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Waste Code of Practice - Practicalities

East Land Quality Forum29th June 2011

Dr Mike Higgins

Key Drivers

“When we have reached a point where what we now call waste is called a resource, we will have achieved an economy that uses its resources wisely.”

Hilary Benn, Environment Secretary, 1 February 2010

This IS Waste This IS NOT Waste

Key Drivers

Waste Management

Risk Assessment

Industry Capabilities

Remediation Technologies

Resource Efficient Remediation

Key Drivers

How the Code of Practice Enables

Resource Efficient Remediation……

Criteria which need to be met.

• Suitable for Use; - does it meet environmental and geotechnical standards

• Certainty of Use – is it needed without question;

• a Defined Quantity is used – only that which is necessary.

How the Code of Practice Enables

Resource Efficient Remediation……

Criteria which need to be met.

• Suitable for Use; - does it meet environmental and geotechnical standards increase in testing and characterisation

• Certainty of Use – is it needed without question key link to timing in terms of planning, more permissions for remediation & earthworks;

• a Defined Quantity is used – only that which is necessary requires careful site management and materials tracting.

Code of Practice: Key Features

Lines of evidence are needed and include;

• Remediation Strategy;

• Materials Management Plan;

• Materials Tracking System;

• Underpinned by Declaration(s) by “Qualified Person’;

• Verification Report;

• Alongside Existing Permitting regimes.

What does MMP really mean ?

• Manage Materials Positively

• Make More Profit

• Make My Problem …..Go Away

Material Management Plans

• An enhancement of a Remediation Method Statement (RMS) through greater identification and understanding of the materials on site

• Identifies where materials can be suitably used on site (or off site) for various purposes

• Integrates the Remedial Method Statement with Value Engineering exercise (e.g., optimum level raising, overdigging service runs – 6F2)

• Integrates the Remedial Method Statement with Ground Engineering exercise (e.g., chemically and geotechnically suitable, treatment for environmental andcivils uses)

• Enables through development of MMP, positive selection of which soils can be re-used, and which cannot. Which get disposed of from site

• Identifies mechanisms for exporting soils from site to site through means including Direct Transfer and Environmental Permitting (Hub / Cluster)

Where the CoP fits in ?

What the CoP Sits Alongside….

Reuse on Site

• Definition of the Site

• Materials Management Examples

• Residential Development of Industrial Land

• Proposed Nuclear facility

Definition – Site of Origin

A1.1 The site of Origin for the purpose of this CoP is single readily identifiable site. This can include:

• The area covered by a specified planning permission;

• The area covered by single detailed Remediation Strategy;

• The area covered by a single detailed Design Statement, e.g. pipeline route, proposed road; and

• The area covered by an agreed Deployment Form in relation to the use of an Environmental Permit which encompasses the development activity where materials are to be used.

Reuse on Site – Case Study 1

Reuse on Site – Case Study 2

Site to Site Transfer

• Direct Transfer

• Hub & Cluster

Revised Focus for Site Assessment

Characterise fully for export

Market Assessment

Volumes for importSite Permit or CoP

Market Assessment

Characterise fully for export

Hub & Cluster Opportunities

Greenfield

Brownfield

Surplus Deficit

Market for Transfer of Materials

0

2,000,000

4,000,000

6,000,000

8,000,000

10,000,000

12,000,000

Naturally Occurring Recycled Materials Contaminated Soils

Supply

Demand

Market for Transfer of Materials

0

500,000

1,000,000

1,500,000

2,000,000

2,500,000

Naturally Occurring Recycled Materials Contaminated Soils

Supply

Demand

Direct Transfer - Brownfield

• Clearly defined areas of naturally occurring soils

• SI – Delineation

• Visual and olfactory inspection

• Dispatch as non-waste

• Confirmatory testing

Direct Transfer - Greenfield

• Natural occurring materials

- No need for treatment

• Desk Top Study

• Visual and olfactory confirmation upon excavation

• Consider SI – confidence in Desk Top Study

• Risk Assessment – likely to be Qualitative

• Dispatch as non-waste

- Delivery tickets

• Confirm material is as expected

Hub & Cluster – Case Study

Key Drivers

For developers with contaminated materials

• Increased Cost of Landfill Disposal;

• Market Need for Sustainable Materials Reuse;

• Insufficient Time to establish Site Specific Arrangements

For landowners with suitable sites for hubs

• Decreased Land Values – need to seek other Income Streams

• Increased costs of remediation - potential for contribution to site remediation costs

© CL:AIRE 2011 32

Exemptions (LFTE)

for Contaminated Soils

Cost Driver…..Landfill Tax Increasing

© CL:AIRE 2011 33

Market Driver…..Small Sites = No Space

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Market Driver…..Big Sites = Surplus

© CL:AIRE 2011 35

Two Site Hub & Cluster Model

? Site Characteristics

? Timing

Legal Agreements

Logistical Approach

Site1Donor

Hub &Receiver

Decontamination Equipment

Off site residues

© CL:AIRE 2011 36

Traditional Hub & Cluster Model for the Sustainable Management of Contaminated Soils

? Site Characteristics

? Regulatory Framework

? Legal Agreements

? Business Model

? Logistical Approach

Site1

Site 2

Site 3

Site 4

Hub site

Decontamination Equipment

Off site residues

Site 5

© CL:AIRE 2011 37

Soil Treatment Centre

Treatment Centre (Hub) &

Receiver SiteSite1

Site 2

Site 3

Site 4

Site 5

Material

Type A

Material

Type B

Material

Use 1

Material

Use 2

Material

Use 2

© CL:AIRE 2011 38

Development Site or

Regeneration Project

Relevant Planning Permission Remediation Requirement Suitable Materials Reuse Criteria Suitable Environmental Setting Significant Materials Requirement

Soil Treatment Centre

Environmental Permit

Site1

Site 2

Site 3

Site 4

Site 5

© CL:AIRE 2011 39

Site Characteristics

• Former Landfill being redeveloped for Housing

• Remedial Actions required for Site Redevelopment

– deployment of Mobile Treatment Licence

– treatment of hydrocarbons;

– other screening and stabilisation requirements.

• Huge Need for “Imported Fill” circa 1,500,000m3

– flood alleviation measures

– land raising and geotechnical treatment

• Proactive Development Team;

• Supportive Regulatory Teams

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Making it Work

• Agree the Business Model

• Formalise the Legal Agreements

• Agree Remediation Strategy and Reuse Criteria

• Obtain Environmental Permit and address Planning Issues

• Write Materials Management Plan and gain QP Sign-Off

• Open for Business

Legal Agreements

Permitting

Business Model

© CL:AIRE 2011 41

Obtaining an Environmental Permit

• Initial Discussions with the Agency regarding site

characteristics, permitting regime, operators plans & objectives

• Preparation of Deployment Form, outlining Materials Management

Issues;

• Donor Site Pre-Characterisation;

• Materials Tracking System;

• Treatment Potential

• Site Specific Agreements with the Environment Agency

• Address any Planning Issues at local and County level

© CL:AIRE 2011 42

Obtaining Environmental Permit

© CL:AIRE 2011 43

Environmental Permit Conditions

• Operational Controls;

• Access & Security;

• Materials Import and Management;

• Contaminant Migration/ Emissions Control;

• Noise, Nuisance, Dust;

• Emergency Procedures

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Environmental Permit Conditions

© CL:AIRE 2011 45

Materials Management Plan

• Demonstrably Treatable – Demonstrably Suitable for Use;

• Ongoing Fill Requirements – Demonstrably Certain to be Used

(Planning);

• Not Treatable or Suspect – Not Imported;

• Materials Rejection Procedures

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Materials Management Plan

• In total 22 separate documents constitute the MMP and will

grow and the project progresses;

• ‘Hub & Cluster’ participants expand & contract to achieve the fill

requirements (planning levels required for development);

• Off-site Remediation or Construction Project (Donor Sites);

• Robust Donor Site Assessment and Acceptance Protocols (Defined and

Agreed in Deployment);

• Pre-Booked and Known Materials;

• Robust and fully auditable Materials Tracking System (MTS) from Donor Site,

Transport, Treatment and Fill Verification

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Materials Tracking System

• Each material accepted for import given a Unique Identification Code (UIC)

• UIC follows material from;

• Initial Assessment;

• Transport (recorded on Waste Transfer Note);

• Weighbridge and Tipping Inspection Procedures;

• Treatment and Validation Procedures;

• Fill Verification (including location).

• MTS/UIC is able to identify each Donor material at any stage of the MMP process

• Fully auditable with the information shared with the Environment Agency

© CL:AIRE 2011 48

Materials Tracking System

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Initial Treatment Solutions

• Physical Screening;

• Bioremediation;

• Stabilisation / Solidification;

• Chemical Oxidation.

© CL:AIRE 2011 51

In Operation….

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Email: [email protected]

Website: www.rem20.co.uk

Telephone: 01604 842888

Thank you