SUMMARY. EUROPEAN COMMUNITY European Regional Development Fund

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1 SUMMARY AN ROINN COMHSHAOIL AGUS RIALTAIS ÁITIÚIL DEPARTMENT OF THE ENVIRONMENT AND LOCAL GOVERNMENT EUROPEAN COMMUNITY European Regional Development Fund

2 Introduction The Environmental Protection Agency (EPA) has prepared a National Hazardous Waste Management Plan in accordance with Section 26 of the Waste Management Act, The Plan is a statutory document which should be read and understood by all organisations involved in the generation, management or regulation of hazardous waste. The principal topics dealt with in the Plan are: the estimation of hazardous waste quantities generated; the prevention of hazardous waste and the setting of targets towards this goal; the collection of hazardous waste; the recovery and disposal of hazardous waste that cannot be prevented; and the management of historical hazardous waste disposal sites. This summary provides an overview of these issues. The Plan itself should be consulted in the event of queries on this summary document. The National Hazardous Waste Management Plan is a statutory document. All commercial generators, managers and regulators of hazardous waste are required to manage their hazardous waste in line with existing legislation and the recommendations made in the Plan. The EPA will review the Plan at least every five years. accrued. Hazardous waste prevention forms the cornerstone of the Plan. A significant gap remains in the collection of smallscale and unreported hazardous waste arisings, most notably from the small industrial, agricultural and commercial sectors. This gap needs to be filled by (a) making all generators aware of their obligations in respect of hazardous waste and (b) ensuring that collection services exist which may be availed of by all generators, large and small. While significant recovery and disposal capacity exists in Ireland for a large number of hazardous waste streams, large quantities of hazardous waste continue to be exported for disposal by thermal treatment or landfill. In order to comply with the principles of proximity and self-sufficiency in waste management, it will be important to ensure that facilities exist for the processing, treatment, recovery and disposal of all hazardous waste. The major bottleneck in this regard is hazardous waste disposal; there is a clear lack of hazardous waste disposal capacity in the form of thermal treatment and landfill facilities. A number of sites previously used for the disposal of hazardous waste have the potential to cause ongoing environmental pollution. Such sites will require identification and investigation to determine the extent of contamination, if any, caused by the historical disposal of hazardous waste. The Challenge Significant and increasing quantities of hazardous waste are being generated. Increased reliance is being placed on disposal activities at the expense of recovery activities. These are unsatisfactory trends which need to be reversed by endeavouring to (a) reduce gross hazardous waste generation, (b) reduce the level of hazard displayed by hazardous waste and (c) develop recovery activities instead of disposal activities. With notable exceptions such as in Integrated Pollution Control (IPC) licensing, little or no coordinated effort has been made to prevent or minimise the generation of hazardous waste. Hazardous waste prevention is important if the risk of environmental pollution is to be reduced. Waste prevention has also been demonstrated as being value for money; by preventing hazardous waste at source, management or disposal costs are not Hazardous Waste Statistics and Data Table 1 summarises the quantities of hazardous waste generated in 1996 and Figure 1 illustrates this data graphically. There are two major categories of hazardous waste listed in the Plan: reported and unreported. Reported hazardous waste is that for which there is a verifiable source, such as a questionnaire response or a waste movement form. Unreported waste is that for which there is no defined source of information; estimates are based on import and export data, extrapolations and international experience. All categories of hazardous waste generation, with the exception of unreported hazardous waste, are increasing. The most notable increases are in hazardous waste disposal and in overall exports. Figure 2 illustrates the categories of reported hazardous waste generated in 1996 and An increase of 29% is observed over two years. It 2

3 should be noted that the category pharmaceutical waste in the 1996 dataset is virtually eliminated in the 1998 dataset. By comparison, a large proportion of reported arisings in 1998 was made up of contaminated soil. Contaminated soil accounts for over two-thirds of the increase in reported quantities between 1996 and 1998; contaminated soil arises from the redevelopment of sites in urban areas. Tables 2 to 5 provide a detailed analysis of the categories of hazardous waste generated and the recovery or disposal methods to which they are subject. Tables 2 and 3 are directly comparable as are Tables 4 and 5. Table 1 Summary of hazardous waste statistics, 1996 to 1998 tonnes tonnes Trend to 1998 Recovered or disposed of on-site 141, ,738 7% decrease Recovered or disposed of off-site 36,434 42,485 17% increase (including landfill (including landfill of 2,964 tonnes) of 3,430 tonnes) Exported 51,727 99,598* 92% increase Other or unspecified category ,196** Total reported hazardous waste 229, ,017 29% increase Total unreported hazardous waste 98,228 74,311 24% decrease Total estimated hazardous waste 327, ,328 13% increase Total disposal 86, ,354 39% increase Total recovery 138, ,583* 10% increase * including 23,691 tonnes of contaminated soil exported for recovery ** including 21,795 tonnes of contaminated soil (More recent data indicate that 144,902 tonnes of waste were exported in 1999 including 35,171 tonnes of contaminated soil exported for recovery and 2,155 tonnes exported for disposal). 300, , , tonnes 150, ,000 50,000 0 Total reported Disposal Recovery Exported Unreported Figure 1 Illustration of hazardous waste quantities 1996 to 1998 (with export data for 1999) 3

4 Pharmaceutical waste 49,483t (21.5%) Filter cake/other sludge 7,243t (3.1%) Waste oil 6,600t (2.9%) Lead acid batteries 5,655t (2.5%) Oily sludge 27,424t (11.9%) Other 24,475t (10.7%) Salt cake 22,222t (9.7%) Contaminated soil 45,486t (15%) Filter cake/other sludge 3,129t (1%) Lead acid batteries Waste oil 15,091t (5%) 5,175t (2%) Oily sludge 16,634t (6%) Other 62,719t (21%) Salt cake 28,121t (9%) Solvents 86,532t (37.7%) 1996: total quantity 229,634 tonnes Solvents 119,662t (41%) 1998: total quantity 296,017 tonnes Figure 2 Hazardous waste types reported for 1996 and Table 2 Destination, recovery and disposal of reported hazardous waste in 1996 (All numbers are in tonnes) D/R Code* Description On-site Off-site Export Total D1 Landfill 20,903 2,964 5,630 29,497 D2 Land treatment 3, ,670 D4 Surface impoundment D5 Engineered landfill D8 Biological pre-treatment D9 Physico-chemical treatment 3, ,580 6,946 D10 Incineration on land 27, ,880 45,964 D13 Blending prior to disposal D14 Packaging prior to disposal D15 Storage prior to disposal Total for disposal 55,464 3,921 27,369 86,754 R0 Re-use in current form 10, ,215 R1 Re-use as fuel ,812 7,017 R2 Solvent recovery 42, ,663 52,615 R3 Organic substance recovery 30, ,557 R4 Metal recovery 0 1,338 7,083 8,421 R5 Inorganic material recovery 1, ,720 R6 Acid/base regeneration R8 Catalyst recovery R9 Used oil re-refining , ,363 R13 Accumulation prior to recovery Total for recovery 85,690 29,228 24, ,969 U Unspecified 2 3, ,594 sub-totals 141,156 36,434 51, ,317 plus unspecified location 317 Total Reported Quantity 229,634 *Disposal and recovery codes are from Commission Decision 94/774/EC concerning the standard consignment note referred to in Council Regulation (EEC) No 259/93 on the supervision and control of shipments of waste within, into and out of the European Community; i.e. the transfrontier shipment form. 4

5 Table 3 Summary of disposal and recovery routes and locations for reported hazardous waste in 1998 (All numbers are in tonnes) D/R Code* Description On-site Off-site Export Unspecified Total D1 Landfill 28,499 3,430 2, ,966 D2 Land treatment 100 7, ,251 D4 Surface impoundment D5 Specially engineered landfill D6 Biological treatment 8,304 1, ,780 D7 Physico chemical treatment 1,505 1, ,144 D8 Incineration 17, , ,631 D9 Permanent storage D10 Release to a water body D11 Blending prior to disposal D12 Repackaging prior to disposal D13 Storage prior to disposal DU Unspecified disposal Total disposal 56,298 13,541 50, ,354 R0 Direct re-use 6, ,287 R1 Solvent recovery 65, , ,035 R2 Recovery of organic substances , ,878 R3 Metal recovery 1 4,085 2, ,589 R4 Recovery of inorganic substances , ,795 R5 Acid and base regeneration R6 Recovery of pollution abatement components R7 Recovery of components from catalysts R8 Oil Recovery , ,878 R9 Use as a fuel 2, , ,782 R10 Landspreading R13 Storage prior to recovery RU Unspecified recovery Total recovery 75,440 28,868 48, ,583 U Unspecified ,208 21,795 23,079 TOTAL 131,738 42,485 99,598 22, ,017 *Disposal and recovery codes are from the Third and Fourth Schedules to the Waste Management Act, 1996, as amended by the European Communities (Amendment of Waste Management Act, 1996) Regulations,

6 Table 4 Hazardous wastes and destinations in 1996 categorised by waste type Total reported quantity - location of recovery or disposal (tonnes) Waste type On-site Off-site Exported Unspec- Sub-total Total Total (Ireland) ified un- quantity reported generated solvents: organic halogenated solvents , , ,690.8 other organic solvents 60, , , ,199.6 unclassified organic solvents other pharmaceutical waste (mixed) 44, , , ,483.0 oily sludges 6, , , , ,924.4 sheep dip , ,000.0 waste oils 0 6, , , ,100.0 saltcake/metallic salts 22, , ,222.0 lead acid batteries 0 1, , , , ,228.0 filter cakes and metal , , ,242.6 bearing sludges washing liquids 3, , ,662.8 household medicine, pesticide , ,469.0 and other waste still bottoms and reaction residues 2, , ,601.0 clinical waste , , ,023.0 metal hydroxide sludges , , ,642.2 and ion exchange resins small batteries , ,398.0 oil filters , ,327.0 paint, ink and varnish sludges ,205.2 household solvents , ,945.0 acid and alkali waste paint, ink and varnish liquid waste photographic waste general office waste lead dross veterinary medicines fluorescent lamps contaminated soil pesticide waste (agricultural) asbestos waste adhesive waste mercury bearing wastes lead bearing tin ashes spent filters zinc oxide PCB waste waxes and fats gold solutions waste catalysts waste explosives boiler dust other (various) 0.1 3, , , , ,268.9 extrapolated for non-ipc , ,828.0 (unknown type) TOTALS 141,156 36,434 51, ,634 98, ,862 6

7 Table 5 Hazardous wastes and destinations in 1998 categorised by waste type Total reported quantity - location of recovery or disposal (tonnes) Hazardous waste type On-site Off-site Exported Unspec- Sub-total Total Total ified un- quantity reported generated Organic halogenated solvents 3, , , ,997 Non halogenated organic solvents 67, , , ,520 Other organic solvents , ,213 Other pharmaceutical waste (mixed) , , ,675 Oily sludges 6,444 9, ,634 2,429 19,063 Spent sheep dip ,000 19,000 Waste oils , ,091 2,255 17,346 Saltcake/salts 28, , ,121 Lead acid batteries 7 3,350 1, ,175 9,038 14,213 Filter cakes and metal containing , , ,129 sludges Washing liquids and mother liquors 19,044 3,860 10, , ,630 Household hazardous waste ,8316,831 Still bottoms and reaction residues 4, , ,795 Clinical waste 0 3 3, , ,659 Metal hydroxide sludges/ion 46 1, , ,887 exchange resins Small batteries ,914 2,932 Oil filters ,327 Paint/ink/varnish sludges Acid/alkali waste 6 5, , ,911 Paint/ink/varnish liquid waste 1, , ,393 Photographic waste ,572 1,609 General office waste Dross from lead metallurgy , , ,352 Veterinary medicine Fluorescent tubes Contaminated soil ,69121,795 45, ,486 Pesticides (agricultural) Asbestos waste 1 0 1, , ,335 Spent filters Adhesive waste Zinc oxide Mercury containing wastes PCB waste Waxes/fats Gold solutions Waste catalysts Paint and ink packaging ,764 7,764 Hazardous thermal treatment residues Other hazardous wastes 43 1,465 1, ,713 19,693 22,406 TOTALS 131,738 42,485 99,598 22, ,017 74, ,328 7

8 Hazardous Waste Prevention The cornerstone of the National Hazardous Waste Management Plan is prevention and the Plan sets out how hazardous waste prevention can benefit industry and minimise hazardous waste costs. Integrated Pollution Control (IPC) licensing has to date resulted in the prevention of significant quantities of hazardous waste and this success needs to be extended to other sectors of society. Experience in Ireland and elsewhere tells us that prevention can pay. The Plan recommends the adoption of an ambitious Prevention Programme which will work towards the following targets which are designed to limit the overall quantities of hazardous waste being generated and more specifically, to reduce the quantities of hazardous waste being disposed of. Prevention Targets 1. A standstill scenario for hazardous waste disposal with 1996 as the base year for that target. 2. The elimination of unreported hazardous waste. The Prevention Programme includes provisions for significant assistance, both financial and technical, in achieving hazardous waste prevention. The Prevention Programme will, if fully implemented and adequately funded, provide real opportunities towards achieving the prevention targets. The Prevention Programme is an integrated one incorporating the key aspects of successful waste prevention. The essential elements of the proposed Prevention Programme are outlined in Table 6. The Plan recommends setting up a Prevention Team which will be tasked with prioritising and coordinating the Prevention Programme. The Plan acknowledges that achieving the prevention targets presents a significant challenge particularly given recent and continuing economic growth and expanding industrial production. A prevention ethos within Irish society and industry is required which would become self-sustaining over time. There is significant scope in the Waste Management Act 1996 for the promotion of prevention and recovery initiatives under the Prevention Programme. The Act allows for a wide range of tools to be used both on a voluntary basis and by regulation. The specific time periods within which these targets are to be achieved shall be agreed with industrial or commercial sectors subject to negotiation with sectoral representatives. Collection of Hazardous Waste Collection rates for many hazardous waste types, particularly those that are currently unreported, Table 6 Elements of a Prevention Programme Sustainable Production (Process Waste) Programme aimed at the manufacturing and transport industries where hazardous waste is generated as a result of a process being carried out Prevention Programme for Product waste aimed at manufacturers of products and generators of product waste such as the agricultural and commercial sectors, industry, households and offices Demonstration: benchmarking, assessment and grant assistance Dissemination of information: demonstration success stories, technical bulletins, newsletter and other publicity Assistance to industry: prevention assessment grants, technical assistance, training grants, investment grants, helpline and sector-specific manuals Education: awareness-raising measures and training courses Public awareness campaigns Producer awareness campaigns Technical assistance, product re-design Technical assistance, training Investment grants Supporting infrastructure prevention team Research and development industrial and academic 8

9 Figure 3 Lead acid batteries. are often poor and do not wholly reflect the level of use of certain products or materials. On the other hand, collection rates for certain sectors, particularly IPC licensed industry, are considered to be close to 100%. The collection industry is characterised by a large number of specialist contractors, brokers and transfer stations whose services are availed of more by larger organisations and less so by small-scale industrial, commercial and agricultural enterprises. The focus for improving collection rates must therefore be on small-scale generators who may be unaware of their generation of hazardous waste or who may, for different reasons, be unable or unwilling to pay for the segregation, separate collection and disposal of that hazardous waste. Improved enforcement of existing legislation by regulatory authorities and the provision of information to generators is essential to ensure that all hazardous waste is properly segregated and separately collected. Small-scale collection services should be made available to all small-scale generators including households, industry, farms and other commercial enterprises. Recovery and Disposal of Hazardous Waste The data for 1996 and 1998 show that increasing quantities of hazardous waste are being generated in Ireland. The data also show an increased reliance on disposal activities between 1996 and 1998 and a reduced reliance on recovery activities. There are a number of hazardous waste treatment facilities in Ireland many of which are involved principally in the recovery of hazardous waste. The Plan states that continued grant assistance and funding is important if we are to ensure the continued operation, innovation, diversification and expansion of hazardous waste treatment facilities. Regulation in the form of waste licences and permits issued under the Waste Management Act 1996 will ensure that facilities operate to a high environmental standard. Significant and increasing quantities of hazardous waste are exported for recovery and disposal. The main recovery and disposal activities are solvent recovery; metal and inorganic substance recovery; reuse as fuel; and disposal by incineration and landfill (see Tables 2 and 3). The Plan recommends 9

10 that Ireland strives to become self sufficient in the management of hazardous waste. The principal existing bottleneck in relation to this recommendation is the lack of hazardous waste disposal capacity. The Plan recommends that hazardous waste disposal capacity in the form of thermal treatment and landfill be developed. Hazardous Waste Disposal Sites (Historical) It is estimated that up to 487 locations in Ireland may have been used for the disposal of hazardous wastes. The Plan recommends that local authorities, in conjunction with their waste management planning functions, identify sites at which hazardous waste disposal activities took place and prioritise these sites into those requiring short, medium and long term action and/or remediation. Implementation of the Plan It is recommended that an Implementation Committee be established to consist of senior representatives of organisations with a statutory responsibility for the management of waste and commercial sectoral organisations. The Implementation Committee will co-ordinate implementation of the recommendations of the Plan. The functions of the Prevention Team will be overseen by the Implementation Committee. Local authorities have a significant role in implementing the Plan, generally within the scope of local or regional Waste Management Plans. Except where a particular facility is licensed by the EPA, local authorities are responsible for waste regulation within their functional areas. It is envisaged that local authorities will take an increasing role in the promotion of hazardous waste prevention. The EPA is required to carry out a review of the Plan at least every five years. Other functions to be carried out by the EPA include participation on the Implementation Committee, participation on the Prevention Team and provision of information on hazardous waste on an ongoing basis. Resources and funding Investment is required in three principal areas: 1. in hazardous waste prevention and implementation of the Prevention Programme; 2. by the hazardous waste recovery and disposal industry in providing new and/or upgraded or improved services; and 3. by local authorities and the EPA in the enforcement of hazardous waste legislation and in planning for the provision of hazardous waste recovery and disposal facilities to householders and other small scale generators. Priorities A detailed set of recommendations are set out in chapter 9 of the Plan. Listed below are the priorities identified from those recommendations. 1. The establishment of an Implementation Committee by the Department of the Environment and Local Government. This committee would be responsible for guiding the overall implementation of the Plan. Figure 4 Storage box used for household hazardous waste in the Netherlands. The box is provided by the local authority, has childproof locks and is typically collected every six months. 2. The establishment of a Prevention Team to implement the Prevention Programme. This Team will be responsible for the development of the Programme, for the setting of priorities within the Programme itself and for their initiation. 3. The identification and elimination of unreported hazardous waste to prevent its 10

11 Figure 5 A hazardous waste storage unit. uncontrolled disposal and resultant emissions to the environment. 4. The identification, preliminary evaluation and prioritisation of sites at which hazardous waste disposal has taken place and the implementation of remedial works at priority sites. 9. Build on on-going prevention, research and demonstration initiatives - for example, the Cleaner Production Pilot Demonstration Programme. 5. Establishment of an improved collection infrastructure for hazardous household, agricultural and small and medium enterprise (SME) wastes. 6. The allocation of financial and technical assistance for the development of facilities for the recovery and disposal of hazardous waste where existing capacity is unsatisfactory. 7. The development of hazardous waste landfill capacity and thermal treatment for hazardous wastes requiring disposal to achieve self sufficiency and reduce our reliance on export. 8. Improved public awareness of the impacts of hazardous wastes. Figure 6 Drums. 11

12 Waste oils Shannon, Portlaoise, Dublin Oil filters Portlaoise, Dublin Fluorescent lamps Athy Hydrocarbon/oily sludges Portlaoise, Dublin Lead acid and other batteries Kildare Solvents Mullingar, Shannon, Dublin Photochemical waste Shannon, Dublin Healthcare risk waste Cork, Dublin General chemical waste Shannon Contaminated soil Portlaoise Drums and containers Shannon, Dublin Transfer station Shannon, Tullamore, Fermoy, Dublin Hazardous waste recovery and disposal facilities Mullingar Tullamore Kildare Dublin Shannon Fermoy Cork Portlaoise Athy 1. Atlas Oils, Portlaoise 2. Dempsey Drums, Dublin 3. EcoSafe Systems, Dublin 4. Irish Environmental Services (Sorundon), Dublin 5. Irish Lamp Recycling, Athy 6. KMK Metals Recycling, Tullamore 7. MinChem Chemicals, Dublin 8. National Recycling and Environmental Protection, Dublin 9. Pipe and Drain Services, Dublin 10. Returnbatt, Kildare 11. Safety Kleen Ireland, Dublin 12. Safeway Warehousing, Fermoy 13. Shannon Environmental Services, Shannon 14. Silver Lining Industries (Ireland), Dublin 15. Soltec, Mullingar 16 Southern Health Board, Cork 17. Sterile Technologies Ireland, Dublin Feedback The National Hazardous Waste Management Plan will be reviewed by the EPA at least every five years. Any comments, submissions or suggestions which readers may wish to make on the Plan are welcome. These may be returned to the Headquarters of the EPA on the User Comment Form at the back of the main document or on another format to the address below. Comments to: National Hazardous Waste Management Plan Environmental Protection Agency P.O. Box 3000 Johnstown Castle Estate County Wexford Ireland Telephone Fax Website 12

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