Waste Classification 2 Classifying Waste Soil Soil from

Waste Classification

2 Classifying Waste Soil • Soil from greenfield sources (with no evidence of contamination) – Receiving Soil Recovery Facilities generally do not require soil to be tested but do require a letter of suitability from an appropriately qualified or competent person which provides basic characterisation information.

3 Classifying Waste Soil • Details required vary from site to site but generally should state the following information: • • • The waste is greenfield soil and stone A description of the source and nature of the soil and stone The location of the source of the soil and stone (including a map) The material is suitable for use as backfill; The material will not cause environmental pollution at the facility • Producer and/or waste collector responsible for ensure information is correct • EPA Draft Consultation document on Soil Trigger Values refers to the need for a letter of suitability for every 5, 000 tonnes of material Note: Compliance testing may carried out by receiving facility prior to use in backfilling/restoration

4 Classifying Waste Soil Non-Greenfield Sources & Other Waste Types • Requirements dictated by legislation and guidelines but also by acceptance criteria of receiving facilities • Classify as non-hazardous or hazardous in accordance with EPA publication entitled ‘Waste Classification : List of Waste & Determining if Waste is Hazardous or Non. Hazardous’

5 Classifying Waste Soil Non-Greenfield Sources • Waste soil should be further classified as inert, non-hazardous or hazardous in accordance with the Landfill Directive and Council Decision 2003/33/EC (i. e. Waste Acceptance Criteria testing) or using proposed Soil Trigger Values for EPA Licenced facilities (Draft proposal) Note: Not all receiving facilities require classification of soil as non-haz or haz, WAC testing is sufficient for some facilities

6 EPA Waste Classification • Valid since 1 st June 2015 • Based on Commission Decision (2014/955/EEC) [List of Waste] and Commission Regulation (EU) No. 1357/2014 • Replaces the EPA 2002 European Waste Catalogue & Hazardous Waste List, Hazardous Waste Classification Tool and Worksheet

7 EPA Waste Classification • EWC now referred to as List of Waste (Lo. W) codes or entries • Waste can have one of three Lo. W entries: – Non-Haz – non-haz without further assessment – Haz (marked with *) – haz without further assessment – Mirror – either non-haz or haz – further assessment required • Main Lo. W entries for Soil – mirror entry so further assessment required

8 EPA Waste Classification Steps for determining if waste is hazardous or non-hazardous

9 EPA Waste Classification • Determine waste composition – identifying and quantifying all substances that could render the waste hazardous (based on knowledge of site history, events, process, activity, previous SI data) • Assign hazard statement codes and hazardous properties for the substances present based on the concentrations (using CLP Reg, ECHA database or SDSs) Note: Hazardous property testing may be required in some cases

10 EPA Waste Classification • EPA publication provides an Assessment Template to be used for Classification Report. Alternatively use the Haz. Waste. Onlinetm software or other available EPA approved tools

11 • Haz. Waste. Onlinetm is web-based software for classifying hazardous waste. • Based on the current European Legislation and UK Environment Agency Technical Guidance Document WM 3 v 1. 1 (same approach to EPA Waste Classification publication) (Note: v 1. 1 has just been published and update to Haz. Waste. Onlinetm is effective from 5 th July) • Accepted by EPA

12 • Useful tool for waste classification for the normal contaminants. • Waste Composition Data required (WAC data not appropriate. Important that data includes all constituents that could render it hazardous) • Software assigns hazard statements and properties and determines classification. • Report produced which confirms classification

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14 Waste Acceptance Criteria (WAC) • Criteria for disposal of inert, non-haz and haz waste soil to landfill • Criteria based on the Landfill Directive (Council Directive 99/31/EC) and Council Decision 2003/33/EC and landfill specific acceptance criteria for PAH’s. • WAC analysis required by all receiving facilities accepting waste from non-greenfield sites

15 Waste Acceptance Criteria (WAC) • Min. sample density varies - 1 sample per 1000/2000 tonnes. Greater density recommended in some cases to ensure accurate classification. • WAC suites available from laboratories. No. of suites of available that have been tailored to receiving facilities e. g. Murphy Suite, Rilta Suite etc. • Important to select appropriate suite of analysis to ensure receiving facility will accept the soil. • Asbestos screening added to the acceptance criteria of some facilities.

16 Information required by Receiving Facility Key information required by receiving facilities: – Full Description of the process from which the material arises – Non-Haz/Haz waste classification (where required – usually non-hazardous and hazardous facilities) – Compliance test results – WAC in accordance with their acceptance criteria (for a min. of one sample per 1000/2000 tonne)

17 Information required by Receiving Facility Key information required by receiving facilities: – Haulier Collection Permit – Waste Facility COR/Permit/Licence if soil is coming from a transfer station – Waste Transfer Note for each load Note: Any waste timber, plastic, metals and organic material would need to be removed prior to disposal to landfill (or be present in minimal quantities c. <2%)

18 Soil Trigger Values • EPA Published a Consultation document and WSA and Development of Soil Trigger Values for EPA Licenced Soil Recovery Facilities (Dec 2017) • Proposes max. Soil Trigger Levels (STL) for relevant contaminants in soil and stone from non-greenfield sources. Licenses are required to include additional parameters on a case-by-case basis, depending on historical activities and the sensitivity of receiving environment.

19 Soil Trigger Values • Concern that STL would be applicable to existing operations and material already accepted. Licensee would be required to demonstrate compliance with STL. • Closing date for comments was March 2018. No indication as to when document will be finalised and published.

20 Summary Classification of waste soil requires the following: • Clean/inert soil from greenfield site does not generally require testing, letter of suitability sufficient • For non-greenfield waste soil and other potentially hazardous wastes representative samples taken and analysis carried out for all substances that could render the waste hazardous.

21 Summary Classification of waste soil also requires the following: • WAC testing • Comparison of WAC results to appropriate criteria (Council Decision 2003/33/EC and landfill specific criteria for PAHs) to classify the soil as inert, non-hazardous or hazardous • EPA Draft document on Soil Trigger Values will have implications for the WAC for existing and proposed Licenced Soil Recovery Facilities