defra mrf code of practice - mrf regulationsmrfregulations.com/pdfs/stuart hh presentation.pdf ·...
TRANSCRIPT
DEFRA MRF Code of Practice
Operator perspectiveStuart Hayward-Higham
What is the aim of the CoP?
• A mandatory legislative scheme for the industry
• To meet the required provisions in the Waste FrameworkDirective (WFD)
• Supports the need to ensure products are fit for reprocessorsin the UK and the export markets
• Encourages good industry practice
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OCTOBER 2014
What SITA is doing
Processing
1. Sampling and testing regimes at facilitiesin the UK generating product for the market
2. Create infrastructure and manpower tocarry out the sampling and testing regime
3. Processes to ensure feedstock materialand product are tested to the prescribedfrequencies and weights
4. Reporting procedures that will complywith the regulators expectation
5. Install signs at sites for feedstock,products and residual for definition
6. Standardised material acceptance processto use across the business
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Collection
1. Material quality training for all drivers
2. Liaise closely with customers to ensureDry Mixed Recyclate is fit for purpose
3. Create reports and procedures to inform
Local Authorities how they are performing
4. Processes and procedures for collectiondrivers and loaders to follow to ensure DryMixed Recycling is fit for collection
5. Visual prompts for drivers, loaders and
general public to encourage correct materialis in the appropriate container
SITA considerations
> Current SITA Policy and Procedures are outlined , tested and theresults of the 2013 trial year are being learned.
> We will test more facilities than are ‘in scope’ to reflect our policy ofproducing quality products.
> Staff training, especially in obtaining a representative sample isessential. This will be the most difficult but most importantcomponent.
> Most likely opportunity to skew any results is ‘selective’ sampling,regulator inspections and mass balance checking is essential to ensurelevel playing field and consistent results between facilities.
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Customers impacts on CoP
• Quality comes from what is put in the bin.Contamination and/or out of scope Recyclate (materials that cannot be extracted at the MRFbecause they are outside the design specification)
• Contamination is the sum of the collection round, notjust a single bin inspection. Understanding crosscontamination and individual party contribution tototal contamination will become more important.
• Matching feedstock to facility and amending both in acoordinated manner
• Site visits will help show the net results
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What is affected and how• “In scope” MRF Operators that process over 1000 tonnes of Mixed
Dry Recyclate annually
They will be audited by the EA against these new permitrequirements
• Local Government Authorities that collect commingled Mixed DryRecyclate that is processed by a MRF operator
Material they supply to these MRF’s will be tested and reportedto the regulator for public record
• Reprocessors that receive products created from MRF operator
They will have the confidence that products created from theseMRF’s will have been tested to recognised reprocessor and
industry specifications the results of which will be publishedby the EA
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SITA facilities likely to be “in scope”
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South&East
Mitcham(MRF
Barking(MRF
Central
Kirklees(MRF
Darwen(MRF
Landor(Street(MRF
Brackmills(Lane(MRF
(
North
West(Sleekburn(MRF
Binn(Farm(MRF((SEPA)
(
(
(
South&West
Wareham(MRF
Bodmin(MRF
Avonmouth(MRF
Pool(MRF
SITA sites that need to sample Even though these facilities are probably not “in scope” they produce
material that is sold into the markets that need to be sampled toensure SITA specifications are being met
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South&East
Brighton)Security)Shred
East)London)SecurityShred
Eastbourne
Si5ngbourne
Leatherhead
Hounslow
Morden
Slyfield
Charlton)Lane)MRF
South&West
Yate
St)Erth
Fareham
Launceston
Greendale)MRF
East)Devon)MRF
Central
Denaby
Wolverhampton
Birmingham
Blackpool
Bootham
Coventry
Granville
Halifax
Kendal)Fell
Land)Rover
Leicester
North)Lincs
Salt)Ayre
Warwick
Wrexham
New)CrosbyLandor)st)SRF
Belfast)MRFMalpass)SRF
North
Scla5e)MRF
Inverness
Campground
Alnwick
Berwick
Hexham
North)Tyneside)TS
Byker
CoP sampling and composition Material quality and composition testing measuring
Feedstock composition testing Product quality and non-target composition sampling
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Testing requirements
These are the current weights andfrequencies in the draft code, they maychange slightly
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Sampling results
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Bad practice - selective sampling
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Sampling example 1
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Data analysis by weight
- 6.2% films
- 0.2% denseplastic
- 0% - PET, denseand others
Sampling example 2
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Data analysis by weight
- 3.2% films
- 10.9% denseplastic
- 0.5% - PET,
- 0% other plastics
How do you calculate• How do you proportion the output of recycled product between
customers considering• Contamination levels of the incoming streams• The process losses• The impact of different contamination types and their impact on process
losses• Levels of confidence
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How do you calculate ??
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Customer A1000 t
Customer B1000 t
Customer C2000 t
5% 8% 3%ApportionedProcess losses
Tonnes productinto the MRF
Customer A600 t
Customer B400 t
Customer C1800 t
Customer A570 t
Customer B368 t
Customer C1746 t
Tonnes of productproduced
40% 60% 10%Contamination %
14% 9% 44%Apportionedproduct as %total input
25% 25% 50%
Reporting
When Reports will need submitting to the regulator every 3 monthsWhatFeedstock: The total weight of feedstock received at the MRF from each named supplier The total number of samples taken The total weight of all the samples The average percentage composition of glass, metal, paper and plastic The standard deviation of the average percentage composition levels for the target materialsProducts: The total weight of the products produced by the MRF The total number of samples taken The total weight of all samples The average percentage composition levels of all the samples by reference to the grades of glass, metal,
paper and plastic identified within those samples The average percentage composition levels of target, non-target and non-recyclable materials The standard deviation of the average percentage composition levels for the target materials
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Regulator inspections
• Serious what happens if…..
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Stage one Stage two Stage three
Review of results
• 3244 samples taken in 2013
• 97.7% pass rate for effective tests in 2013
• All facilities that carried out sampling reported a 100% quality record exceptAvonmouth that was in commissioning
• None of the facilities managed to complete all the required tests expected
• Some facilities over sampled certain materials and under sampled others sothey did plenty of sampling but failed to follow the guidelines set out in thesampling workbook
• Across all the depots a total of 947 tests were in excess of the minimumrequired
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Health and safety
> For sample collection we are putting people as risk, we must haveappropriate controls and safe procedures
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Thank you
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Stuart Hayward-HighamTechnical Development DirectorSITA [email protected]+44 (0) 7970 233747