analysing the financial and commercial viability of waste treatment projects. For projects where private investment is used to fund all the costs associated with the development, construction and operation, the underlying principles are the same whether the project is large or small in capital value. Additionally, it may be that a private developer takes something from this report that leads to either a larger capital project than envisaged here for reasons which are only known to the developer and which enhance its viability. There are many stakeholders in making a privately financed project of this type successful in addition to their being many parts of the puzzle which need to be identified and completed prior to the start of construction. The better the understanding the stakeholders have as to the parts required, their importance and how they impact the economic viability of the project, the better it will aid its progress and success. Therefore, the intention of this section is to briefly outline the key issues which need to be addressed so that all stakeholders have an understanding of the kinds of things the developer will need to consider in their evaluation. For reasons of precedent, flexibility and the general ‘unknown’ of the waste supplier, we believe that long-term WSA’s will be difficult to secure. Whilst no conversations have taken place with waste generators on term of any WSA, we believe that a more realistic term will be a 3-5 year period with a possible option to extend.

8.1 Financial Viability

A detailed financial model is used to assess the economic viability of the options under consideration. The model can assess this viability over differing terms, that is, contracted life, but typically a 15 to 20 year life is assumed as this provides for the best opportunity of making the project viable whilst meeting the asset life expectation. There are a number of variables and model inputs that affect the financial viability of waste treatment projects and the key ones are detailed below.

Waste Types

The type, complexity and ultimately capital and operating costs of any facility are a function of waste types. A facility that needs to treat many multiple waste types (including both organic and non organic) will typically be more complex, require


sophisticated odour control equipment and have a more flexible material handling front end. Operating costs will also typically be higher.

Waste Volume This is a critical component in assessing the economic viability. Due to economies of scale, the higher the volume of waste that can be treated by the facility, the lower the unitised cost of treatment ($/tonne). Of course, the performance limitations of the technology need to be taken into consideration such that this principle holds until a certain plant capacity is reached. Construction Cost Generally, there hasn’t been a worse time over the past number of years to construct any kind of infrastructure. The global strength of the economy and the huge demand from China for minerals (e.g. iron ore), metals, coking coal and natural gas from Australia has meant that there is a skills and labour shortage across all disciplines. Construction companies, both big and small, and the suppliers of various services to those companies have full order books. This could potentially have the following effects on any project:

A higher than expected construction cost; Increased risk of the construction cost varying over short periods of time i.e.

month by month; Suppliers to the construction company do not hold their prices for more than

30 days; Labour and skills shortage and therefore higher salaries; Limited competition when going out to tender and therefore higher costs; High and variable cost of steel; and Risk of time delays.

Operation and Maintenance Costs

These costs are often overlooked as the main focus is on the initial capital cost of the plant. Given that plants of this type will operate for approximately 20 years, if maintained correctly, the quantum of the fixed and variable operating costs over this period can be substantial. The main fixed costs consist of plant operators, part of the electricity costs, annual plant insurances and any other fixed plant maintenance that is not a function of the plant operational hours. The variable costs would consist typically of consumables, chemicals, replacement parts for the plant and associated labour and part of the electricity costs. See Section 8.3 below for further details on the fixed and variable operating cost structure.


Development Costs There is typically a great deal of time, resource and cost that is expended during the period from when the project gets a green light to the start of construction. Construction only typically starts when all construction funding becomes unconditional. For projects where debt is raised to source funding, this point in time is typically referred to as ‘financial close’. For larger type projects (greater than $50m) using 3rd party debt, the development costs can be 20-30% of the overall total project costs. The time taken during the development period is dependent on many factors, such as permitting and approval time, and it is during this period that both the commercial and financial framework for the project is negotiated, agreed and documented. This can take 9 or more months to complete depending on size and complexity and be very resource and cost intensive. The primary development costs (additional to construction costs) are as follows:

Third party consultants (engineering, environmental, financing, tax etc.); Financing charges (payable to the financiers in the way of arrangement and

other fees); Legal costs; Permitting and approvals; Land; Environmental impact assessment; Construction insurance; Long-term strategic spares; Design and engineering costs (additional to detailed construction costs); Contingency; and Internal costs for the owner (if these are to be monetised).

Electricity Costs This can often be a large portion of the operating costs depending upon the technology. Supply with an electricity retailer will need to be secured. In the current climate it will be very difficult to secure a long-term (10 or more years) Power Purchase Agreement (PPA) which contains a defined escalating clause i.e. linked to the Consumer Price Index (CPI). If such a PPA can be secured for a waste project of this type it allows a major operating cost to be ‘fixed’ and as such the variability of the waste gate fee over time is lessened. A typical electricity tariff is made up of both a fixed and variable component and as such even if the plant operated for minimal time, a fee would still have to be paid to the electricity retailer. The split between the fixed and variable portion can be 50/50. This therefore increases the fixed costs for the waste treatment plant.


8.2 Commercial Viability The commercial risk factors are as follows: Security of Waste Supply This is one of the primary commercial risks unless a Capacity Charge (see Section 8.3) is agreed upon. If the developer takes the volume or supply risk associated with the waste, then they have no certainty of revenue over time. In the worst case scenario the revenue will be zero and in the best case the revenue will be a function of the maximum processing capacity of the plant. Or indeed, the revenue can sit anywhere in between these two extremes and also be cyclical on a month to month basis. This poses a couple of potential issues: Firstly, if the facility has been financed using third party debt, then the risk of not being able to service the debt is increased. If the debt is to have limited recourse back to the balance sheet of the developer (owner/investor), then it is going to be very difficult to attract this debt or if some debt is available it is likely to be highly priced. Secondly, if the plant is financed using 100% equity or quasi-equity then the developer runs the risk of ending up with a stranded asset in the worst case. Thirdly, there is a risk that another facility or facilities are built which provide a more cost effective means of treatment and most or all of the waste is then taken to this new facility. However, it is possible that a developer who understands and is currently an integral part of the controlled waste industry in Tasmania, can get comfortable with supply risk. This can only be determined following future discussions with the necessary stakeholders. Permitting and Approvals One of the major stumbling blocks for infrastructure development is permitting and approvals. Some issues to be considered include:

Clear identification of all the permits and approvals required Clear road map as to the process involved in securing each one Time schedule in securing each approval Cost of securing all permits and approvals Has precedent already been set? Which stakeholder parties are supportive and which are not? Do the non-supportive stakeholders have the ability to delay or stop

permitting? Will there be a strong ‘NIMBY’ approach i.e. adverse public reaction?


The above points will need to be taken into consideration, and well understood prior to going too far down the development path. The time, cost and resource involved in the permitting and approval process can be considered prohibitive to going forward with a development. Early and on-going communication with stakeholders will be a critical component. Waste Supply Agreements (WSA) It is typical to have some form of WSA between the developer and the waste supplier(s). This agreement sets the terms, conditions and obligations of both parties for the delivery and treatment of waste. It covers such things as obligation to deliver, type of waste streams, volumes, delivery and pricing. If multiple WSA’s are being put in place it is ideal to have a ‘standard’ agreement but this if often difficult to do during the negotiation phase with multiple parties. The risk lies in the timing in putting these agreements in place, agreed allocation of risk and it being successfully financed. Construction Contract Since the cost of construction will form the largest part of the overall project cost, the associated contracts will drive the successful financing of the project. The risks passed on to the developer from an increase in construction costs will also need to be minimised. Although the developer typically takes construction cost risk, in the strong construction market we are experiencing, some of this cost overrun may need to be passed through to the waste suppliers. One of the things that will drive any change in the construction cost is the time it takes to go through the development process to the start of construction. Early technical and financial analysis will determine the gate fee. At this stage an indicative cost is used for construction prior to detailed design. If a long period of time passes due to, for example, delay in permitting then it is possible that the cost of labour and materials has increased during this time which the construction contractor will not absorb and it will be passed through. Therefore, all stakeholders need to be aware of the need to act in a timely manner. The construction contractor needs to offer guarantees for plant performance, availability and schedule for construction and these are normally linked to agreed liquidated damages. A debt provider will typically require these guarantees. Operation and Maintenance (O&M) Contract Similarly with the construction contract the risks passed through from the O&M contractor because of changes in pricing needs to be minimised. Therefore, it is advantageous for stakeholders to act in a timely manner to lock in as many O&M costs as possible.


Technology Provider Guarantees The chosen technology needs to be proven with a good operating track record. Importantly, the technology provider needs to stand behind their product and offer performance guarantees and support in the case of problems. Typically the construction contractor will not offer performance guarantees for the main treatment technology unless there are back-to-back guarantees in place with the technology provider. Also, if the project is debt financed, the financier will need to have these performance guarantees in place. Financing Agreements If third party debt is raised to finance a portion of the project, the negotiation and finalisation of the suite of financing documents can be very time consuming and costly due to lawyer involvement. This process runs a lot more smoothly when the project risk is allocated fairly, waste security of supply has been addressed and the other issues as discussed in this Section 8.2 have been adequately addressed.

8.3 Tariff Structure

This section includes what could be a typical tariff structure for a privately financed project. The developer would primarily be responsible for all activities and costs associated with the development of the project. Ideally, the term of any WSA should be as long as possible to try and match the expected life of the plant, that is, 15 to 20 years. The primary advantage of entering into a long-term WSA for the waste generator is that the gate fee can be well defined moving out into the future with often the only variables subject to change being linked to CPI. However, the waste generator needs to be sure they will still be producing waste over the long-term as they will have a contingent liability under the WSA if they terminate early. Conversely, whilst the shorter term offers the waste generator more flexibility for the ‘unknowns’, it does mean that after the term ends the gate fee is renegotiated and this could mean an increase in cost, especially if there are other waste generators that have entered the market and are looking for an alternative treatment solution. It should be remembered that any treatment plant will have a finite treatment capacity (e.g. tonnes/hour) and if most of this waste is contracted then it leaves little room for other waste generators to utilise the plant unless it is expanded.

The developer will normally guarantee that the treatment plant will be available for operation for a defined period of time. We would expect this to be approximately 90% on an annual basis.


Gate Fee There are a few ways in which the developer could structure the gate fee. The least risky is to incorporate a Capacity Charge and since this is a fixed monthly fee payable by the waste generator (subject to performance criteria being met), the financial viability of the project remains robust even if the plant operates at well below its capacity or not at all. The developer in this case takes little or no waste supply (demand) risk. A typical three-part tariff structure incorporating this Capacity Charge is shown below. Alternatively, it could be that the developer gets very comfortable with waste supply risk and is willing to share or take 100% of this risk. In this case there would be a minimal or no fixed payment from the waste generator and the tariff would be a completely variable fee ($/tonne) based wholly on the tonnes processed. The base price for waste treatment delivered to the waste generator could be broken into three components as detailed below. It has been worded (italics) to reflect a possible proposal from the developer to a single waste generator.

(a) Capacity Charge The fixed monthly Capacity Charge is paid to service any debt payments (principal plus interest) and to give a Return on Equity. Since these charges are predictable, these amounts are known and can be specifically quoted for each year of the WSA. The Capacity Charge is so named since it will vary with the overall system capacity available as opposed to actual tonnes processed. The base Capacity Charge for waste treatment capacity provided to waste generator shall be $[A]/tonne - month. The Capacity Charge will be applicable for the demonstrated net waste treatment capacity of the project not to exceed [Y]tonnes/hour. Waste generator shall have first call for the first [Y]tonnes/hour of waste treatment capacity of the project. The Capacity Charge will vary for the duration of the Waste Supply Agreement, and will be subject to an escalation of [2.5]% per annum. [Note: the Capacity Charge can in theory be fixed or escalate with any chosen annual percentage and not be linked to CPI. This, to a large degree, gives security of pricing going forward] The Capacity Charge will be due regardless of the amount of waste delivered by waste generator in a month, providing the demonstrated net capacity is at least [Y]tonnes/hour and provided the availability guarantee is met.

(b) Fixed Operations & Maintenance Charge (FOM) The FOM costs are typically plant staff, insurances and any other fixed O&M costs which will be incurred regardless of whether the plant operates or not.


The base Fixed Operations & Maintenance Charge for waste treatment capacity provided to waste generator shall be $[B]/tonne - month as of [dd/mm/yy]. The Fixed Operations & Maintenance Charge will be applicable for the demonstrated net waste treatment capacity of the project not to exceed [Y]tonnes/hour. Waste generator shall have first call for the first [Y]tonnes/hour of waste treatment capacity of the project. The Fixed Operations & Maintenance Charge shall vary in the future with inflation as follows: FOM month m = FOM dd/mm/yy x CPI month m / CPI dd/mm/yy The Fixed Operations & Maintenance Charge will be due regardless of the amount of waste delivered by waste generator in a month, providing the demonstrated net capacity is at least [Y]tonnes/hour and provided the availability guarantee is met.

(c) Variable Operations & Maintenance Charge (VOM) In addition to the fixed charges, the variable costs such as operations and maintenance consumables, chemicals and plant maintenance linked to operating hours are generally passed through in the pricing structure through a variable payment per tonne. It is assumed that these charges are a straight pass through of cost and do not provide any cash flow which increases the Return on Equity. The base Variable Operations & Maintenance Charge to waste generator for tonnes treated shall be $[C]/tonne. The Variable Operations & Maintenance Charge will be applicable only for the waste actually treated by developer. The Variable Operations & Maintenance Charge shall vary in the future with inflation as follows: VOM month m = VOM dd/mm/yy x CPI month m / CPI dd/mm/yy

8.4 Ownership Options

Asset owned by Council Assuming a ‘council’ is the only waste generator, in this scenario, the council is responsible for all aspects and funding of the project. The council will employ third party advisors such as engineering, environmental and financial but ultimately there is minimal risk transferred from the council to other parties. Whilst a fixed price construction contract can possibly be secured, although this is increasingly more difficult and costly in the current hot market, the construction risk is subject to a limit of liability. On the plus side, the cost of the council developing the project should, in theory, be less than undertaking a third party Build, Own, Operate (BOO) project, but it will be dependent upon the quality and experience of the advisors retained by council and the council’s internal project management capability. Ultimately, the decision between a council-owned project and a BOO comes down to risk transfer against cost to the council.


Asset owned by a third party (developer) One of the more typical delivery methods is a Build, Own, Operate (BOO) project. The developer of the project takes the majority of the risk associated with development, permitting, construction, financing and operation of the asset. For this model to work, the council does need to meet the developer part of the way with respect to risk transfer. The developer will typically look to raise project finance debt which can be very time consuming and the cost to the council over the life of the project will be more in this model. Again, it comes down to what cost the council puts on risk transfer.

For this Controlled Waste project we believe that the best outcome would be for the private sector to own and operate the treatment plants.

8.5 Financing Structure

Equity funding (or balance sheet funding) Total funding for the project is provided by the owner as 100% equity with zero debt. This is generally an expensive way of funding projects since the cost of equity is nearly always more expensive than the cost of debt. The cost of processing the waste will therefore be higher to meet a specified return on equity.

Debt and Equity funding (via 3rd party financiers) Most capital infrastructure projects are typically financed in this way. The project is structured in such a way as to attract the highest proportion of debt possible. This is achieved by addressing many things such as providing a complete risk matrix and mitigation strategy for all aspects of the project, balance sheet strength of the owner, security offered by the owner, fixed price contracts, proven technology, experienced stakeholders (developer, constructor, operator etc). However, there are often limitations to the amount of debt that can be secured if the ‘cover’ ratios as shown by the financial model are not high enough such that the free cash flow from the project is insufficient to service the debt. The use of equity and debt provides for a lower weighted average cost of capital (WACC) and therefore a lower gate fee whilst maintaining the Return on Equity requirements of the developer. Alternatively, if the project is owned by the council, the capital will come from council and will therefore, in theory, be cheaper than third party debt. However, it is still capital and will need to fall within budget.

Other debt finance inputs

Term of debt Interest rate during the construction period Interest period during the operating period Debt to equity ratio Debt arrangement fee Debt commitment fee Working capital reserve


Debt service reserve Debt Service Cover Ratio Loan Life Cover Ratio

Return on Equity (RoE) Calculation When the financial model contains all the inputs, the gate fee can be varied to determine the RoE that will be required to make the project commercially viable. Alternatively, if there is a maximum ceiling for the gate fee this can be set in the model and this will drive the RoE. The developer can then determine if this RoE is sufficient to make the investment in the project.

8.6 Risk Matrix

The allocation of the various risk factors in developing a waste treatment project is one of the key issues in agreeing on a waste supply agreement and the other key agreements. One of the main reasons that negotiations become protracted and often end up with higher gate fees than expected is the inequitable division of this project risk. The risk for any particular part of the project should lie with the party most suited to manage that risk. In privately financed projects, it is common for the developer to carry most of the risk but in some things the risk should either lie with the contracting party or be shared.

Table 5 shows a typical risk allocation matrix and its approach to the management of the identified risks. For example purposes, we have assumed that the investor in the new infrastructure is called ‘developer’ and the contracting party providing the waste for treatment is a ‘council’. Table 5 Risk Allocation Matrix

Category Primary

Risk Owner

Secondary Risk

Owner

Possible Risk Management Plan

Financial / Commercial

Financing of Project including development cost overrun, interest rate and foreign exchange risk

Developer - ASX listed company. Strong balance sheet. Hedging

Financing of Upgrades

Developer

-

As above

Land Tenure

Council

Developer Ownership responsibility of

Council. Developer accepts conditions of lease.

Market Demand

Developer or Council

Shared

For a ‘Developer’ - detailed analysis of market


Category Primary

Risk Owner

Secondary Risk

Owner


performed. Developer is a player in the local waste market and therefore understands the dynamics. Developer may ask for contractual obligation for all waste to be delivered to the plant without an obligation of volume.

Revenue Collection

Developer

-

Provide Council with a fair and transparent rate structure.

Inflation / Deflation

Council

-

Contract provides for rise and fall provisions.

Infrastructure Development

Design, Construct and Commissioning

Developer

-

Integrated and experienced team lead by Developer and supported technology and equipment suppliers.

Technology Capability

Developer

-

Facility proposed consists of technologies that are robust and proven.

Operations

Performance Standards

Developer

-

Facility proposed is based on proven reference facilities that successfully process waste streams of a similar nature. Performance based agreement.

Technology Flexibility Developer Council Facility proposed has the ability to maintain any segregation of the waste stream and accommodate seasonal fluctuations in quantity and quality. In addition, the ability to treat non-contracted waste types.


Category Primary

Risk Owner

Secondary Risk

Owner


Operations and Maintenance Requirements Compliance Verification

Developer - Implement planned preventative maintenance programme, hold adequate spares, either on-site or on consignment, and implement quality and environmental management systems in accordance with Developer’s corporate standards.

Changed Operating Requirements

Shared Shared Developer commits to work in partnership with Council to meet the changing needs of the project.

Waste Quantity for Processing

Developer Council Provision has been built into the design to allow for growth, if applicable, over a 20 year period.

Waste Material Characteristics

Developer Council A realistic envelope for the waste stream will be developed and it will be agreed with Council during the development and implementation of the project. That is, the technology is designed based on an envelope of certain waste materials only.

Disposal of Materials Developer - The process is proven to treat certain waste streams with a guaranteed percentage of residuals if applicable.

Environment

Compliance with Permitting and Approval Licences

Developer - Work with Council to ensure that all conditions are met.

Existing Laws

Developer

-

The facility will be designed


Category Primary

Risk Owner

Secondary Risk

Owner


to comply with all relevant legislative requirements.

Change in Laws Shared Council Developer to work in partnership with the Council to manage any change in law within the provisions of the contract.

Natural Disaster Developer Council Developer will implement sound engineering design principles to ensure that the effects of any natural disaster are minimised. However, this it typically a Force Majeure event.

Socio-Political

Community Relations and Education

Council Developer Developer will work in support of the council in its community and stakeholder education initiatives.


9. RECOMMENDATIONS

Outlined below is a list of key recommendations provided throughout the report as listed in the Executive Summary.

1) The Tasmanian Government needs to apply clear and consistent regulation to controlled waste management practices and infrastructure across the State that is fully enforceable. This is a necessary requirement to promote basic compliance, and remove significant risk factors for the investment in new or upgraded infrastructure.

2) The Department of Tourism, Arts and the Environment should develop a ‘Controlled

Waste Management Methods Guide’ – a high-level tool to advise, educate and apply consistent management practices throughout Tasmania. The guide would provide a current list of appropriate treatment, recovery and disposal facilities, transporters, and waste handlers operating in the State, as well as a clear outline of management and disposal practices for all controlled wastes. Information in the guide would need to be updated on an ongoing basis, particularly to incorporate developments in best practice standards and technologies. This should be an electronic, web based application available to the public.

3) There is a significant opportunity for the State Government to play a facilitation role

with Tasmanian industry, by implementing a program involving targeted controlled waste audits and plans to assist and encourage waste reduction and efficiency measures for key controlled waste generators. The program will provide improved environmental outcomes, and will also make Tasmanian industry more financially competitive. This will also support initiatives such as the Tasmanian Government’s CleanBiz Program implemented in 2006.

4) Key growth industries in Tasmania will deal with the issues of both increasing volume

and increasing cost of waste management. The State Government should consider the development of industry-specific waste plans to assist cost management, business expansion and new investments. Specific industries that are experiencing growth in the State also have some of the most significant controlled waste issues and include:

Mining and metals industry; Food and beverage industry; Aquaculture; Healthcare; and Tourism (quarantine waste from ships and increased visitor numbers).


5) Resource recovery and recycling should be viewed as an opportunity for reducing the

cost of waste and environmental impact in Tasmania. Significant ways the State Government can enhance this include:

Providing a facilitation and support role for industry to encourage the development of new options and processes to reduce use, recycle and recover resources;

Improving education within industry, government and the general public; Considering the re-establishment of the Tasmanian Waste Exchange (TWEX)

Program (initially implemented in 2001); and Promoting Tasmania as a centre for excellence in sustainable waste

management.

6) It is critical that State and Local Government in Tasmania work more effectively together, as there are currently overlapping (and at times, ambiguous) roles and responsibilities assigned for controlled waste regulation, control, management and facility operation. Adopting a more cooperative approach will help to deliver the following outcomes:

A reduction in ‘cost-shifting’ for regulation, compliance and provision of infrastructure;

Consistent and uniform regulation for controlled waste management facilities and practices; and

Improved infrastructure planning and efficiency, specifically within regions, leading to improved infrastructure and potential budget savings.

7) The State Government needs to maintain open dialogue with mainland States and

Territories, in order to ensure opportunities for the transboundary movement of controlled wastes are secured under the National Environment Protection Measure (NEPM). Tasmania’s right to trade with other jurisdictions should be kept intact and the NEPM implemented through appropriate negotiation. There needs to be an understanding that Tasmania is a small controlled waste generator, by mainland standards, and requires assistance where possible to manage such wastes.

8) Discussions between Biosecurity Australia, the Australian Quarantine and Inspection

Service, Quarantine Tasmania, the Australian Antarctic Division and the Department of Tourism, Arts and the Environment will continue, with a view to finalising the position on transporting quarantine waste from the Australian Antarctic Territory for treatment and disposal in Tasmania. The type and volume of waste should then be determined, with a view to reassessing the treatment and disposal options.

9) Undertake further due diligence on the high temperature pyrolysis plant for the treatment of tyres, with a view to identifying developers. This report only considers domestic volumes and some commercial volumes. Further opportunities exist if the tyres from operating mines could be used. An audit on the volume of tyres from mines would be necessary.


10) Undertake discussions with Cement Australia regarding the use of the cement kiln at

Railton. Discussions could involve the State Government, Tasmanian Minerals Council, Cement Australia and possibly a developer. Further technical and economic due diligence would be required.

11) Fund a feasibility study (or studies) into establishing additional abattoir rendering facilities and incorporating poultry waste; plus facilities for rendering fish processing wastes. Investigate further opportunities for high value meal and oil products from fish processing wastes.

12) Fund a feasibility study into establishing 4 regional co-composting facilities for

biosludges, specifically concentrating on firming up waste volumes, biosludges and green waste, and engaging in discussions with waste generators to establish the commercial basis upon which the wastes could be provided. Furthermore, establish the market and commercial basis for the compost.

13) Identify opportunities for incorporating a neutralisation, precipitation and solidification

plant, possibly at a sewage treatment plant site. Discuss the appetite of the regional water authority to look at the project and undertake further due diligence.


10. REFERENCES

Legislation

State:

Environmental Management and Pollution Control Act 1994

Environmental Management and Pollution Control (Waste Management) Regulations 2000

Environmental Management and Pollution Control (Controlled Waste Tracking) Regulations 2007 (Draft)

Land Use Planning and Approvals Act 1993

State Policies and Projects Act 1993

Classification and Management of Contaminated Soil for Disposal, August 2006 (Bulletin 105)

Commonwealth:

National Environment Protection (Movement of Controlled Waste between States and Territories Measure 2004, NEPC

Quarantine Act 1908

Reports / Guidelines

Asterisk One (2006) A Household Hazardous Waste Collection System for Tasmania – Program Design Report, prepared by Asterisk One for DTAE, Sydney Athena Waste Management (2006) A Report on Waste Transfer Station Infrastructure and Operations in Tasmania, Athena Waste Management for DTAE and the Board of Environmental Management and Pollution Control, Hobart Blue Environment (2007) Draft Waste Management Strategy for Tasmania: Background Report, prepared by Blue Environment for DTAE, Melbourne DPIWE (2004) Classification and Management of Contaminated Soil for Disposal DPIWE, Hobart. DPIWE (2004) Controlling Waste: A Six-Point Plan for Managing Controlled Waste 2004-05, DPIWE, Hobart


DPIWE (2004) Landfill Sustainability Guide, DPIWE, Hobart

DPIWE (2005) Approved Management Method for Clinical and Related Waste DPIWE, Hobart DPIWE/DTAE (2005) Controlled Waste Inventory: Controlled Waste Generation and Management in Tasmania, 2004-2005 DTAE, Hobart

DTAE (2006) The Approved Management Method for Biosolids Reuse DTAE, Hobart

DTAE (2007) Controlled Waste Tracking Newsletter, DTAE, Launceston

DTAE Internal reports e.g. summary report of Inventory

Environment Division website, DTAE (www.environment.tas.gov.au)

EPA Victoria website, Prescribed Industrial Waste Database (http://www.epa.vic.gov.au/waste/) NEPC, Report on the Implementation of the Movement of Controlled Waste between States and Territories NEPM: Annual reports for the 2001/02, 2002/03, 2003/04, 2004/05 and 2005/06 financial years


11. APPENDICES

Appendix 1 Controlled Waste Lists 1 and 2, National Environment Protection (Movement of Controlled Waste

between States and Territories) Measure 200

Current and Future Controlled Waste Practices In Tasmania - SIA

LIST 1: WASTE CATEGORIES

WASTE STREAM OR WASTES HAVING AS CONSTITUENTS: Acidic solutions or acids in solid form Animal effluent and residues (abattoir effluent, poultry and fish processing wastes) Antimony; antimony compounds Arsenic; arsenic compounds Asbestos Barium compounds (excluding barium sulfate) Basic solutions or bases in solid form Beryllium; beryllium compounds Boron compounds Cadmium; cadmium compounds Ceramic‐based fibres with physico‐chemical characteristics similar to those of asbestos Chlorates Chromium compounds (hexavalent and trivalent) Clinical and related wastes Cobalt compounds Containers which are contaminated with the residues of substances referred to in this list Copper compounds Cyanides (inorganic) Cyanides (organic) Encapsulated, chemically‐fixed, solidified or polymerised wastes Ethers Filter cake Fire debris and fire washwaters Flyash Grease trap waste Halogenated organic solvents Highly odorous organic chemicals (including mercaptans and acrylates) Inorganic fluorine compounds excluding calcium fluoride Inorganic sulfides Isocyanate compounds Lead; lead compounds


Mercury; mercury compounds Metal carbonyls Nickel compounds Non‐toxic salts Organic phosphorus compounds Organic solvents excluding halogenated solvents Organohalogen compounds ‐ other than substances referred to in this list Perchlorates Phenols, phenol compounds including chlorophenols Phosphorus compounds excluding mineral phosphates Polychlorinated dibenzo‐furan (any congener) Polychlorinated dibenzo‐p‐dioxin (any congener) Residues from industrial waste treatment/disposal operations Selenium; selenium compounds Sewage sludge and residues including nightsoil and septic tank sludge Soils contaminated with a controlled waste

Surface active agents (surfactants) containing principally organic constituents and which may contain metals and inorganic materials

Tannery wastes (including leather dust, ash, sludges and flours) Tellurium; tellurium compounds Thallium; thallium compounds Triethylamine catalysts for setting foundry sands Tyres Vanadium compounds

Waste chemical substances arising from research and development or teaching activities including those which are not identified and/or are new and whose effects on human health and/or the environment are not known

Waste containing peroxides other than hydrogen peroxide Waste from heat treatment and tempering operations containing cyanides Waste from manufacture, formulation and use of wood‐preserving chemicals Waste from the production and preparation of pharmaceutical products Waste from the production, formulation and use of biocides and phytopharmaceuticals


Waste from the production, formulation and use of inks, dyes, pigments, paints, lacquers and varnish

Waste from the production, formulation and use of organic solvents

Waste from the production, formulation and use of photographic chemicals and processing materials

Waste from the production, formulation and use of resins, latex, plasticisers, glues and adhesives

Waste mineral oils unfit for their original intended use Waste of an explosive nature not subject to other legislation Waste oil/water, hydrocarbons/water mixtures or emulsions Waste pharmaceuticals, drugs and medicines Waste resulting from surface treatment of metals and plastics

Waste substances and articles containing or contaminated with polychlorinated biphenyls (PCBs), polychlorinated naphthalenes (PCNs), polychlorinated terphenyls (PCTs) and/or polychlorinated biphenyls (PBBs)

Waste tarry residues arising from refining, distillation and any pyrolytic treatment Wool‐scouring wastes Zinc compounds


Table of Waste Codes (To be used in conjunction with List 1, Schedule A of the National Environmental Protection Measure for the Movement of Controlled Wastes between States and Territories)

Acidic solutions or acids in solid form B100

Animal effluent and residues (abattoir effluent, poultry and fish processing wastes) K100 Antimony; antimony compounds D170 Arsenic; arsenic compounds D130 Asbestos N220 Barium compounds (excluding barium sulfate) D290 Basic solutions or bases in solid form C100 Beryllium; beryllium compounds D160 Boron compounds D310 Cadmium; cadmium compounds D150

Ceramic‐based fibres with physico‐chemical characteristics similar to those of asbestos N230 Chlorates D350 Chromium compounds (hexavalent and trivalent) D140 Clinical and related wastes R100 Cobalt compounds D200

Containers and drums contaminated with the residues of substances referred to in this list N100 Copper compounds D190 Cyanides (inorganic) A130 Cyanides (organic) M210 Encapsulated, chemically‐fixed, solidified or polymerised wastes N160 Ethers G100 Filter cake N190 Fire debris and fire washwaters N140 Fly ash N150 Grease trap waste K110 Halogenated organic solvents G150 Highly odorous organic chemicals (including mercaptans and acrylates) M260 Inorganic fluorine compounds excluding calcium fluoride D110 Inorganic sulfides D330 Isocyanate compounds M220 Lead; lead compounds D220


Mercury; mercury compounds D120 Metal carbonyls D100 Nickel compounds D210 Non‐toxic salts D300 Organic phosphorus compounds H110 Organic solvents excluding halogenated solvents G110 Organohalogen compounds ‐ other than substances referred to in this list M160 Perchlorates D340 Phenols, phenol compounds including chlorophenols M150 Phosphorus compounds excluding mineral phosphates D360 Polychlorinated dibenzo‐furan (any congener) M170 Polychlorinated dibenzo‐p‐dioxin (any congener) M180 Residues from industrial waste treatment/disposal operations T190 Selenium; selenium compounds D240 Sewage sludge and residues including nightsoil and septic tank sludge K130 Soils contaminated with a controlled waste N120

Surface active agents (surfactants) containing principally organic constituents and which may contain metals and inorganic materials M250 Tannery wastes including leather dust, ash, sludges and flours K140 Tellurium; tellurium compounds D250 Thallium; thallium compounds D180 Triethylamine catalysts for setting foundry sands M230 Tyres T140 Vanadium compounds D270

Waste chemical substances arising from research and development or teaching activities including those which are not identified and/or are new and whose effects on human health and/or the environment are not known T100 Waste containing peroxides other than hydrogen peroxide E100 Waste from heat treatment and tempering operations containing cyanides A110 Waste from manufacture, formulation and use of wood‐preserving chemicals H170 Waste from the production and preparation of pharmaceutical products R140

Waste from the production, formulation and use of biocides and phytopharmaceuticals H100


Waste from the production, formulation and use of inks, dyes, pigments, paints, lacquers and varnish F100 Waste from the production, formulation and use of organic solvents G160

Waste from the production, formulation and use of photographic chemicals and processing materials T120

Waste from the production, formulation and use of resins, latex, plasticisers, glues and adhesives F110 Waste mineral oils unfit for their original intended use J100 Waste of an explosive nature not subject to other legislation E120 Waste oil/water, hydrocarbons/water mixtures or emulsions J120 Waste pharmaceuticals, drugs and medicines R120 Waste resulting from surface treatment of metals and plastics A100

Waste substances and articles containing or contaminated with polychlorinated biphenyls (PCBs), polychlorinated naphthalenes (PCNs), polychlorinated terphenyls (PCTs) and/or polychlorinated biphenyls (PBBs) M100

Waste tarry residues arising from refining, distillation and any pyrolytic treatment J160 Wool‐scouring wastes K190 Zinc compounds D230


Appendix 2 Controlled Waste List, Tasmanian Context

Adapted from ‘List 1’ of NEPM


Waste Code Waste Code Description Fee Class

A100 Waste resulting from surface treatment of metals and plastics C

A110 Waste from heat treatment and tempering operations containing cyanides C

A130 Cyanides (inorganic) C

B100 Acidic solutions or acids in solid form B

C100 Basic solutions or bases in solid form B

D100 Metal carbonyls C

D110 Inorganic fluorine compounds excluding calcium fluoride C

D120 Mercury; mercury compounds C

D130 Arsenic; arsenic compounds C

D140 Chromium compounds (hexavalent and trivalent) C

D150 Cadmium; cadmium compounds C

D160 Beryllium; beryllium compounds C

D170 Antimony; antimony compounds C

D180 Thallium; thallium compounds C

D190 Copper compounds C

D200 Cobalt compounds C

D210 Nickel compounds C

D220 Lead; lead compounds C

D230 Zinc compounds C

D240 Selenium; selenium compounds C

D250 Tellurium; tellurium compounds C

D270 Vanadium compounds C

D290 Barium compounds (excluding barium sulphate) C

D300 Non toxic salts C

D310 Boron compounds C

D330 Inorganic sulfides C

D340 Perchlorates C

D350 Chlorates C

D360 Phosphorus compounds excluding mineral phosphates C

E100 Waste containing peroxides other than hydrogen peroxide B


E120 Waste of an explosive nature not subject to other legislation B

F100 Waste from the production, formulation and use of inks, dyes, pigments, paints, lacquers and varnish

B

F110 Waste from the production, formulation and use of resins, latex, plasticisers, glues and adhesives

B

G100 Ethers B

G110 Organic solvents excluding halogenated solvents B

G150 Halogenated organic solvents B

G160 Waste from the production, formulation and use of organic solvents B

H100 Waste from the production, formulation and use of biocides and phytopharmaceuticals

C

H110 Organic phosphorus compounds C

H170 Waste from manufacture, formulation and use of wood-preserving chemicals C

J100 Waste mineral oils unfit for their original intended use B

J120 Waste oil/water, hydrocarbons/water mixtures or emulsions C

J160 Waste tarry residues arising from refining, distillation, and any pyrolytic treatment C

J200 Materials contaminated with mineral oils where the oils are free or expressible C

K100 Animal effluent and residues (abattoir effluent, poultry and fish processing waste) A

K110 Grease trap waste A

K130 Sewage sludge and residues including nightsoil and septic tank sludge A

K140 Tannery wastes (including leather dust, ash, sludges and flours) C

K190 Wool scouring waste A

M100 Waste substances and articles containing or contaminated with polychlorinated biphenyls (PCBs), polychlorinated naphthalenes (PCNs), polychlorinated terphenyls (PCTs) and/or polybrominated biphenyls (PBBs)

C

M150 Phenols, phenol compounds including chlorophenols C

M160 Organohalogen compounds - other than substances referred to in this list C

M170 Polychlorinated dibenzo-furan (any congener) C

M180 Polychlorinated dibenzo-p-dioxin (any congener) C

M210 Cyanides (organic) C

M220 Isocyanate compounds C

M230 Triethylamine catalysts for setting foundry sands C

M250 Surface active agents (surfactants), containing principally organic constituents and which may contain metals and inorganic materials

C

M260 Highly odorous organic chemicals (including mercaptans and acrylates) C


N100 Containers which are contaminated with residues of substances referred to in this list C

N120 Soils contaminated with a controlled waste C

N140 Fire debris and fire washwaters C

N150 Fly ash C

N160 Encapsulated, chemically-fixed, solidified or polymerised wastes C

N190 Filter cake C

N220 Asbestos C

N230 Ceramic-based fibres with physico-chemical characteristics similar to those of asbestos

C

Q100 Quarantine derived waste not defined by other controlled waste categories C

R100 Clinical and related wastes A

R120 Waste pharmaceuticals, drugs and medicines A

R140 Waste from the production and preparation of pharmaceutical products A

T100 Waste chemical substances arising from research and development or teaching activities including those which are not identified and/or are new and whose effects on human health and/or the environment are not known.

C

T120 Waste from the production, formulation and use of photographic chemicals and processing materials

C

T140 Tyres C

T190 Residues from industrial waste treatment/disposal operations C


Appendix 3 Grouping of Controlled Wastes, Department of Tourism, Arts and the Environment

(Taken from Controlled Waste Inventory: Controlled Waste Generation and Management in Tasmania, 2004-5)


Appendix 4 SIA Grouping of Controlled Waste Adapted from DTAE’s list in Appendix 3 and considering common waste handling/disposal

practices


Waste Category Waste Types

Cyanides (inorganic)

A100 Waste resulting from surface treatment of metals and plastics A110 Waste from heat treatment and tempering operations containing cyanides A130 Cyanides (inorganic)

Acid solids and solutions Alkaline solids and solutions Laboratory / photography chemicals

B100 Acidic solutions or acids in solid form (with pH value of 4 or less) C100 Basic solutions or bases in solid form (with pH value of 9 or more) T100 Waste chemical substances arising from research and development or teaching activities including those which are not identified and/or are new and whose effects on human health and/or the environment are not known T120 Waste from the production, formulation and use of photographic chemicals and processing materials

Inorganic chemicals

D100 Metal carbonyls D110 Inorganic fluorine compounds excluding calcium fluoride D120 Mercury; mercury compounds D130 Arsenic; arsenic compounds D140 Chromium compounds (hexavalent and trivalent) D150 Cadmium; cadmium compounds D160 Beryllium; beryllium compounds D170 Antimony; antimony compounds D180 Thallium; thallium compounds D190 Copper compounds D200 Cobalt compounds D210 Nickel compounds D220 Lead; lead compounds D230 Zinc compounds D240 Selenium; selenium compounds D250 Tellurium; tellurium compounds


D270 Vanadium compounds D290 Barium compounds (excluding barium sulphate) D300 Non toxic salts D310 Boron compounds D320 Phosphorus compounds excluding mineral phosphates D330 Inorganic sulphides D340 Perchlorates D350 Chlorates

Reactive chemicals

E100 Waste containing peroxides other than hydrogen peroxide

E120 Wastes of an explosive nature not subject to other legislation


F100 Waste from the production, formulation and use of inks, dyes, pigments, paints, lacquers and varnish F110 Waste from the production, formulation and use of resins, latex, plasticisers, glue and adhesives

H100 Waste from the production, formulation and use of biocides and phytopharmaceuticals H110 Organic phosphorus compounds H170 Waste from the manufacture, formulation and use of wood-preserving chemicals


G100 Ethers

G110 Organic solvents excluding halogenated solvents G150 Halogenated organic solvents G160 Waste from the production, formulation and use of organic solvents


J100 Waste mineral oils unfit for their original intended use J120 Waste oil/water, hydrocarbons/water mixtures or emulsions J160 Waste tarry residues arising from refining, distillation, and any pyrolytic treatment

K100 Animal effluent and residues (abattoir effluent, poultry and


Putrescible / organic wastes fish processing waste) K110 Grease trap waste K130 Sewage sludge and residues including nightsoil and septic tank sludge K140 Tannery wastes (including leather dust, ash, sludges and flours) K190 Wool scouring waste

Organic chemicals

M100 Waste substances and articles containing or contaminated with polychlorinated biphenyls (PCBs), polychlorinated naphthalenes (PCNs), polychlorinated terphenyls (PCTs) and/or polybrominated biphenyls (PBBs) M150 Phenols, phenol compounds including chlorophenols M160 Organohalogen compounds including chlorophenols M170 Polychlorinated dibenzo-furan (any congener) M180 Polychlorinated dibenzo-p-dioxin (any congener) M210 Cyanides (organic) M220 Isocyanate compounds M230 Triethylamine catalysts for setting foundry sands M250 Surface active agents (surfactants), containing principally organic constituents and which may contain metals and inorganic materials

M260 Highly odorous organic chemicals (including mercaptans and acrylates)

Solid / sludge wastes requiring special handling

N100 Containers which are contaminated with residues of substances referred to in this list N120 Soils contaminated with a controlled waste N140 Fire debris and fire washwaters N150 Fly ash N160 Encapsulated, chemically-fixed, solidified or polymerised wastes N190 Filter cake N205 Residues from industrial waste treatment/disposal options N220 Asbestos N230 Ceramic-based fibres with physio-chemical characteristics similar to those of asbestos



R100 Clinical and related wastes R120 Waste pharmaceuticals, drugs and medicines R140 Waste from the production and preparation of pharmaceutical products

Waste tyres

T140 Tyres

Security materials

Security materials, currency notes, contraband, confiscated drugs

Quarantine wastes

Quarantined materials from seaports and airports, as well as wastes from the Australian Antarctic Territory


Appendix 5 SIA Tasmanian Controlled Waste Generation Estimates


SIA Controlled Waste Generation Estimates for Tasmania*

NEPM waste code

Wastes or waste streams with the following constituents

SIA's generation estimate

(TPA) A100 Waste resulting from surface treatment of metals and plastics - A110 Waste from heat treatment and tempering operations containing cyanides - A130 Cyanides (inorganic) - B100 Acidic solutions or acids in solid form 200 C100 Basic solutions or bases in solid form 410 D100 Metal carbonyls - D110 Inorganic fluorine compounds excluding calcium fluoride - D120 Mercury; mercury compounds - D130 Arsenic; arsenic compounds - D140 Chromium compounds (hexavalent and trivalent) - D150 Cadmium; cadmium compounds 15 D160 Beryllium; beryllium compounds - D170 Antimony; antimony compounds - D180 Thallium; thallium compounds - D190 Copper compounds 35 D200 Cobalt compounds - D210 Nickel compounds - D220 Lead; lead compounds 1700 D230 Zinc compounds 580 D240 Selenium; selenium compounds - D250 Tellurium; tellurium compounds - D270 Vanadium compounds - D290 Barium compounds (excluding barium sulfate) - D300 Non-toxic salts 2,000 D310 Boron compounds - D330 Inorganic sulfides - D340 Perchlorates - D350 Chlorates - D360 Phosphorus compounds excluding mineral phosphates - E100 Waste containing peroxides other than hydrogen peroxide - E120 Waste of an explosive nature not subject to other legislation - F100 Waste from the production, formulation and use of inks, dyes, pigments, paints, lacquers and varnish 230 F110 Waste from the production, formulation and use of resins, latex, plasticisers, glues and adhesives - G100 Ethers - G110 Organic solvents excluding halogenated solvents 270 G150 Halogenated organic solvents 33 G160 Waste from the production, formulation and use of organic solvents 11 H100 Waste from the production, formulation and use of biocides and phytopharmaceuticals - H110 Organic phosphorus compounds - H170 Waste from manufacture, formulation and use of wood-preserving chemicals - J100 Waste mineral oils unfit for their original intended use 4,500


J110 Waste hydrocarbons 250 J120 Waste oil/water, hydrocarbons/water mixtures or emulsions 6,100 J160 Waste tarry residues arising from refining, distillation and any pyrolytic treatment 32 J200 Materials contaminated with mineral oils where the oils are free or expressible 820 K100 Animal effluent and residues (abattoir effluent, poultry and fish processing wastes) - poultry processing 2,700 K100 Animal effluent and residues (abattoir effluent, poultry and fish processing wastes) - abattoir effluent 20,000 K100 Animal effluent and residues (abattoir effluent, poultry and fish processing wastes) - fish processing 10,000 K110 Grease trap waste 3,500 K120 Grease interceptor trap waste - industrial 2,400 K130 Sewage sludge and residues including nightsoil and septic tank sludge 25,800 K140 Tannery wastes including leather dust, ash, sludges and flours -

K190 Wool-scouring wastes 3

M100 Waste substances and articles containing or contaminated with polychlorinated biphenyls (PCBs), polychlorinated naphthalenes (PCNs), polychlorinated terphenyls (PCTs) and/or polybrominated biphenyls (PBBs)

200

M150 Phenols, phenol compounds including chlorophenols - M160 Organohalogen compounds other than substances referred to in this list - M170 Polychlorinated dibenzo-furan (any congener) - M180 Polychlorinated dibenzo-p-dioxin (any congener) - M210 Cyanides (organic) - M220 Isocyanate compounds - M230 Triethylamine catalysts for setting foundry sands - M250 Surface active agents (surfactants) containing principally organic constituents.. - M260 Highly odorous organic chemicals including mercaptans and acrylates - N100 Containers and drums contaminated with the residues of substances referred to in this list 580 N120 Soils contaminated with a controlled waste 12,650 N140 Fire debris and fire washwaters - N150 Fly-ash - N160 Encapsulated, chemically-fixed, solidified or polymerised wastes - N190 Filter cake - N200 Ion-exchange column residues 250 N220 Asbestos 2,000 N230 Ceramic-based fibres with physico-chemical characteristics similar to those of asbestos - Q100 Quarantine derived waste not defined by other controlled waste categories 2,000 R100 Clinical and related wastes 800 R120 Waste pharmaceuticals, drugs and medicines 3 R140 Waste from the production and preparation of pharmaceutical products -

T100 Waste chemical substances arising from research and development or teaching activities including those which are not identified and/or are new and whose effects on human health and/or the environment are not known

4

T120 Waste from the production, formulation and use of photographic chemicals and processing materials 5 T140 Tyres 3,540 T190 Residues from industrial waste treatment/disposal operations 882


* For each waste type (where possible), an annual generation value has been arrived at using historical controlled waste records and other estimation methods. The primary data sources include:

‐ Commercial waste transport businesses (WTBs) quarterly reports for Tasmania between the first quarter of 1998 and the second quarter of 2007.

‐ Controlled Waste Inventory: 2004-2005 DTAE. ‐ Questionnaire feedback and stakeholder meetings, during consultation

process undertaken by SIA in 2007. Inconsistencies and issues relating to controlled waste data measurement and reporting have also been considered. Discussed in Section 4.3.2, these issues include:

‐ controlled waste quantities reported each year by WTBs vary significantly ‐ incomplete records, for example, gaps in WTB quarterly reports for 2000 and

the second half of 2002 ‐ issues relating to double handling ‐ varying units of measurement used i.e. litres, kilograms/tonnes, and cubic

metres. Also, the use of ‘tonnes / cubic metres’ where there is an assumed density ratio of 1:1.

SIA has accommodated for this by using cubic metres (or kilolitres) and applying an estimated bulk density (kg/m3), based on the properties of the waste material. This then gives a tonnage figure (TPA or tonnes per annum). Where there are blank spaces, either there is a lack of reliable data available, or the waste type is not generated in Tasmania. The scope of this report did not include a waste audit, so SIA has used what existing data and sources are available.

draft report current and future controlled waste practices in … · 2011-07-27 · infrastructure...

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