what is wm3 - elqf is wm3? the simple answer wm3 is the current technical guidance for the...

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What is WM3 ? Dr. Ian Bishop One Touch Data Ltd [email protected] Tel: +44 (0)1628 771731 www.hazwasteonline.com June 5, 2016 © 2016 One Touch Data Limited 1 Presentation to the East Land Quality Forum 10 th March 2016

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What is WM3 ?

Dr. Ian Bishop

One Touch Data Ltd

[email protected]

Tel: +44 (0)1628 771731

www.hazwasteonline.com

June 5, 2016

© 2016 One Touch Data Limited

1

Presentation to the East Land Quality

Forum

10th March 2016

What is WM3? The Simple Answer

WM3 is the current technical guidance for the

classification of waste from the four UK Environment

Agencies

In force since June 2015

Changes - from WM2 to WM3 – the headlines

H1 to H15 changed to HP1 to HP15

Hazard Statement Codes (eg H350) replace Risk

Phrases (eg R45)

DSD and DPD repealed (CHIP 4 Regulation)

Except in the case of Ecotoxic assessment (HP14)

where risk phrases (eg R50/R53) are retained

Persistent Organic Pollutants (POPs) added

2June 5, 2016

© 2016 One Touch Data Limited

What isn’t WM3

You must not use defunct guidance such as:

Technical guidance WM2

HWR08 (unknown oils, England, Wales, NI)

DRO C10-C25

SWAN04 (unknown oils – Scotland)

ASL – data from the Approved Supply List

You cannot use WAC data to determine whether your

waste is hazardous or not

If a waste classification is received that used older

guidance, it has to be re-done using WM3

3June 5, 2016

© 2016 One Touch Data Limited

Background and Relevant Legislation

June 5, 2016

© 2015 One Touch Data Limited

Waste Classification

Not just for landfill disposal

Not the same as Waste Acceptance Criteria

Not the same as H&S labelling

Not just for development sites

It is fundamentally different to assessing risks

from contaminated land

The investigation and remediation of land contamination is

risk based

The assessment of contaminated soil as hazardous waste

is hazard based

June 5, 2016

© 2015 One Touch Data Limited

5

Soil - Doesn’t become a waste

Definition of Waste: Development Industry Code of Practice Version 2

CL:AIRE, March 2011 (England & Wales only)

Look at re-use of excavated materials first

Materials Management Plan

Must follow CoP

Only if you have a surplus of material does it become a waste

-> Site Waste Management Plan

Then look at classification

and then WAC if necessary

Processing is evidence that it’s a waste

Recovery operation – material ceases to be a waste

June 5, 2016

© 2016 One Touch Data Limited

6

Legislative Context - 1

Revised Waste Framework Directive 2008/98/EC

Defines the legislative framework for handling of waste in EU

rWFD defines waste as:

‘any substance or object which the holder discards or intends or is

required to discard’

Provides a precise and Europe-wide definition of hazardous

waste as:

‘a waste which displays one or more of the hazardous properties

listed in Annex III’

HP 1 through HP 15

Directive enacted into national law by The Waste

(England and Wales) Regulations 2011 (as amended)

Annex III rWFD replaced by Regulation 1357/2014/EU -18/12/14

June 5, 2016

© 2016 One Touch Data Limited

7

Legislative Context - 2

rWFD in turn refers to Decision 2000/532/EC - the List of

Waste (LoW) Also known as the European Waste Catalogue (EWC)

Contains 842 waste codes for different types of waste

Every waste can be classified as either hazardous or non-hazardous

Submissions based on codes are used to measure tonnages for each

waste stream across Europe

LoW is divided into 20 chapters and sub chapters e.g. Chapter 17: CONSTRUCTION AND DEMOLITION WASTES

17 05 soil, stones and dredging spoil

17 05 03* soil and stones containing hazardous substances

17 05 014 soil and stones other than those mentioned in 17 05

03

LoW most recently amended by Decision 2014/955/EU - 18/12/14

8June 5, 2016

© 2016 One Touch Data Limited

List of Waste

The LoW (Decision 2000/532/EC) was implemented by

the List of Wastes Regulations 2005

However today, amendment Decision 2014/955/EU is referred to

directly - with other national laws being amended by:

The Hazardous Waste (Miscellaneous Amendments)

Regulations 2015, which amended:

The Waste (England and Wales) Regulations 2011

Hazardous Waste (England and Wales) Regulations 2005

Cremation (England and Wales) Regulations 2008

Environmental Permitting (England and Wales) Regulations

2010

Controlled Waste (England and Wales) Regulations 2012

And also revoked the List of Wastes Regulations 2005

June 5, 2016

© 2016 One Touch Data Limited

9

What is link between rWFD and classification?

rWFD (2008/98/EC) states that the classification of

waste as hazardous

‘should be based, inter alia, on the Union legislation on

chemicals, in particular concerning the classification of

preparations as hazardous, including concentration limit

values used for that purpose.’

Main EU chemical legislation being REACH and CLP

Plus subsidiary legislation for pesticides, biocides,

pharmaceuticals and cosmetics

Alongside CLP, chemical legislation (for mixtures) was:

Dangerous Substances Directive (DSD)

Dangerous Preparations Directive (DPD)

brought into UK law under the CHIP 4 Regulation

10June 5, 2016

© 2016 One Touch Data Limited

Chemical substances in the CLP (Annex VI, Table 3.1 or 3.2) or

the older DSD/DPD have standardized phrases describing one or

more hazards of some 4,500 harmonised substances

DSD/DPD approach uses Risk Phrases

e.g. R45 Carc. Cat. 1 (threshold 0.1%)

CLP approach uses Hazard Statements

e.g. H350 Carc. 1A (threshold 0.1%)

But CLP documents both

Risk Phrases (Annex VI, Table 3.2)

Hazard Statements (Annex VI, Table 3.1)

Risk Phrases and Hazard Statements

Exception is for Ecotoxic R50, R51, R52, R53 & R59

11June 5, 2016

© 2016 One Touch Data Limited

Carc. 1A = Hazard Class &

Category

H350 = hazard statement

code

Together = hazard statement

EU Chemical Legislation - CLP

CLP Regulation (EC) No. 1272/2008

Classification, Labelling and Packaging of

substances and mixtures

Came into force 20th January 2009

Adopts UNs’ Globally Harmonised System (GHS) of

classifying and labelling of chemicals

GHS heavily influenced by the older EU chemical

legislation

Transition period for mixtures, classified under

DSD/DPD (ie Risk Phrases) ended 1st June 2015

June 5, 2016

© 2016 One Touch Data Limited

12

CLP Data

Regulation (EC) No 1272/2008 - Classification, labelling and

packaging of substances and mixtures (CLP)

Annex VI, Table 3.1 (& Table 3.2)

Tables contain the hazard statements and risk phrases for

~4500 substances

1st , 2nd, 3rd & …. Adaptations to Technical Progress for

European Regulation 1272/2008/EC (ATPs)

June 5, 2016

© 2015 One Touch Data Limited

13

Hazard Statement codes

Note

Hazard statement codes e.g. “H300 Fatal if swallowed” can have TWO thresholds:

H300 Acute Tox. 1 - 0.1%

H300 Acute Tox. 2 - 0.25%

So you need to record both Hazard Class & Category and hazard statement code to determine the correct calculation approach

14June 5, 2016

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Regulation (EU) No.1357/2014

Replaces Annex III to rWFD 2008/98/EC

Renames H1 to H15 to HP 1 to HP 15

Defines hazard statement codes and thresholds

e.g. Carc. 1A H350 0.1%

Repeals DSD and DPD

Requires an additional study HP 14 ecotoxic

And requires us to carry on with DPD approach for

ecotoxic i.e. the R50-R53 risk phrases

Revises some Hazard Property names:

15June 5, 2016

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Revised Hazard Property Names

Name Status

HP 3 Flammable H3-A (4 indents) and H3-B

replaced by 5 indents

HP 4 Irritant - skin irritation and eye damage Revised to specifically include

eye damage

HP 5 Specific Target Organ Toxicity

(STOT)/Aspiration Toxicity

Amended to align with changes

in chemicals legislation and in

particular new hazard class /

categories in CLPHP 6 Acute Toxicity

HP 12 Produces Toxic Gases in Contact with

water, air or acid

New names to ensure

consistency with the naming of

the other hazard propertiesHP 15 Waste capable of exhibiting a

hazardous property listed above not

directly displayed by the original waste

16June 5, 2016

© 2015 One Touch Data Limited

Decision (EU) No. 2014/955

Updates the List of Waste

Defines a “hazardous substance”

Lists “heavy metal” as any compound of

antimony, arsenic, cadmium, chromium (VI), copper, lead,

mercury, nickel, selenium, tellurium, thallium and tin

Specifically links Persistent Organic Pollutants (POPs)

into waste classification

Concentration limits… do not apply pure metal alloys in

their “massive” form … unless a specific entry in LoW

17June 5, 2016

© 2015 One Touch Data Limited

WM3 & List of Waste

June 5, 2016

© 2015 One Touch Data Limited

WM3

Technical Guidance WM3 1st Edition, published 15th

May 2015.

How should we be classifying wastes in land development projects ?

June 5, 2016

© 2015 One Touch Data Limited

19

First – how is waste coded in the LoW ?

842 six digit code covering all wastes :

Absolute Hazardous (AH) – marked with an

asterisk, automatically hazardous, e.g. 13-07-01*

fuel oil and diesel

Absolute Non-hazardous (AN) – not marked with

an asterisk e.g. 03-01-01 waste bark and cork;

Mirror entries – typically a “pair” of codes, one

Hazardous (MH), one Non-hazardous (MN);

17 05 03* or 17 05 04 Soil and stones…

the selection of which depends on whether one or

more substances contain ‘hazardous substances’ at or

above a given threshold.

June 5, 2016

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LoW

June 5, 2016

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1. Look in chapters 1-12

(industry process) or 17-

20 (business activity)

2. No luck – look in 13-15

3. No luck – look in 16

4. No luck - 99 codes may

be considered

Exercise - Multiple Choice

Waste: A radiation apron dumped in a skip of builder’s waste

Questions to ask:

Where did it (the waste) come from..?

What is it made of?

Fabric

Leather

Lead

Is it :

A. 20 Municipal wastes (household waste and similar commercial, industrial and

institutional wastes

20 01 separately collected fractions

20 01 10 clothes

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Radiation Apron

Is it?

B. 18 Wastes from human or ….. health care

18 01 wastes from …diagnosis, treatment of disease in humans

Is it?

C. 15 Waste packaging, wiping cloths.. and protective clothing not otherwise

specified

23June 5, 2016

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Different examples

June 5, 2016

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Two examples of Chapter 16: Wastes not otherwise specified in the list:

• liquor from composting

• portable toilet waste

Waste Soils

June 5, 2016

© 2015 One Touch Data Limited

Waste: Soil 17 05 04 or 17 05 03*

We have a waste soil.

So we need to decide:

What to sample

We will discuss:

What to ask the lab to test for (and why those tests)

Which metals

Which other substances

TPH

POPs

26June 5, 2016

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Which LoW code?

Estranged husband dumps bricks and rubble on wife's car

A man has been arrested after allegedly using a JCB digger to tip

bricks and mud over his estranged wife's car.

27

LoW code(s) ?

20 02 02 soil and stones

20 03 03 street cleaning

residues

20 03 01 mixed municipal

waste

16 -1 04 * end of life

vehicles

17 05 04 or 03* soils

17 09 04 or 03* C&D

June 5, 2016

© 2016 One Touch Data Limited

Soils Scenario 1 – the SI Report…

SI performed in winter 2014

20 test pits

Original consultant used HazWasteOnline

to ascertain that of 20 test pits:

19 were non hazardous and 1 was

hazardous …..

Summer 2015, developer excavating soils

Muck haulier submits the SI Report for

disposal of 2000 cube of waste soil

Q1 - Is stock pile 17 05 04 or 17 05 03* ?

28June 5, 2016

© 2016 One Touch Data Limited

Soils Scenario 1 – Further Problems

Contractor needs the space where the 2000 cube

stock pile is sitting – in 2 days time

And - Contractor is only now thinking about disposal

And - Financial penalties could be incurred for delays

Issues

Contractor has excavated the soils without

consideration for any hazardous areas

Contractor has mixed non hazardous soils with

hazardous soils

Contractor now has 2000 cube of hazardous soil?

Discuss….

29June 5, 2016

© 2016 One Touch Data Limited

A better approach

Soils excavated from hazardous area should be

kept separate from non hazardous soils

Mixing should be minimised

More sampling may be needed to better define

actual extents of hazardous area

Sampling and testing should be factored into the

management plan(s) from the start so not an

afterthought

30June 5, 2016

© 2016 One Touch Data Limited

Sampling ?

There is no off-the-shelf sampling plan for soil

Both the stratigraphy and contamination on every

site are different

Different Sampling Plans are needed for

Site investigation/characterisation

Human health risk assessment

Waste Classification

Waste Acceptance Criteria

And

WAC is only required if the soils are going to (certain

classes of) landfill

31June 5, 2016

© 2016 One Touch Data Limited

Lab testing of our soil samples

We’ve decided what and where to sample

But what do we actually test for?

Phase I should have discovered the sites’ history

Industries and their processes - over time

Chemicals used by those industries

Raw materials, products, treatments, spills

And potentially spilt/leaked/buried

Phase II should have identified

Different types of contamination (populations)

Spatial extent and degree of contamination

Need for any extra investigation

32June 5, 2016

© 2016 One Touch Data Limited

Lab testing

You shouldn’t be asking for (just) the HazWasteOnline

suite of lab tests (or any other standard suite) …

You may have a minimum suite comprising

metals (but which ones?)

PAHs (16 USA EPA PAH suite)

TPH CWG or EPH ….

also

BTEX, pH, POPs …..

Selection should be steered by findings of Phase I

and II

Plus observations made since

33June 5, 2016

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Metals - Not straight forward…

1. When lab tests soils for metals: cadmium, zinc, copper

etc

i. Lab reports total concentration of the metal

ii. However, it cannot tell you which compound of

cadmium, zinc or copper etc. you are dealing with

iii. Lab does not report the total amount of a metal

compound

2. However, in classification (in most cases) you have to

identify either

i. worst case metal compound, or

ii. most likely case metal compound

3. Then you have to convert total metal concentration - to

the chosen total metal compound concentration…

34June 5, 2016

© 2016 One Touch Data Limited

For Example

Your laboratory tells you that the concentration of total

copper in your waste sample is 2750 mg/kg, which you

suspect to be in the form of copper (I) oxide Cu2O.

What is the actual concentration of copper (I) oxide?

The atomic weight of copper is ~ 63.5

The atomic weight of oxygen is ~ 15.9

The molecular weight of copper (I) oxide is 143

The concentration of copper (I) oxide is:

(143 /(2x63.5)) x 2750 mg/kg = 3096 mg/kg

[& conversion factor is simply 143/127 = 1.126]

June 5, 2016

© 2016 One Touch Data Limited

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Is the waste (soil) hazardous?

Does the waste possess any of the

hazardous properties HP 1 to HP 15 - or

POPs? Yes = hazardous 17 05 03 *; No = non hazardous 17 05 04

Hazardous because either;

Where hazardous substances are present,

identified hazard statement codes are

compared against thresholds; and/or

Testing indicates the waste possesses a

hazardous property (e.g. flashpoint for

flammability HP 3).

June 5, 2016

© 2016 One Touch Data Limited

36

What you can’t do

Is use rules of thumb - such as:

“If all the metals add up to less than 2500mg/kg, the

waste is not hazardous……”

Which metals?

Which metal compounds?

Trial HazWasteOnline and get it to work out thresholds

for different metals…

37June 5, 2016

© 2016 One Touch Data Limited

Nickel sulphate is

commonly used in

electroplating

Why rules of thumb don’t assess waste

You have to assess all the hazardous substances as:

Many hazard properties are additive

Case where concentrations of substances have to

be added together

Irritant HP 4, STOT HP 5, Toxic HP 6, Corrosive HP 8

Or test based on “fiddly” equations

Ecotoxic HP 14

Also they don’t allow for a (helpful) correction for things

like:

Moisture content

“Cobble” correction

38

Σ((M × 10 × H410) + H411) ≥ 25 %

June 5, 2016

© 2016 One Touch Data Limited

Why can’t we use “experience”?

What are the risks?

No defensible record to document how a classification

was reached

No metal conversions and/or unsuitable metal species

Substance specific thresholds / M factors not applied

No correction for amendments to rules or thresholds

when ATPs published

No identification of Hazard Properties

No audit trial

So no ability to check

39June 5, 2016

© 2016 One Touch Data Limited

Whereas

A report should document

everything that a third

party would need to check

a classification

Who did work & when

Lab data & meta data

Conversions

Additive/cumulative

Rules/equations used

Moisture

Note 1

Legislation

Software version

…..40June 5, 2016

© 2016 One Touch Data Limited

Another reason…

The Environment Agency is running a campaign to

crackdown on dubious 17 05 04 classifications

For last few months EA have been sending out

letters to different parts of the waste chain asking for

evidence that a waste is 17 05 04

41June 5, 2016

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Waste Receiver letter

42June 5, 2016

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Waste Producer letter

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Other wrinkles in the law/guidance

Some substances;

Have substance specific thresholds

Benzo[a]anthracine 25 mg/kg

Are Note 1

Case where you can use just the metal concentration

e.g. lead compounds (see next slide)

Are Note H

Effectively means they have missing hazard

properties e.g. HP 14 ecotoxic

All the oils in the CLP are Note H

44June 5, 2016

© 2016 One Touch Data Limited

Worse still?

Some hazard statements in Table 3.1 are only considered a minimum classification

As shown by * or ****

And, in contrast to DSD approach,

all entries in CLP are considered potentially incomplete

i.e. not only those that we still label Note H

Good example is CLP entry: “lead compounds with the exception of those specified elsewhere in the Annex”

Doesn’t have an entry for HP 7 carcinogenic

But many sources including IARC consider it carcinogenic

So CLP requires classifier to add the missing hazard property(s)

45

Waste Acceptance Criteria

June 5, 2016

© 2015 One Touch Data Limited

WAC

Waste classification tells you whether a waste is

hazardous or non hazardous

It does not tell you whether the waste is “inert”

You cannot use WAC tests to classify your soil and

determine whether it is hazardous or not

WAC is only required for disposal (of wastes) at certain

classes of landfill

How many times have I heard

“It’s failed Inert WAC therefore it’s hazardous”

47June 5, 2016

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“It’s failed Inert WAC therefore it’s hazardous”

What this often relates to (from the “classifier’s” point of

view) is that the soil has failed WAC because:

Total organic content or

Dissolved organic carbon

has exceeded the WAC criteria for the Inert Class of

landfill

However

Neither are hazardous substances, and

Neither make a waste hazardous

And

“Classifier” hasn’t and doesn’t understand the law

48June 5, 2016

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Conflict between terminology & laws

Landfill Directive - 1999/31/EC

Article 2e

Defines “inert waste” as:

Waste that does not undergo any significant physical,

chemical or biological transformations.

Inert waste will not dissolve, burn or otherwise physically or

chemically react, biodegrade or adversely affect other matter

with which it comes into contact in a way likely to give rise to

environmental pollution or harm to human health.

The total leachability and pollutant content of the waste and

the ecotoxicity of the leachate must be insignificant and in

particular not endanger the quality of surface water and/or

groundwater.”

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Inert Waste

It should be noted that

inert waste is by definition non-reactive and

therefore not harmful (non-hazardous) to the

environment, whereas non-hazardous waste

includes non-inert, reactive waste like organic matter

present in household waste (kitchen waste, garden

waste…).

Then we have the landfill tax as originally defined by

the Finance Act 1996

50June 5, 2016

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The Finance Act

Part III Finance Act 1996 (Landfill Tax: sections 39 to 71)

Section 42 – Amount of tax

Refers to reduced rate for qualifying materials

material listed is “of the kind commonly described as

inactive and inert”

Section 63 introduces “qualifying materials”

And the concept of “small quantity of non-qualifying

material”

Exemptions

Section 43 Material removed from water

Section 44 Mining and quarrying

Section 45 Pet cemeteries

June 5, 2016

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Landfill Tax

Landfill tax

Standard Rate: £82.60/tonne

Increasing to £84.40/tonne

Lower Rate : £2.60/tonne

Increasing to £2.65/tonne

52June 5, 2016

© 2014 One Touch Data Limited

Today

Excise Notice LFT1 updated 16th December 2015

Lower Rate: qualifying material

Waste must be:

Listed in Landfill Tax (Qualifying Material) Order 2011

And

Non Hazardous within meaning of rWFD

LFT1 defines qualifying materials in groups including

Group 1 includes:

Rocks and soil - Naturally occurring

Group 2 includes:

Concrete, including brick, concrete blocks

53June 5, 2016

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Why WAC is not suitable for waste

classification

Primarily, because of the metals:

1. Metals in a WAC test are a test of the eluate

They are only a test for 12 soluble metals

Not a test for the insoluble fraction of same 12

metals

2. Mineral oil may only be testing the aliphatic component

3. WAC is a fixed list of chemical tests

No tests for any other potential hazardous

substances

Other metals

Other organics

54June 5, 2016

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However, WAC can be helpful

WAC can provide clues for which metal compounds

present

Example

Cyclone ash from incineration of municipal waste

For zinc, research had shortlisted

zinc oxide (insoluble)

Zinc chloride (soluble)

Which species to use?

Lab results:

zinc (WAC): < 0.5 mg/kg

zinc (solids): 2,630 mg/kg

55June 5, 2016

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Waste Classification data v WAC data

They are not the same and cannot be mixed

Classification has to be done first

Waste Producers must obtain characterisation data that, amongst other

uses, will determine the destiny of each of their waste streams.

First, there may be a need to determine whether the waste is

hazardous or non-hazardous (Classification).

Then, if it is to be landfilled, the class of landfill at which it can be

accepted must be identified.

Then, you look at whether the waste has to comply with the WAC for

that class of landfill

June 5, 2016

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Waste Acceptance Criteria

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WAC not applicableIs the waste defined as hazardous ?

May be accepted at

inert landfill

Hazardous WAC apply

Can be accepted at hazardous

landfill

Can not be accepted at hazardous landfill.

Other options required, such as treatment.

May be accepted at

non-hazardous landfill

Fail Inert WAC Meet Inert WAC

Yes No

Yes No

Met Failed

Is the waste to be disposed of to landfill ?

Stable Non-Reactive Hazardous Wastes

You can dispose of Stable, Non-Reactive Hazardous

Wastes (SNRHW) in non-hazardous landfills

Managed in dedicated cells

This is waste that is incapable of reacting with other

wastes

SNRHW potentially include

Monolithic solidified wastes in large blocky forms

e.g. those mixed with cement or PFA

Granular solid wastes

e.g. filter cakes, treated fly ash

Asbestos

SNRHW specific Waste Acceptance Criteria apply

58June 5, 2016

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WAC Responsibilities

There is no obligation on any landfill operator to

take waste if they choose not to

Their Environmental Permit entitles them to take

waste of particular descriptions but does not

compel them to do so

Waste operators may require additional testing of

waste soils prior to acceptance at landfill

The obligation to ensure compliance with Waste

Acceptance Criteria (WAC) is placed on the

operator of the landfill.

June 5, 2016

© 2015 One Touch Data Limited

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Unknown Oils

June 5, 2016

© 2015 One Touch Data Limited

Waste oils and oil contaminated waste

WM3, Chapter 3.4 focuses on mineral and hydrocarbon

oils

1) Waste mineral oils (predominately oils, liquid fuels &

lubricants, synthetic oils & waste separator oil)

= Absolute entries

even if no hazardous properties

Exceptions = edible oil and sometimes biodiesel

Use safety data sheet, failing that petroleum group

2) Wastes contaminated with oil

i.e. oil phase is not major component

1. Known oil

2. Known group of oils

3. Unknown oil

61June 5, 2016

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Scenario 1 – Known oil

Example – spill from a domestic oil tank in a garden

Brand of oil is known

Safety Data Sheet (SDS) can be obtained from supplier

Use hazard statement s on SDS

Cannot apply any markers

62June 5, 2016

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Scenario 2 – Known Petroleum Group

If can identify petroleum group, e.g. diesel tank on a farm - but

specific brand is unknown

Can use petroleum group

Cannot assume that if DRO range (C10-C25) is present that it

is a diesel

Would need lab to report that results are consistent with fresh,

weathered or a biodegraded diesel

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Scenario 3 - Unknown oil

Case where identity of the oil is unknown

Should consider potential presence of other organic

“contaminants” e.g. coal tar, coal, solvents, peat

Have to ask lab to consider whether oil could be diesel

or gasoline

Otherwise assume following hazard statements:

H304 & H373 (HP 5 STOT/Aspiration Toxicity) ≥25%

H340 (HP 11 Mutagenic) ≥0.1%

H350 (HP 7 Carcinogenic) ≥0.1%

H361d (HP 10 Toxic for Reproduction) ≥5%

H411 (HP 14 Ecotoxic) ≥ 2.5%

Flammability (HP 3)

HazWasteOnline’s “TPH (C6-C40) Petroleum Group” applies

H226 Flammable liquid and vapour

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Unknown oil & the benzo[a]pyrene marker

Unknown oil can be classified as non carcinogenic :

1. where the concentration of TPH is ≥ 0.1%, the

waste will be classified as HP 7 Carcinogenic and

HP 11 Mutagenic, unless the concentration of the

marker, benzo[a]pyrene is <0.01% w/w of the

concentration of the TPH, and

2. laboratory analysis has concluded, through

examination of the chromatograph and carbon

bands, that the hydrocarbons present have not

arisen from petrol or diesel, and

3. this has been determined by an appropriate and

representative sampling approach in accordance

with the principles set out in WM3, Appendix D.

June 5, 2016

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What’s Coming

June 5, 2016

© 2015 One Touch Data Limited

What is Coming ?

Legislation

EC Regulation for HP 14

Replacement of R50-R53 risk phrases and substance specific

thresholds

Through use of H400, H411, H412, H413 and M factors

EC Guidance document

28 member states would have to agree….

8th ATP

Main objective: Alignment with 5th revision of GHS

New test method for oxidising solids

Amended criteria for skin corrosion/irritation, severe eye damage/irritation, and

aerosols

June 5, 2016

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What is Coming ?

HazWasteOnline™

Electronic Data Delivery (EDD)

Lab data are emailed to HWOL servers for validation

and publication

Quicker

Better QA/QC

Deals with units, moisture and other sources of error

Will include an interface for WAC data

German classification engine

Smartphone App for waste receivers

68June 5, 2016

© 2015 One Touch Data Limited

Dr. Ian Bishop

One Touch Data Ltd

[email protected]

Tel: +44 (0)1628 771731

www.hazwasteonline.com

June 5, 2016

© 2016 One Touch Data Limited

69

Presentation to the

East Land Quality

Forum

10th March 2016