introductory guidance on the management of the non...

Old Shore Road, Drigg, Holmrook, Cumbria, United Kingdom CA19 1XH

A company owned by UK Nuclear Waste Management Ltd Company Registration No. 05608448

May 2017

Introductory guidance on the management of the non-radiological

properties of waste

(including non-radioactive waste classification and coding)

Introductory guidance

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Name Role

Originator: David Claxton National Nuclear Laboratory Ltd

Checker: Nicole Towler National Programme Implementation Manager

Approver: Damian Seath Lead Service Delivery Manager

Document History

Issue Date Amendments

1 May 2017 First iteration of document


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Contents

1. Introduction ........................................................................................................... 4

1.1 What is the purpose of this document? ................................................................................ 4

1.2 What does this guidance cover? ............................................................................................ 4

1.3 Who is this guidance for? ....................................................................................................... 4

2. Waste definition and regulation ............................................................................. 5

2.1 What is non-radioactive waste? ............................................................................................ 5

2.2 Does the Waste Framework Directive have any relevance to radioactive waste? ............... 5

2.3 Why manage non-radioactive waste responsibly? ............................................................... 6

2.4 Key principles of non-radioactive waste management ......................................................... 7

2.5 Waste management hierarchy for non-radioactive waste .................................................... 8

2.6 Legislative framework for non-radioactive waste ................................................................. 9

2.7 The regulators ...................................................................................................................... 10

2.8 Other regulatory considerations for non-radioactive waste ............................................... 10

2.9 The consequences of non-radioactive waste mismanagement .......................................... 11

3. Managing non-radioactive waste across the waste management lifecycle ............ 13

3.1 Planning and characterisation ............................................................................................. 13

3.2 Generation and pre-treatment ............................................................................................ 17

3.3 Handling, packaging and storage ......................................................................................... 18

3.4 Transfer for treatment and disposal .................................................................................... 20

4. Classification, codes and assessment procedure for non-radioactive waste ........... 22

4.1 Overview .............................................................................................................................. 22

4.2 Step 1 – Is classification required? ....................................................................................... 23

4.3 Step 2 – Identify code(s) ...................................................................................................... 23

4.4 Step 3 – Identify what additional assessment is needed ..................................................... 26

4.5 Step 4 – Determine the chemical composition of the waste ............................................... 28

4.6 Step 5 – Determine if the composition includes hazardous substances or POPs ................ 29

4.7 Step 6 – Assess the Hazardous Properties of the waste ...................................................... 30

4.8 Step 7 – Assign code(s) ........................................................................................................ 31

4.9 Summary of the waste classification and assessment procedure 7 step process for non-

radioactive waste ............................................................................................................................. 32

5. Summary of key points ............................................................................................... 33

6 Additional information on non-radioactive waste ........................................................ 34

6.1 National Waste Programme (NWP) resources ..................................................................... 34

6.2 Regulatory links .................................................................................................................... 34

6.3 Paperwork required for non-radioactive waste transfer ..................................................... 34

6.4 Legislation & legislative guidance on non-radioactive waste............................................... 35

6.5 Guidance documents (advisory, non legislative) .................................................................. 36

6.6 Abbreviations and acronyms ................................................................................................ 36


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1. Introduction 1.1 What is the purpose of this document? This guidance, written for waste producers in the nuclear industry, is designed to raise awareness on how to manage the non-radiological properties of waste consignments being diverted from Low Level Waste disposal; it does this by examining how non-radioactive waste is managed. Management of the radiological properties of radioactive waste is already widely understood across the sector and is not considered in this document. This guidance encourages fuller consideration of the non-radiological component of radioactive waste and the interplay with current legislation for conventional (non-radioactive) waste. The document aims to provide a basic understanding of non-radioactive waste, what it is, and how it should be classified, coded and managed responsibly. Where appropriate, these same principles can be applied to the non-radiological properties of radioactive waste being disposed to appropriately permitted landfill sites or sent for waste treatment. Section 4 introduces the 7-step process used to classify and code non-radioactive waste in accordance with the Waste Framework Directive.

1.2 What does this guidance cover? This guidance covers:

• The two broad categories of non-radioactive waste.

• Explains the link between non-radioactive and radioactive waste.

• Describes the regulatory framework and key regulatory principles governing non-radioactive waste management.

• Describes the waste management hierarchy and its application within waste management.

• Describes good practice in non-radioactive waste management, including the packaging, storage and labelling of non-radioactive waste.

• Explains non-radioactive waste classification and coding.

1.3 Who is this guidance for? The guidance is designed for anyone who is required to make decisions concerning the non- radiological properties of waste; including waste advisors, waste engineers and waste team leaders. It is also relevant to project and building managers as well as others involved in site decommissioning.


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2. Waste definition and regulation

2.1 What is non-radioactive waste?

Drawing on the Waste Framework Directive (WFD) definition of waste, non-radioactive waste can be defined as: “Any substance or object which the holder discards or intends or is required to discard”. The legislative framework, which the WFD forms part of, is described further later in this guidance. In practice, this sub-divides into 2 broad categories of non-radioactive waste: hazardous wastes such as asbestos or synthetic oils; and non-hazardous wastes, such as uncontaminated soil or rubble. Non-radioactive waste is a term used in the nuclear industry to describe waste that can be treated as conventional waste; just as it would be on any other industrial site. Formerly radioactive waste is considered as non-radioactive waste after re-categorisation renders it out of the scope of regulation governing radioactive waste. ‘Non-radiological properties of waste’ is used in this document to describe the conventional waste properties of radioactive consignments generated on a nuclear site. Radioactive and non-radioactive wastes are covered by different classification systems; the classification and coding system under the WFD covering non-radioactive waste will be explained later in this document. 2.2 Does the Waste Framework Dire

Waste not subject to radioactive waste legislation.

Main legislation is covered later

in this guidance (e.g. Waste Framework Directive).

Main focus is on chemical or

physical nature of waste. disposal. Only the oil

Non-radioactive waste

Waste subject to radioactive waste legislation.

Main focus is on radionuclide

component.

Non-radiological properties must also be considered.

Radioactive waste

2.2 Does the Waste Framework Directive have any relevan ce to radioactive waste? It is worth noting that though waste producers are not legally required to code and classify radioactive waste under the WFD (unless the waste is classified as out-of-scope or is from an exempt activity), transport providers and some waste management facilities may still require this information. For example, permitted landfill sites operate under a non-radiological permitting system, which they apply to all waste they receive including Very Low Level Waste (VLLW). They use the information to ensure that they are appropriately handling and disposing of the hazardous or polluting components of the VLLW. Treatment facilities also need to understand the non-radiological properties being managed and the hazards posed by the waste. Waste producers will increasingly be required to provide this information for radioactive waste and appropriate characterisation or sampling of the non-radiological properties of the waste needs to be carried out. The remainder of this guidance looks at the managem ent of non-radioactive waste; waste producers can then consider where they need to appl y the same principles to the management of the non-radiological properties of ra dioactive waste.


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2.3 Why manage non-radioactive waste responsibly?

Responsible waste management is required to meet a number of regulations, standards and expectations.

There are a number of legal requirements for the handling, storage and disposal of waste. It is important to note that there may be differences in the legal framework in England, Wales, Scotland and Northern Ireland.

Regulatory bodies may impose specific conditions on waste management as a condition of a site’s permit or any exemptions allowed. Record keeping and associated paperwork are also required.

Responsible waste management includes managing and minimising its environmental impact.

Waste needs to be managed in a manner that does not adversely impact the health of local communities or animal health.

Management of wastes should protect the health and safety of the workforce undertaking waste management duties.

Public expectation is that wastes are handled in a safe and effective manner.


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2.4 Key principles of non-radioactive waste manage ment

The first key principle of waste management is that the Polluter Pays. This principle states that the person or organisation generating the waste is responsible both for its management and the costs of managing it. It is a legal requirement in the Waste Framework Directive.

The second key principle of waste management is the Precautionary Principle. This principle states that if the effects of a component or components of the generated waste are unknown, the waste management approach should assume caution and proceed as if the material is hazardous until it is proven otherwise. The European Waste Catalogue (used to determine waste classifications) requires that unknown components be treated as hazardous unless the waste creator can determine otherwise. The European Waste Catalogue will be covered in more detail later in the guidance.

The third key principle of waste management is Proximity. Wastes should be dealt with local to the point of generation. Trans-boundary shipment of waste, that is, shipment of waste across international borders, is discouraged and may not receive regulatory approval.

The fourth key principle of waste management is Prevention. Prevention of waste is the first strategic preference in the waste management hierarchy.


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2.5 Waste management hierarchy for non-radioactive waste

The waste management hierarchy or waste hierarchy defines a ranked list of waste management options according to their environmental impact, with a preference for waste management options that have the lowest possible impact (i.e. those at the top). Waste producers are legally obligated to take all reasonable measures to apply the waste hierarchy throughout the waste management process including when they transfer the waste to another business. Early consideration of waste management options enables potential wastes to be moved up the hierarchy, reducing environmental impact and often also reducing overall cost. PREVENTION The most successful way to undertake waste management is not to create waste in the first place. Waste can be avoided by designing out waste - changing process steps or by using different materials. If waste prevention is not possible, the amount of waste produced should be minimised. It is also important to prevent or minimise the amount of hazardous waste created; for example, by the substitution of a less hazardous alternative. PREPARE FOR RE-USE Re-use re-categorises waste as a useful item or items or as a reusable raw material. Checking, cleaning, repairing or refurbishing items or potential spare parts enables them to be re-used on site or by other organisations. RECYCLING Like reuse, recycling converts waste to a useful substance or product; for example, decontamination of aluminium recovered from a uranium-enrichment diffusion-plant resulted in the clean aluminium ingots being able to be released for resale on the open market. OTHER RECOVERY This is similar to recycling, but recovers other resources from the waste - especially energy; through, for example, combustion with energy recovery or anaerobic digestion. Alternatively, demolition material could be used as infill on a site. DISPOSAL Disposal is the option of last resort, to be considered only after all other avenues have been exhausted. Disposal covers disposal to landfill or incineration without energy recovery.


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2.6 Legislative framework for non-radioactive waste The legislative framework includes a number of EU and UK legislative acts, covering the definition and processing of waste, control of substances hazardous to health or detrimental to the environment, waste electronic equipment, transport, storage and handling of wastes. EU Directives are enacted into UK legislation. This section of the guidance highlights only the most relevant; it is not an exhaustive list. Key components of the legislative framework include:

Additional information on these components of the Legislative framework can be found in section 6. WM3 (and the EWC) will be referred to regularly throughout the guidance and in particular in section 4, therefore, it is worth noting what an important document WM3 is in UK non-radioactive waste management. WM3 contains a copy of the EWC, which is also known as the LoW. This guidance does not cover gaseous emissions or liquid effluents.

Key European components:

• The Waste Framework Directive (WFD).

• The European Waste Catalogue (EWC) or List of Wastes (LoW).

• The Waste Electrical and Electronic Equipment Directive (WEEE).

• Specific directives covering for example: batteries; packaging; and end-of-life vehicles. Key UK components:

• Environmental Protection Act 1990 (EPA 90).

• Waste Regulations 2011.

• Control of Substances Hazardous to Health 2002 (COSHH).

• Environmental Permitting Regulations 2010.

• Regulations covering transport, storage and handling of waste materials, including the Control of Asbestos Regulations 2012.

• Guidance on the classification and assessment of wastes (Technical Guidance WM3).


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2.7 The regulators

The regulators for non-radioactive waste are the Environment Agency in England (EA), the Scottish Environmental Protection Agency (SEPA), Natural Resources Wales (NRW) and the Northern Ireland Environment Agency (NIEA). It should be recognised that there are differences in what legislation applies and how it is applied based on region. Generally, environmental regulation in Scotland is enacted separately to that for England and Wales, so it is important to check if there are any details that differ. For example, the application of waste classification codes given in the European List of Wastes for mixed wastes is different in Scotland to its application in England and Wales. Application of the Landfill Tax is also applied differently. 2.8 Other regulatory considerations for non-radio active waste There are a number of general considerations associated with the regulation of waste management.

• Under EPR10, permits are required for most waste management activities. Waste management must conform to the waste hierarchy and regulators will need to satisfy themselves that all reasonable efforts have been made to apply the waste hierarchy. They may apply restrictions on the quantities of materials handled or stored.

• Exemptions from the permitting process are possible e.g. for scrap metal recovery, or for quantities of materials below a specified limit. These exemptions are requested by waste producers and granted by the regulators.

• The waste management Duty of Care code of practice imposes a duty of care on waste producers to ensure that the waste is handled responsibly; if it is passed to another organisation, the waste producer has to be satisfied that the recipient complies with the Duty of Care.

• There is a requirement on businesses to classify, code and describe all waste according to the EWC/LoW before it is collected, disposed of or recovered. This applies to both hazardous and non-hazardous waste.


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2.9 The consequences of non-radioactive waste misma nagement Responsible waste management is crucially important, because mismanagement of wastes can have a number of adverse consequences all of which can affect an organisation’s ability to win future work. The diagram below explores the consequences of mismanagement and provides some real life case studies.

Mismanagement could result in:

Criminal proceedings Convictions

Fines Imprisonment

A director of a skip hire company pleaded guilty to 7

charges under the Environmental Permitting Regulations 2010 and was fined £14,000 plus £7,000 costs. The

charges related to site waste levels being over 80 times in excess of their permit limits. The company has ceased trading.

Mismanagement could result in :

Loss of public confidence Negative perception adversely affecting goodwill and the undertaking of further

waste management activities Damage to reputation

Remedial actions

Loss of public confidence can have a serious effect upon how a business or organisation is

perceived. In 2010, an oil company had to devote significant resources to overcoming the loss of public confidence following an oil spill

in the Gulf of Mexico; as did a major car manufacturer involved in an emissions

testing scandal.

Regulatory bodies could:

Take regulatory action Withdraw permits

Reduce or restrict permitted activities Close waste management routes

Require re-demonstration of compliance with permits Require remedial actions

One of the UK's largest concrete suppliers was fined £110,000 for

environmental offences. The site’s environmental permit was designed to cut pollution and limit the impact of operations on

residents. The company had breached an enforcement notice in April 2015 requiring lorry wheels to be cleaned before leaving site.


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Adverse impact on public health Mitigation and remedial actions

In 2004, the same machinery and scrap metal company was fined £20,000 by the Environment Agency when an illegal bonfire produced dangerous fumes.


Adverse impacts on the health and safety of the workforce

Remedial actions Possible withdrawal of labour

A machinery and scrap metal company was ordered by the Environment Agency to pay almost £60,000 in fines and costs for health and safety failings after workers suffered from lead poisoning.


Adverse impact on the environment Mitigation or remedial actions

A company in Medway was ordered to pay £17,120 for illegal waste activity. The Environment Agency found “significant” volumes of waste on and surrounding the

permitted site. It said the company exceeded the limit of 20te of non-hazardous waste and 150te of inert waste.

So who has overall responsibility? It is worth remembering that ultimately the waste producer has a Duty of Care to manage waste responsibly, and there is individual and corporate liability for any mismanagement that occurs. A sheriff court jailed a former director of a tyre recycling company for 14 months and fined the firm £195,000 for illegally depositing and keeping controlled waste.


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3. Managing non-radioactive waste across the

waste management lifecycle A waste producer’s duty to manage waste responsibly applies across the whole waste management lifecycle from planning and characterisation; through generation, packaging and storage; to transfer for treatment and, if necessary, disposal. Section 3 of this guidance looks at good practice for each section of the lifecycle.

3.1 Planning and characterisation

3.1.1 Facilitating good waste management

Good management starts with early planning as this enables waste producers to:

• consider how they will apply the waste hierarchy • characterise waste to fully understand the physical, biological, chemical and

radiological properties of each component of the waste in order to optimise the plan for the waste’s management.

• secure permits before undertaking work • be proactive rather than reacting to an adverse event • take responsibility for waste under Duty of Care obligations.

Early planning allows time for waste producers to establish what potential wastes they are dealing with, and to develop the most appropriate strategy for managing the wastes. Waste producers should plan to avoid generating waste if it has not already happened and consider wherever practicable re-use or recycling of materials. It also enables waste producers to determine if an application for exemption is applicable. The CL:AIRE Code of Practice and Waste & Resources Action Programme guidance are useful in this context. This Code of Practice sets out good practice

for industry to use when assessing whether excavated materials are classified as waste or not. It also allows the determination, on a site specific basis, when treated excavated waste

can cease to be waste for a particular use.

CL:AIRE CoP

These protocols set out the steps that must be taken for waste to become a non-waste

product or material that can be either reused by business or industry, or supplied into other markets. This enables recovered

products to be used without the need for waste regulation controls.

WRAP quality protocols


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3.1.2 Case Study This hypothetical case study will be used to illustrate the principles and good practices associated with non-radioactive waste management. Background information A vehicle maintenance workshop is to be converted into a sort and segregation facility. The building dates from the 1950s, and was constructed from materials typical of structures from that time including asbestos.

Ground Plan of the Former Vehicle Maintenance Facility

Previously, it was used to maintain vehicles, and a legacy of oil stained concrete floors, tools, oil, grease, rust passivators and used parts has been left for the conversion crew. The building has a scrapping area for redundant parts such as car batteries, pieces of redundant equipment, and forklift truck battery packs. Other wastes include a stack of broken wooden pallets, part filled paint tins, old brake pads, cabling, surplus hydraulic ram spares, diagnostic equipment, oil spill residues, copper piping, asbestos lagged pipework, and asbestos sheet in dividing wall. In the staff change room there are a stack of blown fluorescent tubes, and resin-based flooring. In the office there are surplus, reasonably modern, computers. Initial waste hierarchy considerations:

• To minimise waste, the roller-shutter doors to Bays 1 & 2 are to be retained in the new sorting facility.

• Hydraulic platforms in Bays 1 & 2 have been transferred for re-use to the new vehicle maintenance facility.


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Managing the potential waste from the conversion Thinking about the questions below, some of the issues to be considered are highlighted in in the red boxes:

1. Are there any wastes that don’t need to be generated? 2. Are there any wastes that could be moved up the waste hierarchy to reduce

environmental impact? 3. What wastes might need early or specialist attention to avoid having to react to an

adverse event and to comply with a waste producer’s duty of care? 4. Is any additional characterisation needed to optimise the plan for the waste’s

management?

Some wastes such as the waste oil and the oil soaked floor have already been created, so there is no scope to prevent them. The oil could be routed for incineration with heat recovery rather than disposal. Only the oil contaminated sections of the concrete floor might need removing.

Repair Bay 2 & Store

For wastes that are still to be generated, there may be scope for prevention or minimisation. Not all the internal walls may need demolishing - this would reduce the volume of waste generated; and, if appropriate and safe to do so, would also avoid disturbing asbestos within the walls. Minimising the amount of hazardous waste created is particularly important.

Walls

Early planning helps with the identification of potential problems, such as asbestos lagging on pipes and in walls and ceilings. It enables early characterisation of potential problem materials, for example, determining if the older brake pads might contain asbestos. Bay 1 should be rechecked to see if there is also oil contamination of the floor.

Spares and General Storage & Bay 1

Early planning enables potential options for treatment, re-use, recycling or other recovery to be considered rather than disposal. The surplus office computer could be used in another office on site; the diagnostic equipment, tools and spares may be useful in the new vehicle maintenance facility; copper pipework is ideal for recycling; cabling might be suitable for reuse or recycling too. The broken pallets could be routed for incineration with heat recovery rather than disposal.

Office & Spares, Bay 2 & External Storage

Early planning also gives a head start for putting in place permits and other documentation. And ensuring the appropriate contractors undertake work - such as management and handling of the asbestos.

All


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3.1.3 Developing the plan It is good practice to produce a Project Waste Management Plan (PWMP), or a similar planning document, as these provide a useful reminder of issues and factors to be considered. The PWMP sets out what is anticipated in terms of the wastes to be managed, the properties of the wastes, classification, waste route, handling and treatment requirements as well as timescales and who needs to be involved.

The permits and acceptance criteria of downstream processing or disposal facilities or other organisations involved need to be taken into account in the PWMP. These define the form or forms, composition and quantities of waste that can be accepted. Transport requirements can also set criteria in terms of how the waste must be packaged. The content of the waste itself may limit the waste disposal routes able to accept the particular waste. For example, not all landfill sites can accept hazardous waste, and asbestos disposals require specialised locations. The PWMP should be reviewed and revised as necessary to reflect operational changes as well changes following characterisation. Wastes that were originally considered to be non-hazardous may have been found to be hazardous, and vice versa. This would impact their classification and coding, and may have implications relating to the WAC of the intended treatment or disposal facilities.

The National Waste Programme has produced both a PWMP template and an associated guidance document. These can be used for both radioactive and non-

radioactive waste; they can be accessed via: http://llwrsite.com/national-waste-programme/waste-practitioner-support-guidance/

A Project Waste Management Plan (PWMP) includes:

� a checklist of factors to be considered � wastes to be managed � non-radiological and radiological

properties of the waste � classification and coding of the waste � waste route(s) � handling and treatment requirements � timescales � who to involve � Waste Acceptance Criteria � transport and packaging requirements


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The PWMP should be treated as a ‘live’ document; it is an important tool for communicating plans for the management of the waste to all those involved. It should be updated as soon as circumstances or information changes, so that all stakeholders who access the PWMP are working to the latest requirements.

3.2 Generation and pre-treatment

The first consideration in waste generation is to prevent or minimise waste to be created, the first level of the waste hierarchy. Once waste has been generated, it’s too late to take action. This may be the case for legacy waste from past projects and activities.

Preventing waste generation means that waste management has been optimised.

Minimising the amount of wastes created reduces the amount of subsequent rework or the volume for disposal.

Wastes generated need to be compatible with downstream processes. Processing facilities may impose restrictions on the content, composition or form of the received waste.

The second stage of waste generation is, therefore, to consider whether changing the properties of the waste would facilitate handling or recovery.

The waste may be acceptable in its current state for example the blown fluorescent tubes in the case study.

It may benefit from dismantling or size reduction into separate hazardous and non-hazardous components. Removing asbestos lagging from redundant pipework to facilitate separate management; or cutting of pipework into shorter lengths to facilitate handling and storage.

Remember, waste producers are required by law to classify, code and describe their non-radioactive waste as set out in the WM3 and the List of Wastes

(see guidance section 4).

This information must be worked out before waste is moved, disposed of or recovered. It must be included on waste documents and records; and will

determine the controls that apply to movement of the waste.


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Sorting or segregation could be used to separate material with hazardous contamination from uncontaminated material. A concrete planer could be used to skim the oil-soaked surface-layer from the workshop floor so that only the oil contaminated concrete need be managed as hazardous waste. Visual inspection or core samples could be used to confirm that the remaining floor could be left in place, minimising waste generation.

Draining liquids such as sump oil or hydraulic fluid facilitates downstream handling. Putting a hydraulic ram containing trapped fluid into a smelter could be highly explosive. Draining fluids also makes storage easier for the solid waste components.

Clean up can be used to remove surface contamination. Spills residues in the repair area or stores could be wiped away. Section 3.3 of this guidance looks at handling, packaging, and storage of non-radioactive waste, however, in terms of waste generation, it should be conducted in such a way that double handling is minimised, and to take account of the intended storage, transport, treatment or disposal requirements. Handling is facilitated if the waste is in a suitable form for use of standard handling equipment, for example, if it is drummed, bagged or appropriately dismantled. But items should not be dismantled more than necessary; ion-exchange cartridges are more easily handled than loose beads. 3.3 Handling, packaging and storage

3.3.1 Handling

The handling of waste depends upon the nature of the material being handled. Non-hazardous waste can be handled simply and by standard handling equipment. Hazardous waste will require more in the way of Personal Protective Equipment (PPE) – and, for items such as asbestos, will require specialist skills and equipment.

3.3.2 Packaging and labelling

Some wastes may not require packaging – inert soil and rubble fill being typical examples. Other wastes may require packaging to keep waste dry, segregated from other materials or to facilitate later processing. Wastes scheduled for receipt at processing or disposal facilities should be in packaging which meets the relevant Waste Acceptance Criteria.

Packaged waste should be clearly labelled with both unique identifiers (e.g. bar code) and a description for human eyes. The relevant codes should match the accompanying paperwork.


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Wastes with a List of Wastes hazard categorisation should also be clearly labelled with the appropriate symbol(s) to reflect the waste’s Hazardous Properties.

For dangerous goods, United Nations approved packaging must be used. Seek advice from a Dangerous Goods Safety Advisor on site. 3.3.3 Storage

Storage must be appropriate for the material being handled.

For example:

• waste bricks could be stacked outside a building • items with the potential to release gases or flammable vapours would require more

controlled storage • batteries must have the terminals capped to prevent short-circuiting whilst stored • liquids should be stored to minimise leakage in a bunded area to contain the liquids

in the event of container leakage/failure. Spill kits should be available where the nature of the liquid indicates them.

Storage considerations also depend upon time limits imposed by permits or other legal requirements. Longer term storage will usually be facilitated if liquids are drained. Shrink wrap and palletisation may also be used for suitable wastes. 3.3.4 Handling, packaging, and storage of the case study waste

The way wastes are handled, packaged and stored will of course vary between organisations and sites due to local procedures and available waste processing routes. Below are examples of possible options to consider for the waste in the mechanical maintenance vehicle workshop, though it is acknowledged that sites will and can do things differently.

It is important to note that hazardous wastes must not be mixed together; for example, it is prohibited to mix waste chemicals together. Be aware that it is also

prohibited to mix non-hazardous wastes with hazardous wastes.


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Handling, packaging and storage of potential wastes from the vehicle maintenance workshop conversion:

Forklift truck battery packs should be stored with terminals insulated/capped; and should be collected by a specialist recycler.

Bricks and rubble from remodelling activities could be recycled. Good bricks could be reclaimed and reused. Rubble could be used as infill if it is asbestos free. The materials could be stored in builders’ bags or in a skip. Asbestos contaminated material or items would need to be retrieved, handled and disposed of by a specialist contractor in line with asbestos regulations.

Diagnostic equipment could be shrink wrapped and delivered to other vehicle facility for reuse.

Concrete shavings from a planer machine (skim off surface) would be suitable for machine collection and skip disposal. Fluorescent tubes should be recycled under the WEEE Directive. They should be collected by hand, segregated, stored and transported in such a way that the tubes are not broken. Mercury from only one fluorescent lamp can contaminate up to 30,000 litres of water beyond a safe standard for drinking.

Paint tins and similar small containers are also most suited to hand collection and management by a specialist recycler.

3.4 Transfer for treatment and disposal The next step in the waste management lifecycle is transferring wastes off site for treatment or disposal. There are a number of key considerations in relation to transport, treatment and disposal. Firstly, the Waste Acceptance Criteria of the intended treatment or disposal facilities may specify that the transfer of material conforms to certain specified restrictions. These could be to do with the container type or size or the vehicle on which it is to be transported. Secondly, the waste consignment may be subject to the Carriage of Dangerous Goods Act (CDG) 2009 and its 2011 amendments (or Scottish equivalents).


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Web links to a Hazardous Waste Consignment Note template and the non-hazardous waste equivalent, a Waste Transfer Note, can be found in Section 6.3. There is a legal requirement for record keeping. Hazardous Waste Consignment Notes are to be completed in triplicate, and held for up to 5 years. The Waste Transfer Notes are completed in duplicate and held for 2 years. Waste producers using a waste contractor to handle their waste, need to assure themselves that records are being appropriately maintained and are accessible. Treatment works and disposal facilities for handling waste materials need to be authorised under EPR10 or relevant devolved administration legislation. Their permits will specify what material(s) can be handled and set regulatory limits. Waste producers must satisfy themselves under their Duty of Care that the recipient treatment and/or disposal facilities are covered by EPR10 permits and have been duly licenced to receive the wastes being transferred. A facility may impose additional restrictions on the form, content or quantity of the waste materials they can receive to reflect the requirements of their specific permit. By adopting a Project Waste Management Plan, waste producers are encouraged to engage early with key stakeholders such as treatment and disposal contractors, to establish any such requirements or limitations.

On most sites, waste producers usually contract with waste contractors to handle bulk or specialised wastes. Therefore it is possible that several contract organisations may be working on the same site. Waste producers must satisfy themselves that all organisations engaged comply with the Duty of Care.

CDG 2009 covers materials that are explosive, gaseous, flammable, oxidising, toxic, radioactive, and corrosive, as well as other miscellaneous dangerous goods. The Dangerous Goods Safety Advisor on site should be consulted with regard to such

transfers.

There are also other legal requirements associated with the transfer of non-radioactive waste materials. A Hazardous Waste Consignment Note must accompany all

hazardous waste shipments. List of Wastes EWC code(s) and Hazard codes (also known as Hazardous Property codes) relevant to the waste need to be entered on the

form; these are discussed in more detail in section 4.


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4. Classification, codes and assessment procedure

for non-radioactive waste 4.1 Overview

Section 4 is a basic introduction to the waste classification system and the assessment procedure for non-radioactive waste. This is for familiarisation purposes only, individuals required to classify waste will need to undertake comprehensive training; this is because the List of Wastes (or LoW) contains a very specific set of legal instructions that must be followed to ensure waste is correctly coded – it is a detailed and complex process. Section 4 draws on Technical Guidance WM3 (Guidance on the classification and assessment of wastes), which sets out a 7 step process (shown in flowchart below) which needs to be followed to confirm a classification for waste and to describe its hazardous properties.


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4.2 Step 1 – Is classification required?

Non-radioactive waste: The first step is to ensure the waste needs to be classified and coded. As discussed earlier, radioactive waste is excluded from the Waste Framework Directive unless it has been determined to be out-of-scope of (or from an activity exempted from) radioactive waste legislation. There are a number of other reasons why the waste might not need classifying (such as if it is a decommissioned explosive or waste water). It is important to consider all the exclusions before classifying waste.

4.3 Step 2 – Identify code(s) The second step is to identify the waste code or codes that might apply. Appendix A of WM3 contains the ‘List of Wastes’ or LoW, which has a large number of waste categories, each with a separate LoW waste code. These are also called European Waste Catalogue (EWC) codes. These help to clarify if a waste material is hazardous, or non-hazardous. Understanding how to use the List of Wastes is complex as there is a specific ‘Order of Precedence’ to decide on the most applicable waste description; in many cases more than one description and code will need to be considered. There are also exceptions that are treated differently. What follows provides a basic introduction to how the List of Wastes works and what it looks like.

Radioactive waste: It is worth noting that though you are not legally required to code and classify radioactive waste under the WFD (unless it is out-of-scope or exempt);

transport providers and some waste management facilities may still require this information. For example, permitted landfill sites operate under a non-radiological

permitting system, which they apply to all waste they receive including Very Low Level Waste (VLLW). They use the information to ensure that they are appropriately handling

and disposing of the hazardous components of the VLLW; you will be increasingly required to provide this information.


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The green chapters refer specifically to a process or activity producing waste, and to municipal waste. A business will typically have municipal waste and wastes from one or more processes or activities. A number of chapters will normally need to be considered.

The orange chapters focus on specific wastes e.g. oils or solvents.

The pink chapter contains codes for many general wastes such as vehicles, electronic equipment and chemicals.

The List of Wastes chapters provide both the classification codes and a description of each EWC code; as well as its entry type which is used in Step 3, the next step. On the following page are two example extracts from the List of Wastes, from Chapter 13 (Oil wastes and waste liquid fuels) and from one of the industry process chapters, Chapter 11 (Wastes from chemical surface treatment).

The table from the LoW shown below looks rather like an index. It is designed to help you navigate through the List of Wastes, to identify the area (or LoW chapter) your waste might fall into, such as Chapter 17 ‘Construction and Demolition Wastes’. However it is critical that possible waste code ‘chapters’ are considered in the correct order and that all relevant chapters are considered. The final column shows the Order of Precedence. Possible codes from Order-of-Precedence-1 chapters (the green chapters) must be ruled out before you can consider possible codes from the precedence 2 chapters (the orange chapters). The Order-of-Precedence-3 chapter codes (in the pink chapter) can only be considered once precedence 1 & 2 chapter codes have been ruled out.

What is meant by an Order of Precedence?


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Review the extracts by looking first at the Description, then the code. This then leads to the Entry type used in Step 3. Sample LoW extract 1 : In the case study, the waste sump oil arises from a known source, and has been assigned to a specific code: 13 02 06*

Sample LoW extract 2: In the case study, waste phosphoric acid used in the maintenance workshop to passivate rust could be coded using Chapter 11 codes as shown: Residual, unused phosphoric acid waste - coded as: 11 01.05* - pickling acids. Debris filtered from the used pickling solution - coded as: 11 01 08* - phosphatising sludges.

1. By looking through the various LoW chapters, in the appropriate Order of Precedence, and reviewing all the relevant code Descriptions, you find the description or descriptions that match your waste.

2. This then

identifies the EWC code(s)

that might apply. 3. The Entry Type for

your waste, used in Step 3.

The use of ‘98’

general codes and

‘99’ generic codes is

discouraged.


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If it is not possible to identify a specific code, there are so called ‘98’ general codes and ‘99’ generic codes, as shown. However, general and generic codes should not be used if there is a relevant specific code or codes. The use of general and generic codes is not encouraged, may attract negative regulatory attention, and could incur a disposal cost premium. So wherever possible, a specific List of Wastes EWC code or codes must be identified. 4.4 Step 3 – Identify what additional assessment i s needed

Having established the possible code(s), Step 3 identifies what further assessment is required to confirm the correct code(s); this is determined by the Entry Type identified in the LoW.

The List of Wastes has 2 overarching Entry Types:

Hazardous - possessing a hazardous property such as asbestos or oils. Non-hazardous - not possessing a hazardous property, but requiring handling as waste; such as certain scrap metals like iron or copper or rubble.”

Both have the sub-divisions of ‘Mirror’ and ‘Absolute’, giving four List of Wastes Entry Types:

AH - Absolute Hazardous

MH - Mirror Hazardous

MN - Mirror Non-hazardous

AN - Absolute Non-hazardous

Absolute: this means that the material is definitely in that category and the waste is from the outset automatically classified as Absolute Hazardous or Absolute Non-hazardous.

Mirror: most wastes are not automatically hazardous or non-hazardous - they are called mirror entry wastes. Mirror is used to indicate that there may, or may not, be hazardous substances at or above levels that cause it to display a Hazardous Property such as being ‘Flammable’; or that there may, or may not, be Persistent Organic Pollutants (POPs) at or above prescribed concentration limits.

Waste sulphuric acid is categorised in the LoW as Absolute Hazardous no matter the concentration level. It is assigned EWC code: 10 01 09* and is always automatically Absolute Hazardous. Wooden packaging is Absolute Non-hazardous (EWC code: 15 01 03) and is always automatically Absolute Non-hazardous.


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Colour coding is used to distinguish the 4 entry types and all hazardous codes have an asterisk after them e.g. 11 01.05* - pickling acids.

What is the significance of the Entry Type?

Entry Type:

Absolute Hazardous (AH) Mirror Hazardous (MH) Mirror Non-hazardous (MN)

Absolute Non-hazardous (AN)

An example given in the WM3 Guidance is for waste soil containing an unknown amount of hazardous substances. Possible EWC codes are: Soil and stones containing hazardous substances - Mirror Hazardous Soil and stones other than those mentioned above - Mirror Non-hazardous. At this stage both codes could apply, it is only at Step 6 that it will be confirmed whether or not there are hazardous substances or POPs at or above the limits set out in WM3. If limits are exceeded, it would then be confirmed as Mirror Hazardous; it is important to understand that it does not become Absolute Hazardous. ‘Absolute’ is reserved only for those wastes, which are always hazardous no matter the concentration. For example, construction material containing asbestos would be categorised as Mirror Hazardous and Mirror Non-hazardous until it is known at Step 6 if the asbestos is at or above the threshold limit of 0.1%. The threshold means that it is concentration dependent. It would be classified as Mirror Non-hazardous if it was below the limit (or limits - be careful additional limits can be introduced during the assessment process). It would be classified as Mirror Hazardous if the limits were exceeded. Concentrations and thresholds are considered at Step 6. And only at Step 7 is the final Mirror Hazardous or Mirror Non-hazardous classification and coding confirmed.

If Step 2 classifies the waste as AN, then in most cases proceed straight to Step 7 and

assign the waste code already identified. (There are no Hazardous Properties.)

If Step 2 classifies the waste as a mirror entry, then steps 4-7 need to be completed to both identify which actual codes apply to the waste (is it mirror hazardous or mirror

non-hazardous?) and to determine the Hazardous Properties to list on the

consignment note.

If Step 2 classifies the waste as AH, then the preliminary code(s) identified are correct and

must be the code(s) used. Further assessment (undertaking Steps 4-7) is only to determine the Hazardous Properties that

need to be listed on the transportation Consignment Note, since the waste has already been confirmed as hazardous.


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4.5 Step 4 – Determine the chemical composition of the waste Steps 4 to 6 are concerned with the composition and Hazardous Properties for the wastes that were identified as either mirror entries or absolute hazardous entries. For the mirror entries it still remains to be determined if they actually display a Hazardous Property (for example is there enough flammable content to render the waste actually flammable?). Step 4 answers the question ‘What chemicals are in the waste?’; establishing its chemical composition, if this is not already known. Considering the maintenance workshop case study, it may be known that there is a pot of degreasing waste containing hazardous substances 11 01 13*, but it still remains to be determined what it is made from, what hazardous substances it contains and how much of each chemical is in the waste. Typical sources of information:

The tins of spray paint in the case study will have a Chemical Data Sheet provided by the manufacturer detailing their contents.

Information on specific chemicals or products can be found through reliable websites e.g. the European Chemical Agency (ECHA) website.

A well understood industrial process may directly provide the necessary waste composition information.

Where additional sampling is required, a Sampling Plan, as extensively detailed in the WM3 guidance (and in accordance with the relevant British Standard) should be developed. This covers the ‘who, how, where and why’ associated with sampling of wastes.

WM3 also provides guidance on the analysis of sample results to determine if a material is hazardous or not.

WM3 indicates the paperwork and chain of custody requirements. This ensures that samples are taken, packed and handled in ways to preserve the sample for analysis by accredited laboratories, and an unbroken chain of custody indicates that the samples are reliable.

Environmental regulators may review any of the above documents in order to assess the approach taken and accuracy of results.


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4.6 Step 5 – Determine if the composition includes hazardous substances or POPs

Once Step 4 is completed and the chemical composition of the waste is known, the information is used to decide if the composition includes: 1) Persistent Organic Pollutants - the resin flooring material in the staff changing room

may have contained PCBs, which are POPs; Step 4 should have confirmed the composition and this step identifies if the composition includes a listed POP – a list can be found on page 9 of WM3.

2) Hazardous substances - this is achieved by revisiting WM3 and looking at Appendix B,

which explains how to identify if the waste includes hazardous substances and the chemical classification of the individual substances. The process also identifies the hazard statement codes (see below) assigned to the hazardous substances. Again there is a process that needs to be followed carefully that includes checking relevant manufacturer’s or supplier’s safety data sheets and a Classification and Labelling Inventory database that is maintained by ECHA.

Hazard statement codes A hazard statement code, and its associated description, describe the nature of the hazard in the substance or mixture; indicating a potential risk. Below are two extracts from WM3 showing examples of hazard statement codes such as: H350, along with its associated description ‘May cause cancer’; or H372, ‘Causes damage to organs’. These are hazard statement codes for asbestos.

The last column in the table identifies the Hazardous Property or Properties (for asbestos HP5 & HP7) associated with the hazard statement code(s); this information will be used in the next step.


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4.7 Step 6 – Assess the Hazardous Properties of th e waste

There are 15 listed Hazardous Properties with Hazardous Property codes; these are referred to as Hazard Codes on the Waste Consignment Note.

Hazardous Property Hazardous Property HP1 Explosive HP9 Infectious HP2 Oxidizing HP10 Toxic for reproduction HP3 Flammable HP11 Mutagenic HP4 Irritant HP12 Release of an acute toxic gas

HP5 Harmful

HP13 Sensitizing (to the skin or the respiratory organs)

HP6 Toxic HP14 Ecotoxic HP7 Carcinogenic

HP15 Waste capable of exhibiting a hazardous property listed above not directly displayed by the original waste

HP8 Corrosive

Step 6 takes into account the concentration levels of the chemicals in the waste to assess the Hazardous Properties that the waste actually displays. Although the composition may include chemicals with assigned hazard statement codes, it does not mean that the associated Hazardous Property will be displayed. For example, ethanol has a flashpoint of < 23oC, whereas a 4% ethanol aqueous solution has a flashpoint > 60oC, and would not display Hazardous Property HP3, Flammable. The hazard statement codes identified in Step 5 determine which Hazardous Properties you initially need to consider (these were HP5 & HP7 for asbestos). There are 3 methods that can be used to check if the Hazardous Property applies to your waste, these include:

Once you know which of the 15 Hazardous Properties apply, you must then consider for mirror entries if any POP is present above the concentration limit listed in Appendix C, page C58. This information, on the Hazardous Properties displayed by the waste, can now be used on your Consignment Note and waste labelling of the non-radioactive waste.

By calculation, with reference to a set of concentration limits. The threshold limits that apply are identified by considering Appendix C of WM3. Appendix C sets out the hazardous statement codes linked to each Hazardous Property; it provides an assessment flowchart or decision tree; concentration limits (the decision tree can introduce additional concentration limits to consider as you progress through the assessment); and test methods.

By reference to a datasheet.

By actual experimental testing for the property. This is typically used when testing for explosive, oxidising or flammable properties.


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4.8 Step 7 – Assign code(s) The final step in the assessment and classification procedure is to assign the classification code. For wastes identified at Step 3 as being Absolute Non-hazardous, the preliminary waste code applied. Likewise, for wastes identified at Step 3 as being Absolute Hazardous, the preliminary EWC code applied. If a waste was classified as Mirror Hazardous or Mirror Non-hazardous, the Mirror Hazardous code must be assigned if the additional assessment of the waste composition showed that the waste contained one or more hazardous substances or POPs above the specified limits. If waste with an initial preliminary Mirror designation does not contain a hazardous substance or a POP above the specified limits, it should be classified as Mirror Non-hazardous and assigned the relevant EWC code.

Once the codes have been assigned, the Project Waste Management Plan (PWMP), discussed in section 3.13, should be reviewed and revised as necessary based on the assigned waste codes. Wastes that were originally considered as non-hazardous may have been found to be hazardous, and vice versa. The PWMP review should check that it still covers the wastes appropriately including their handling and transport, and any implications relating to the acceptance criteria of the intended treatment or disposal facilities.

In the Case Study, the waste sump oil has the allocated EWC: 13 02 06* synthetic engine, gear and lubricating oils. It is designated Absolute Hazardous. Construction material containing asbestos at or above the threshold limit of 0.1% would be categorised as Mirror Hazardous with EWC code: 17 06 05*.

For mixed materials, the situation is a little more complicated. Typically in England and Wales, the mixed wastes would receive all pertinent codes depending upon the composition of the mixture. In England and Wales, multiple codes are permitted. Whereas in Scotland, multiple codes are not permitted, and there are no de minimis levels (the level/concentration below which the item or chemical need not be considered). Consequently, the waste would have to be assigned the most restrictive classification code.

The example quoted in WM3 is a batch of non-hazardous construction waste (17 09 04), which if contaminated sufficiently with PCB containing wastes, such as PCB containing resin-based floorings, should be coded as 17 09 02* - construction and demolition wastes containing PCBs.

In England and Wales the allocated codes from the WM3 guidance would be: 17 09 02* Construction waste containing PCBs 17 09 04 Non-hazardous construction waste

In Scotland it would be just:

17 09 02* Construction waste containing PCBs.


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4.9 Summary of the waste classification and assess ment procedure 7 step process for non-radioactive waste

It is worth reiterating that this guidance provides only a basic introduction to waste classification, codes and the assessment procedure for non-radioactive Waste; it does not equip the reader to undertake waste classification and coding. Comprehensive training is required to classify waste correctly.


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5. Summary of key points

1) Waste is “Any substance or object which the holder discards or intends or is required to discard.”

2) The Legislative Framework for managing conventional (non-radioactive) waste is defined by EU Directives translated into UK legislation. The Waste Framework Directive and List of Wastes are the two key components of the legislative framework. WM3 is UK guidance on how to apply the LoW in the UK. Waste producers are required by law to classify, code and describe their non-radioactive waste as set out in the LoW. There are some variations in how these instruments are applied in England, Wales, Scotland and Northern Ireland.

3) Formerly radioactive waste is considered as non-radioactive waste after re-categorisation renders it out of the scope of regulation governing radioactive waste.

4) Non-radiological properties of waste describes the components of radioactive waste generated on a nuclear-industry site that should be assessed as conventional waste; as they would be on any other industrial site. This enables permitted landfill sites and treatment facilities to appropriately handle, treat or dispose of the hazardous or polluting components of the waste. All requirements to appropriately manage the radiological properties of waste, including during its transportation, must be fully complied with.

5) The 2 broad entry types of non-radioactive waste in the European Waste Catalogue, or LoW, are ‘Hazardous’ and ‘Non-hazardous’. Both have sub-divisions of ‘Mirror’ and ‘Absolute’.

6) The various codes generated during the 7-step classification and assessment process for non-radioactive waste take the forms:

• EWC code - 17 06 05* • Hazard statement code - H372 • Hazardous Property code or Hazard Code - HP5.

7) Under the WFD, waste producers are legally obligated to take all reasonable steps to apply the waste management hierarchy; starting with the preferred option of waste prevention, and finishing with the least preferred option, disposal.

8) Applying good practice in waste management is a sign of responsible waste management, and helps a waste producer in its Duty of Care to manage waste effectively.

9) The key stages of waste management lifecycle to be considered are:


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6 Additional information on non-radioactive waste

6.1 National Waste Programme (NWP) resources

The NWP PWMP template & guidance for radioactive and non-radioactive waste can be found at: http://llwrsite.com/national-waste-programme/waste-practitioner-support-guidance/ The NWP eLearning module Introduction to Radioactive Waste is available on the Nuclear Training Network portal. Register at: https://www.nucleartrainingnetwork.com/ Search ‘NWP’ to locate all free training courses provided by the National Waste Programme.

6.2 Regulatory links

Regulatory bodies within the UK for non-radioactive wastes:

I. In England: The Environment Agency (EA) https://www.gov.uk/government/organisations/environment-agency

II. In Scotland: The Scottish Environmental Protection Agency (SEPA) http://www.sepa.org.uk/

III. In Wales: Natural Resources Wales (Cyfoeth Naturiol Cymru) (NRW/CNC) https://naturalresources.wales/?lang=en

IV. In Northern Ireland: Northern Ireland Environment Agency http://www.nidirect.gov.uk/northern-ireland-environment-agency

6.3 Paperwork required for non-radioactive waste tr ansfer

Hazardous waste

Hazardous Waste Consignment Note (Template and Specimen Example) https://www.gov.uk/government/publications/hazardous-waste-consignment-note

Non-hazardous waste Waste Transfer Note: https://www.gov.uk/how-to-dispose-of-nonhazardous-waste/waste-transfer-notes


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6.4 Legislation & legislative guidance on non-radio active waste The glossary provides information on relevant legislation and guidance:

Regulation / guidance Description EU

Waste Framework Directive. Directive 2008/98/EC https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/218586/l_31220081122en00030030.pdf

Overarching framework directive covering all categories of non-radioactive waste. It sets the basic concepts, principles and definitions relating to waste management that must be applied by member states.

European Waste Catalogue EWC (List of Wastes or LoW) Commission Decision 2000/532/EC http://www.legislation.gov.uk/uksi/2005/895/contents/made

EWC defines and delineates the categories of hazardous and non-hazardous wastes. See WM3 guidance for its application in a UK context.

Directive on waste electrical and electronic equipm ent (WEEE) Directive 2012/19/EC http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32012L0019

Example of a directive covering specific waste. This directive covers waste electrical and electronic equipment such as transformers, computer hardware and electrical devices. Other directives cover: batteries; packaging; end-of-life vehicles, etc.

UK

Guidance

Technical Guidance WM3: Waste Classification - Guidance on the classification and assessment of wa ste (Guidance for application of List of Wastes) https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/427077/LIT_10121.pdf

WM3 guidance shows the application of the European List of Wastes in the UK context. Step by step guidance for the allocation of waste codes, which are required for all waste materials. It includes specific worked examples, such as mirror wastes and differences between England and Scotland in terms of application.

Environmental

Environmental Protection Act 1990 http://www.legislation.gov.uk/ukpga/1990/43/contents

Definitive legislation combining control of pollution, emissions and waste handling/disposal.

Control of Substances Hazardous to Health (COSHH) 2002 http://www.hse.gov.uk/coshh/

COSHH is the law that requires employers to control substances that are hazardous to health. COSHH regulations indicate hazards associated with potential waste substances, the associated control measures and their maintenance. It also covers monitoring and emergency planning.

Wastes (England and Wales) The Waste (England and Wales) Regulations 2011 http://www.legislation.gov.uk/uksi/2011/988/contents/made

Regulations covering the management of waste in England and Wales.

The Waste (England and Wales) (Amendment) Regulations 2012 http://www.legislation.gov.uk/uksi/2012/1889/contents/made

Amendment to the 2011 Regulations.

Wastes (Scotland)

The Waste (Scotland) Licencing Regulations 2011 http://www.legislation.gov.uk/sdsi/2011/9780111012147/contents

Regulations enacted separately covering the management of waste in Scotland.


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Regulation / guidance Description The Waste (Scotland) Regulations 2012 http://www.legislation.gov.uk/sdsi/2012/9780111016657/contents

Amendment to the 2011 Regulations.

Environmental Permitting The Environmental Permitting (England and Wales) Regulations 2010 http://www.legislation.gov.uk/uksi/2010/675/pdfs/uksi_20100675_en.pdf (Amended 2013, 2014, 2015)

Permitting and Licencing for the storage, treatment and disposal of non-radioactive wastes (only English/Welsh version quoted).

Carriage of Dangerous Goods The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 http://www.legislation.gov.uk/uksi/2009/1348/contents/made

Regulations covering the transport of hazardous wastes and pressure equipment.

6.5 Guidance documents (advisory, non legislative)

Guidance Description

CL:AIRE Code of Practice (CoP) http://www.claire.co.uk/

Code of Practice covering the re-use of excavated materials from greenfield, brownfield and contaminated land sites.

Waste & Resources Action Programme (WRAP) quality protocols http://www.wrap.org.uk/

Guidance on the re-use of material rather than disposal – inert fill, plastics and similar materials.

6.6 Abbreviations and acronyms

A

AH LoW/WM3 waste category – Absolute Hazardous.

AN LoW/WM3 waste category – Absolute Non-hazardous. C

CDG Carriage of Dangerous Goods (Regulations).

CL:AIRE Contaminated Land: Applications In Real Environments.

CoP Code of Practice. D

DGSA Dangerous Goods Safety Advisor. E

ECHA European Chemical Agency.

EPR10 Environmental Permitting Regulations 2010.

EWC European Waste Catalogue (also known as the ‘List of Wastes’ or LoW).

Exempt

Exempt means that no permit is required under the Environmental Permitting Regulations 2010 or Radioactive Substances Act 1993 to keep or use such radioactive sources, or accumulate and dispose of such radioactive waste, provided that the conditions specified are met.


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H

Hazardous Property

A property of the material (flammable, toxic, gas-generating, environmental blight, etc.), which may or may not be dependent upon the quantity or concentration of material present. See WM3 guidance for limits.

HWCN Hazardous Waste Consignment Note. I

Inert

Inert waste means 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 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.

Inert fill Civil engineering term for clean, re-usable material such as soil or rubble recycled as support, foundation or filler material.

L

LoW List of Wastes, the ‘working name’ for the European Waste Catalogue. (See WM3) M

MH LoW/WM3 waste category – Mirror Hazardous.

MN LoW/WM3 waste category – Mirror Non-hazardous.

Non-radioactive waste

Non-radioactive waste is a term used in the nuclear industry to describe waste that can be treated as conventional waste; just as it would be on any other industrial site. Formerly radioactive waste is considered as non-radioactive waste after re-categorisation renders it out of the scope of regulation governing radioactive waste.

N

NWP National Waste Programme. O

Out-of-scope

Out-of-scope of regulation means that there are no restrictions under the Environmental Permitting Regulations 2010 or Radioactive Substances Act 1993 to keep or use such radioactive materials, or accumulate and dispose of such radioactive waste.

P

PCB Polychlorinated Biphenyls.

POP Persistent Organic Pollutant.

PWMP Project Waste Management Plan. W

WAC Waste Acceptance Criteria.

WM3 Waste Management Guidance 3 - How to apply the LoW in practice in the UK.

WRAP Waste & Resources Action Programme.

introductory guidance on the management of the non...

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