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Waste Management Standard Rev 05 UNCLASSIFIED Document 0000-S-90-04-O-0258-00-E Appendix 5 Revision 05 Printed copy uncontrolled p1 of 18 APPENDIX 5 Waste Management Standards Comparison This document is based on original project data and standards in force at date of signing. Purpose This document benchmarks the Company’s waste management practices and plans and determines compliance versus international standards and guidelines. Who is this for? This document supports the Asset/Activity HSE Managers and Environmental and Waste Management Specialists to benchmark performance, determine compliance, maintain internal standards and specifications, and advise Asset/Activity Managers on relevant requirements. Ref Document Aspect/Relevant issues/Requirements Project Specification Comments 1. Environmental, Health and Safety Guidelines for Waste Management Facilities (IFC, December 2007) Environmental Health and Safety Guidelines (EHS) covers establishments and assets, dedicated to urban solid and industrial waste management including waste collection and transport, receiving, loading, utilization and storage, waste disposal, physicochemical and biological treatment and incineration. World Bank (WB) policy relates to the following aspects: Impact of industrial activity and its management; Waste collection and handling; Receiving, loading, utilization and storage of waste; Disposal on landfills; Project siting; General environmental requirements; Monitoring; Work planning for landfills removal and after removal; Hazards Protection ; Company policy and strategy is defined by the following documents: Waste Management Standard 0000-S-90-04-O-0258- 00-E 2011-2015 Corporate Key Performance Indicators for Waste Management and Minimization 0000-S-90-04-P- 0091-00 Waste Classifier Comply except gas control, monitoring programs for Nogliki and Smirnykh landfills

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Page 1: Waste Management Standards Comparison€¦ · Waste Management Standard Rev 05 UNCLASSIFIED Document 0000-S-90-04-O-0258-00-E Appendix 5 Revision 05 Printed copy uncontrolled p1 of

Waste Management Standard Rev 05

UNCLASSIFIED Document 0000-S-90-04-O-0258-00-E Appendix 5 Revision 05 Printed copy uncontrolled p1 of 18

APPENDIX 5

Waste Management Standards Comparison This document is based on original project data and standards in force at date of signing.

Purpose

This document benchmarks the Company’s waste management practices and plans and determines compliance versus international standards and guidelines.

Who is this for?

This document supports the Asset/Activity HSE Managers and Environmental and Waste Management Specialists to benchmark performance, determine compliance, maintain internal standards and specifications, and advise Asset/Activity Managers on relevant requirements.

Ref Document Aspect/Relevant issues/Requirements Project Specification Comments

1. Environmental, Health and Safety

Guidelines for Waste Management

Facilities (IFC, December 2007)

Environmental Health and Safety Guidelines (EHS) covers establishments and assets, dedicated to urban solid and industrial waste management including waste collection and transport, receiving, loading, utilization and storage, waste disposal, physicochemical and biological treatment and incineration.

World Bank (WB) policy relates to the following aspects:

Impact of industrial activity and its management;

Waste collection and handling;

Receiving, loading, utilization and storage of waste;

Disposal on landfills;

Project siting;

General environmental requirements;

Monitoring;

Work planning for landfills removal and after removal;

Hazards Protection ;

Company policy and strategy is defined by the following documents:

Waste Management Standard 0000-S-90-04-O-0258-00-E

2011-2015 Corporate Key Performance Indicators for Waste Management and Minimization 0000-S-90-04-P-0091-00

Waste Classifier

Comply except gas control, monitoring programs for Nogliki and Smirnykh landfills

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Ref Document Aspect/Relevant issues/Requirements Project Specification Comments

Employee Health & Safety;

Training;

Record Keeping and Reporting

2. IFC Environmental, Health and Safety

Guidelines for Offshore Oil and

Gas Development (April. 2007)

Covers development and production activities, pipeline delivery of products, tanker loading and unloading, ancillary and support operations. The guidelines are intended to be used as a standard in project conception and design whilst project operations may be evaluated against the guidelines.

An Environment, Health and Safety Management System (EHSMS) is required for Category A projects.

In terms of solid waste, packaging material, containers, discarded and damaged pipe and drill bits, and leftover construction materials are to be taken ashore and appropriately reused, recycled or disposed. Hazardous wastes (e.g. paint residues, solvents, batteries, pig-cleaning sludge, etc) are to be taken ashore to facilities for treatment and disposal with efforts made to eliminate, reduce or recycle hazardous wastes.

Sakhalin Energy uses a “hierarchical approach” to select appropriate waste management solutions. This prioritises waste minimisation and is consistent with RF and international best practice.

Sakhalin Energy has a strategy for dealing with all items mentioned in the IFC guidelines, as specified in Waste Management Standard 0000-S-90-04-O-0258-00.

Wastes generated offshore including hazardous wastes shall be stored in secure containers on platforms until viable economic quantities are accumulated and then shall be handed over to a licensed contractor for further disposal ashore.

Comply

3. Directive 2000/59/EC of the

European Parliament and of

the Council on port reception facilities for ship-generated waste and cargo

residues (amended by: 2002/84/EC;

2007/71/EC; Regulation (EC) № 1137/2008 of 22

October 2008)

Protection of the marine environment can be enhanced by reducing discharges into the sea of ship-generated waste and cargo residues. One way this can be achieved is through improving the availability and use of reception facilities and enforcement.

The upgraded landfill facilities can receive the Hazard Class 4 and 5 wastes from ships on a contingency basis.

Comply

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Ref Document Aspect/Relevant issues/Requirements Project Specification Comments

4. Directive 2000/76/EC of the

European Parliament and of the Council on the

incineration of waste (amended by

Regulation (EC) № 1137/2008 of 22 October 2008)

This Directive is intended to fill the gaps in existing legislation pertaining to incineration i.e. Directives 89/369/EEC and 89/429/EEC (new and existing municipal waste-incineration plants) and 94/67/EC (incineration of hazardous waste).

Repealing of the latter Directives came into force on December 28, 2005.

Apart from the incineration of non-toxic municipal waste its scope extends to the incineration of non-toxic non-municipal waste (such as sewage sludge, tyres and hospital waste) and toxic wastes not covered by Directive 94/67/EC (such as waste oils and solvents). It is also intended to incorporate the technical progress made on monitoring incineration-process emissions into the existing legislation.

Small capacity incinerators not exceeding 25kg per hour are used by the Company’s contractors for the disposal of selected waste streams such as oily rags, oil filters, oil sludge where no feasible management option currently exists on Sakhalin.

A limit of 90 tonnes per year sets on the total waste that may be disposed of to such incinerators during operations phase. Such activities are limited to Sakhalin Energy operations, controlled and performed by trained personnel.

Sakhalin Energy carries out a compliance audit (to RF standards e.g., air emissions and waste incineration permits are required) for any such incinerator used by contractor.

Comply

5. Council Directive on hazardous waste

91/689/EEC (amended by

94/31/EC; Regulation (EC)

№166/2006 of 18 January 2006; 2008/98/EC)

Member States ensure that hazardous waste is recorded and identified; and that different categories of hazardous waste are not mixed and that hazardous waste is not mixed with non-hazardous waste (except where the necessary measures have been taken to safeguard human health and the environment).

Any establishment or undertaking which carries out disposal operations must obtain a permit.

Establishments or undertakings which carry out disposal operations or operations which may lead to recovery and producers of hazardous waste are subject to periodic inspections covering in particular the origin and destination of the waste. Transporters, producers, establishments and undertakings keep a record of their activities and make this information available to the competent authorities designated by each State.

Does not cover domestic waste.

Sakhalin Energy record, identify and segregate all hazardous from non-hazardous waste classes.

The amount of waste volumes in Classes 1-3 shall be relatively small compared with the non-hazardous classes 4 and 5. The majority of Class 1 and 2 wastes shall be recycled by returning it to the manufacturers, and shall largely comprise LNG filters, mercury lamps and lead acid batteries. Class 3 waste, which largely comprises waste oil, shall be stored in secure containers on assets sites until economic quantities for viable resource recovery and thus have a minimal direct environmental impact.

As part of the landfill upgrade programme, the Landfill Code of Conduct shall stipulate separation and storage of Class 1 to 3 wastes coming from non-Sakhalin Energy sources at the landfills. Waste segregation and checking for compliance is under the landfill Operator's responsibility. Sakhalin Energy shall provide PPE and appropriate training to Landfill operator's personnel to ensure no Hazard Class 1 to 3 wastes are disposed of in the landfill cells.

Landfill operation is permitted through Russian State

Sakhalin Energy complies with EU Directive 91/689/EEC except that the waste classification required under RF law differs in detail from that of the EU waste classification.

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Ref Document Aspect/Relevant issues/Requirements Project Specification Comments

environmental expertise, State Construction expertise, waste disposal limits approval and Hazardous waste management licence to be issued to the landfill operator.

Storage of hazardous wastes shall also meet this standard.

6. Council Directive concerning urban

waste water treatment

91/27/EEC (amended by 98/15/EC);

The objective of the Directive is to protect the environment from the adverse effects of discharges of urban wastewater and of wastewater from the agro-food industry.

In terms of SWM, EU states must provide general rules or registration or authorisation for the sustainable disposal of sludge arising from wastewater treatment and phase out dumping or discharge of sewage sludge into surface waters.

Treated sewage sludge generated by the assets operations disposed of to landfills.

Complies with EU

Sakhalin Energy complies with the Directive with regard to the urban wastewater discharge

7.

Council Directive on the disposal of waste

oils (amended by 87/101/EEC; 91/692/EEC; 2000/76/EC; 2008/98/EC)

These Directives apply to any mineral-based lubrication or industrial oils which have become unfit for the use for which they were originally intended.

EU Member States must ensure that waste oils are collected and disposed of (by processing, destruction, storage or tipping above or underground). They must give priority to the processing of waste oils by regeneration i.e., by refining.

Where this process is not used, other methods may be considered: combustion, destruction, storage or tipping. The Directives stipulate the conditions under which this must occur; in particular, they allow undertakings to collect and/or dispose of waste oils.

Used oils shall be stored in secure containers on assets sites until viable economic quantities are accumulated and then shall be handed over to the licensed contractor for further disposal (processing).

Comply

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Standards Comparison of the Upgraded Non-Hazardous Waste Landfills (and potential future new facilities) against EC Landfill Directive EC 1999/31/EC (updated 2003/33/EC)

Ref Design aspect/issue

EU Directive Requirements

Sakhalin Energy’s approach

Remarks regarding RF Standards Nogliki Landfill Smirnykh Landfill Korsakov Landfill

Article 4

Class of Landfill

Each landfill shall be classified in one of the following classes:

- landfill for hazardous waste;

- landfill for non-hazardous waste;

- landfill for inert waste.

The applicable class is “landfill for non-hazardous waste” regardless of waste origin.

Sakhalin Energy utilises municipal landfills in Korsakov, Nogliki and Smirnykh.

Municipal landfill operation is regulated by RF Sanitary Rules SP 2.1.7.1038-01.

Solid domestic waste disposal sites shall receive the waste from residential properties, public buildings and establishments, enterprises of commerce and catering, street and park garden sweepings, construction debris and some Hazard Classes 3-4 industrial waste as well as other non-hazardous wastes.

Comply with RF and EU requirements.

Article 5 and Annex

2

Waste excluded from Landfill

Promotes the reduction of biological waste deposited in landfills and specifically excludes non-sterilised infectious waste, whole tyres, liquid waste, any waste categorised as hazardous due to properties and environmental contaminant risks as judged by the competent jurisdiction pending

All wastes anticipated to be explicitly excluded in the EU are similarly excluded by Sakhalin Energy. In addition, while not excluding or progressively restricting biodegradable waste, its source waste diversion practices are intended to minimise it

In general, RF regulations permit a broader range of wastes to be deposited in municipal landfills, although they have equivalent exclusions for what would be anticipated to be considered hazardous wastes in the EU.

Russian regulations also require any waste for which a recycling or

Complies with RF and EU.

According to the RF legislation medical waste shall be sterilized, secured in a container (encapsulated) and buried in a secure area (i.e. buried at a dedicated site) at the landfill. As a minimum this shall include the use of proprietary containers of medical establishments. Items with sharp edge shall be flooded by flooring cement (or a commercial product such as Isolyser) which when fully reacted, shall encase the waste in a solid protective matrix. The encapsulating agent shall completely fill the container. The container and solidified contents must withstand an applied pressure of 40 psi without disintegration.

These practices are consistent with guidance documents published by the World Health Organisation (WHO 1999) and World Bank

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Standards Comparison of the Upgraded Non-Hazardous Waste Landfills (and potential future new facilities) against EC Landfill Directive EC 1999/31/EC (updated 2003/33/EC)

Ref Design aspect/issue

EU Directive Requirements

Sakhalin Energy’s approach

Remarks regarding RF Standards Nogliki Landfill Smirnykh Landfill Korsakov Landfill

adoption of a unified waste classification system in the EU.

resource recovery option is available to be so diverted.

(WB 1999 and 2000).

Article 6 and Annex

2

Wastes Accepte

d at Landfills as Non- Hazardo

us

Requires pre-treatment of all land filled waste except where it is inert or in the absence of pre-treatment shall not compromise an overall object of prevention or reduction in environmental impact to air, surface and ground water or the global environment.

Excludes access of hazardous waste and allows access to municipal waste, inert waste and other non-hazardous waste without properties with hazardous properties and contaminant risk.

Sakhalin Energy wastes directed to the upgraded landfills shall be limited to Class 5 and selected Class 4 wastes as permitted under RF regulations. These wastes would generally be allowable in the EU at non-hazardous waste landfills

As above except Russian regulations allow case-specific exceptions for Class 3 wastes, some of which might be excluded under EU regulations.

Exception is medical waste, as above.

Article 7

Permitting

Requires a formal application for a permit that includes identity of applicant/s, operators, capacities, waste quantities, site

Sakhalin Energy is only utilising landfills permitted under the RF system. The upgrade activities themselves shall be subject to an approval

The Russian development permitting and state expertise process involves equivalent although not exactly the same requirements as the EU

Complies with RF and EU (except financial security provisions) requirements.

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Standards Comparison of the Upgraded Non-Hazardous Waste Landfills (and potential future new facilities) against EC Landfill Directive EC 1999/31/EC (updated 2003/33/EC)

Ref Design aspect/issue

EU Directive Requirements

Sakhalin Energy’s approach

Remarks regarding RF Standards Nogliki Landfill Smirnykh Landfill Korsakov Landfill

description (including geological and hydrogeological setting), pollution control measures, operational plan (e.g. operation, monitoring, control and closure), EIA and financial security provisions.

process involving presentation of information to authorities in an application that is generally equivalent to that required in the EU. The exception is that mechanisms for financial security provisions contemplated by the EU

standard are not considered applicable or feasible in Russia at this time. The relevant plans are covered by the Landfill Code of Conduct included as a requirement under Sakhalin Energy’s agreement with landfill operators as part of the operating support provided.

standards. One specific exception is the provision for financial security provisions that are not considered feasible for municipal facilities.

Article 11

Waste Accepta

nce Procedu

res

Requires a formal procedure related to documentation of waste deliveries and its verification

Sakhalin Energy’s waste tracking and documentation system in combination with the Landfill Code cover this requirement. Waste tracking from the source and any intermediate handling to the final

RF requirements (MPR Order #721 that came into force on November, 2011) requires landfill operators, waste producer/collectors to maintain the comprehensive system for waste identification, inspection and registering.

Comply with EU and RF requirements.

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Standards Comparison of the Upgraded Non-Hazardous Waste Landfills (and potential future new facilities) against EC Landfill Directive EC 1999/31/EC (updated 2003/33/EC)

Ref Design aspect/issue

EU Directive Requirements

Sakhalin Energy’s approach

Remarks regarding RF Standards Nogliki Landfill Smirnykh Landfill Korsakov Landfill

disposal.

Article 12

Operational

Control and

Monitoring

Procedures

The Landfill Owner shall undertake a monitoring programme in accordance with Annex III, report environmental impacts, provide annual reports on monitoring results and ensure that analysis is undertaken by qualified facilities.

The Landfills Owners (Operators) develop the Monitoring Programme and perform monitoring (that includes underground and surface waters monitoring) under a direct contract with a Certified laboratory. Sampling and analysis is made by Certified laboratory.

RF regulations require that monitoring to include sampling and analysis in a certified laboratory. The number of parameters and schedule of sampling shall be substantiated in the Monitoring design developed for each landfill. Mandatory requirements for monitoring are established only with respect to the periodicity of air sampling which shall be done on a quarterly basis.

The Environmental Monitoring programme is the responsibility of the Landfill Owner/Operator once the upgrade is commissioned.

The following is monitored:

Groundwater

Surface water

Air

Topographical survey after each cell closure.

Article 13

Closure and After Care

Procedures

Requires the closure of a landfill or part thereof, ongoing monitoring and reporting of results

Where upgraded landfills are operated post Sakhalin Energy funding, closure of landfill cells and monitoring shall be the District Administration’s responsibility.

Russian regulations nominally required equivalent closure and after care procedures as applied to the operator and/or permitted party.

Technical remediation shall be completed by landfills owners (Sakhalin Region Administration and municipalities)

Annex I General Requirements for All Classes of Landfills (As Applied to Non-hazardous Waste Landfills)

Annex I.1

Location Requires consideration of the following factors in

The Sakhalin Energy landfill screening and selection process applied

Russian regulations nominally apply equivalent considerations in selection

The Landfills are on an existing site complying fully with RF legislation and the considerations under EU Directives.

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Standards Comparison of the Upgraded Non-Hazardous Waste Landfills (and potential future new facilities) against EC Landfill Directive EC 1999/31/EC (updated 2003/33/EC)

Ref Design aspect/issue

EU Directive Requirements

Sakhalin Energy’s approach

Remarks regarding RF Standards Nogliki Landfill Smirnykh Landfill Korsakov Landfill

landfill siting:

Surrounding land use including residential, recreational and agriculture

Potential receptors (groundwater, waterways, water bodies, coastal waters).

Geological and hydrogeological conditions.

Flooding and land instability risk.

Nature and cultural protection.

to the upgraded landfills included equivalent site screening selection criteria.

of landfill sites.

Annex I.2

Water Control

and Leachat

e manage

ment

Requires provision in design for:

1. Control of precipitation entering the landfill.

2. Prevent surface and groundwater entering the landfill

3. Contaminated water and leachate collection

4. Contaminated water

Sakhalin Energy’s landfill upgrade design includes the corresponding features:

1. Surface run-off is diverted away from the upgraded cells by appropriate grading.

2. The bottom barriers are intended to prevent groundwater from entering the

Russian regulations have similar general requirements in this area, aimed to protect the surface and ground waters.

Complies with RF and EU.

The waste body is covered with impervious screen to prevent effluents from migration to surface and underground waters. 2 closed drainage ditches filled with gravel are made to

Complies with RF and EU.

2 closed drainage ditches filled with gravel are made to accept effluents which are then discharged into the pond with waterproof walls and bottom.

The waste body is

Complies with RF and EU.

The impervious screen is made in the base layer of the landfill. A flood wall is made to prevent effluents from spreading. Effluent collection system is used to discharge it into insulated

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Standards Comparison of the Upgraded Non-Hazardous Waste Landfills (and potential future new facilities) against EC Landfill Directive EC 1999/31/EC (updated 2003/33/EC)

Ref Design aspect/issue

EU Directive Requirements

Sakhalin Energy’s approach

Remarks regarding RF Standards Nogliki Landfill Smirnykh Landfill Korsakov Landfill

and leachate treatment as required

landfill. Surface water is diverted as above.

3. Leachate collection at upgraded cells is provided for.

4. Leachate treatment is not considered necessary and not provided for. Disposal shall be return to the cell or if leachate system full treated at the Municipal sewage treatment works.

accept effluents which are then discharged into the pond with waterproof walls and bottom.

A leak monitoring system between two HDPE liners is provided. Recycling leachate assists in dust control: upon reaching of 40 centimetre of the fluid column the effluents are pumped out and spread over the waste for better compatibility.

A circular flood wall is constructed to make the waste body stable. Surface waters are discharged through the interception ditch.

Forest protective belt is made to separate administrative facilities from wastes.

covered with impervious screen to prevent effluents from migration to surface and underground waters.

A leak monitoring system between two HDPE liners is provided. Recycling leachate assists in dust control: upon reaching of 40 centimetre of the fluid column the effluents are pumped out and spread over the waste for better compatibility. . A circular flood wall is constructed to make the waste body stable. Surface waters are discharged through the interception ditch.

Forest protective belt is made to

containers located beyond the waste dump. Pumping of effluents is regularly performed from the containers. The drainage network is made from drains which are above ‘the waterproofed screen filled with sandy gravel according to the method of a reverse filter. Leachate effluents inflow into containment ponds through the drains. Recycling leachate assists in dust control: upon reaching of 40 centimetre of the fluid column the effluents are pumped out and spread over the waste for better compatibility. . Containment pond is 2 sections catch pit with a filter

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Standards Comparison of the Upgraded Non-Hazardous Waste Landfills (and potential future new facilities) against EC Landfill Directive EC 1999/31/EC (updated 2003/33/EC)

Ref Design aspect/issue

EU Directive Requirements

Sakhalin Energy’s approach

Remarks regarding RF Standards Nogliki Landfill Smirnykh Landfill Korsakov Landfill

separate administrative facilities from wastes.

membrane. Interception ditches are made to catch rain waters.

Annex I.3

Protection of Soil and Water

Requires protection of soil and ground water by natural geological conditions or mineral engineered barriers at the bottom, sides and surface (upon closure).

The permeability (K) and bottom barrier thickness (T) requirements are:

K< 10-9

m/sec

T> 1.0 m (natural) or

T> 0.5 m (artificial)

A Leachate collection and sealing layer involving an additional artificial sealing barrier and drainage layer > 0.5 m thickness.

At the discretion of the competent authority, surface sealing to prevent leachate formation may be required. This shall

Sakhalin Energy is providing for side and bottom barriers in its upgraded landfill cells taking into account the following:

1. The permeability requirement shall be K< 10

-9 m/sec;

2. Compacted and as necessary soil enhanced artificial bottom barrier of T >0.5m;

3. HDPE synthetic geomembrane liner 1.5 mm thick.

Leachate drainage layer of 300mm thickness.

4. A 200mm protective layer of natural soil placed on the leachate drainage layer.

Russian Technical Standards have the same requirements: both natural (geological) layer and an artificial watertight membrane can be used for the soil and groundwater protection.

The bottom permeability requirement are the same as International ones (subject to appropriate correspondence between International and Russian classification of waste):

No extra watertight membrane at the bottom is required for IV-class landfills if the natural soil permeability is less than

K≤ см/s (=1,0x10− 7 m/s)

If the natural soil does not meet the above requirements, then a liner

Nogliki upgraded landfill protective barrier with liner has been constructed as follows:

(a) bottom layer of 1.0m compacted natural soil

(b) b) artificial bottom barrier of 700mm clay to ensure compliance to K<1x10

-9

m/sec;

(c) mineral 0.3m underlayer;

(d) 0.3m sand drainage layer with 0.6m sealing barrier and effluent leak detection system;

(e) 0.3m

Smirnykh upgraded Landfill protective barrier with liner has been constructed as follows:

a) bottom layer of 1.0m compacted natural soil with artificial bottom barrier of 0.6m clay to ensure compliance to K<1x10

-9

m/sec;

b) mineral 0.3m underlayer;

c) sand drainage layer with additional protective barrier of 0.6m soil and effluent

Korsakov upgraded Landfill protective barrier with liner has been constructed as follows:

a) bottom layer of 1.0m compacted natural soil with artificial bottom barrier of 0.6m clay to ensure compliance to K<1x10

-9

m/sec;

b) mineral 0.3m underlayer;

c) sand drainage layer with 0.7m sealing barrier and effluent leak detection system;

d) 0.2m protective layer of

− 510

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Standards Comparison of the Upgraded Non-Hazardous Waste Landfills (and potential future new facilities) against EC Landfill Directive EC 1999/31/EC (updated 2003/33/EC)

Ref Design aspect/issue

EU Directive Requirements

Sakhalin Energy’s approach

Remarks regarding RF Standards Nogliki Landfill Smirnykh Landfill Korsakov Landfill

involve a gas drainage layer, impermeable mineral layer, drainage layer (>0.5 m) and top cover (>1.0 m).

The above requirements may be reduced based on a risk assessment.

5. Landfill Upgrade Risk Assessment Report incorporating some information regarding conceptual model, environmental setting, installation design review and hydrogeological risk assessment. The Report takes into consideration best practices regarding protection of the soil and water at landfills and was prepared taking into account the provisions of IPPC Directive (Directive 96/61/EC) and Landfill Directives (99/31/EC).

of compacted clay with K≤

см/s (=1,0x10− 9 m/s)

and T≥ 0,5 м has to be put.

If no clay satisfying the aforementioned permeability is available, then other types of watertight liners can be used, providing that its material is durable and specific waste content proof.

Drainage and leachate managing ponds shall be installed at the Landfill operation zone.

Evaporation ponds, drainage managing ponds and drainage canals shall have watertight liners corresponding to the leachate hazard class.

recultivating (protective) layer of drainage soil;

(f) 0.2m of natural soil protective layer;

Double layer impervious screen is made of 1.5mm HDPE geomembrane and protective geotextile laying. HDPE liner integrity resistivity testing was completed in 2005.

Risks Re-Assessment has been made on the basis of data received in the course of landfill monitoring plan implementation.

Every landfill operator has Landfill Monitoring Plan. System of monitoring includes wells and test pits to control surface and ground

collection system;

d) 0.3m protective layer of local drainage soil;

e) 0.2m of natural soil protective layer.

Double layer impervious screen is made of 1.5mm HDPE geomembrane and protective geotextile laying. HDPE liner integrity resistivity testing was completed in 2005.

Risks Re-Assessment has been made on the basis of data received in the course of landfill monitoring plan implementation.

Every landfill operator has

drainage soil;

e) 0.2 m of natural soil protective layer.

Double layer impervious screen is made of 1.5mm HDPE geomembrane and protective geotextile laying. HDPE liner integrity resistivity testing was completed in 2005.

Risks Re-Assessment has been made on the basis of data received in the course of landfill monitoring plan implementation.

Every landfill operator has Landfill Monitoring Plan. System of monitoring includes wells and test pits to control surface and ground water, control of atmospheric air and

− 710

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Standards Comparison of the Upgraded Non-Hazardous Waste Landfills (and potential future new facilities) against EC Landfill Directive EC 1999/31/EC (updated 2003/33/EC)

Ref Design aspect/issue

EU Directive Requirements

Sakhalin Energy’s approach

Remarks regarding RF Standards Nogliki Landfill Smirnykh Landfill Korsakov Landfill

water, control of atmospheric air and soils, noise and radiation control in the area of landfill impact, control of the isolation layer and waste compaction, control of the toxicity of the leachate and the sanitary condition of the adjacent territories. The results of the analyses show that there is no exceedance of the established MPC

Landfill Monitoring Plan. System of monitoring includes wells and test pits to control surface and ground water, control of atmospheric air and soils, noise and radiation control in the area of landfill impact, control of the isolation layer and waste compaction, control of the toxicity of the leachate and the sanitary condition of the adjacent territories. The results of the analyses show that there is no exceedance of the established MPC

soils, noise and radiation control in the area of landfill impact, control of the isolation layer and waste compaction, control of the toxicity of the leachate and the sanitary condition of the adjacent territories. The results of the analyses show that there is no exceedance of the established MPC

Annex I.4

Gas Control

Gas control is mandatory where biodegradable waste is deposited, and must be flared in the

Sakhalin Energy’s upgrade design is not providing for any gas control measures but

Russian regulations do not require gas control measures.

Comply with RF legislation.

A passive ventilation system is installed

Comply with RF legislation.

A passive ventilation system

Comply with RF legislation. As per The degassing system includes

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Standards Comparison of the Upgraded Non-Hazardous Waste Landfills (and potential future new facilities) against EC Landfill Directive EC 1999/31/EC (updated 2003/33/EC)

Ref Design aspect/issue

EU Directive Requirements

Sakhalin Energy’s approach

Remarks regarding RF Standards Nogliki Landfill Smirnykh Landfill Korsakov Landfill

absence of capture for fuel use.

Gas monitoring (CH4, CO2,

O2, H2S, H2 etc.) must be representative for each section of the landfill. The gas sampling is to be taken on a monthly basis during Operation Period.

passive venting is included.

for gas removal. is installed for gas removal.

drainage layers of soil and ventilation pipes Ø0.53 cm.

Annex I.5

Nuisance and Hazards

Requires control measures related to odours, dust, windblown material, birds/vermin/insects, fires, as well as prevention of soil transfer off site

Sakhalin Energy’s upgrade programme provides for clean up and containment of litter from past operations and regular cover (i.e. daily) as a means of controlling odour and other problems.

Russian regulations do not provide specific enforceable provision in this area.

Sites are fenced to 2.2m.

Burning of waste is prohibited on the upgraded landfills.

Recycling leachate assists in dust control: upon reaching of 40 centimetre of the fluid column the effluents are pumped out and spread over the waste for better compatibility.

Annex I.6

Stability Requires that stability of the mass of deposited waste be maintained should the barriers protecting water and soil as well as capturing leachate are damaged or breached

The emplacement of waste on the site shall take place in such a way

The construction, siting and design of the upgraded landfills along with the nature of waste deposited are anticipated to provide for stability of the waste mass in the event that the dykes are damaged or breached.

Russian regulations do not provide specific enforceable provision in this area.

Complies with EU

Building of protective bunding from the edge of the outer slope, 0.1 m deep topsoil removal, building of water intercepting ditches, building of drainage systems at the bottom for collecting and removing filtrated surface

Complies with EU

Topsoil removal (0.1 m) from the entire landfill area, building of protective bunding, installing of two-layer geotextile slope protection interbedded with a water-proof polymer

Complies with EU Strengthening of the existing ravines has been completed: weak soil removed, internal slopes flattened and covered with rock. Where the road adjoins level 2 of the household solid waste, landfill slopes have been flattened,

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Standards Comparison of the Upgraded Non-Hazardous Waste Landfills (and potential future new facilities) against EC Landfill Directive EC 1999/31/EC (updated 2003/33/EC)

Ref Design aspect/issue

EU Directive Requirements

Sakhalin Energy’s approach

Remarks regarding RF Standards Nogliki Landfill Smirnykh Landfill Korsakov Landfill

as to ensure stability of the mass of waste and associated structures, particularly in respect of avoidance of slippages. Where an artificial barrier is established it must be ascertained that the geological substratum, considering the morphology of the landfill, is sufficiently stable to prevent settlement that may cause damage to the barrier.

water. membrane. including cutting of the landslide-prone soil.

Annex I.7

Barriers Requires a fenced and gated site that has access control to prevent illegal dumping.

The Sakhalin Energy upgrade programme provides for the sites to be fenced and gated with access controlled by the operator.

Russian regulations nominally contain generally equivalent requirements although their enforcement is limited.

Complies with RF and EU requirements

All the landfills are fenced to 2.2m and gated. The landfill operator provides security to prevent illegal access or illegal dumping of waste.

The Administrative area is separately fenced off.

Annex II Waste Acceptance Criteria and Procedures

Annex II.2

General Principles

In the absence of a unified EU waste classification system, the

Sakhalin Energy is directing the waste of Class 4 and 5 which is not

In advance of EU requirements, Russian regulations apply a hazard

Complies with RF and EU

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Standards Comparison of the Upgraded Non-Hazardous Waste Landfills (and potential future new facilities) against EC Landfill Directive EC 1999/31/EC (updated 2003/33/EC)

Ref Design aspect/issue

EU Directive Requirements

Sakhalin Energy’s approach

Remarks regarding RF Standards Nogliki Landfill Smirnykh Landfill Korsakov Landfill

requirements are that each jurisdiction has such a system and that this dictates the direction of waste to various types of landfills based on properties and environmental risk posed. Furthermore it contemplates that such restrictions be applied on a landfill specific basis.

diverted to re-use to disposal on upgraded landfills.

class system and catalogue each waste type by class and individual coding. Municipal landfills can accept all Class 5 (practically non-hazardous waste) and Classes 3 and 4 waste under a site and waste specific exception justified by evaluation of the impacts on the specific location involved. While the specific requirements and methodologies may differ the general principle is consistent with what the EU is targeting to achieve.

Annex II.3

General Procedures for Testing and Acceptance of Waste

Requires a tiered system of waste assessment covering basic characterisation, periodic compliance validation and inspection upon delivery. In fact at this time only on site verification is currently mandatory (Annex II.4) and sapling procedures are yet to be promulgated (Annex II.5).

Sakhalin Energy’s requirements respecting source based segregation and collection, waste tracking and documentation, and manifest verification on delivery to the landfill provide the basic check on acceptance. Classification is in accordance with Russian regulations.

RF regulations apply analogous requirements with respect to waste characterisation through the unified classification system and catalogue system as well as the establishment of waste limits by waste generators and annual reporting requirements. The main differences lie in the term over which the basic characterisation can apply

Complies with RF and EU

Sakhalin Energy performs periodic (scheduled) audits of the Landfill Operator to check compliance.

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Standards Comparison of the Upgraded Non-Hazardous Waste Landfills (and potential future new facilities) against EC Landfill Directive EC 1999/31/EC (updated 2003/33/EC)

Ref Design aspect/issue

EU Directive Requirements

Sakhalin Energy’s approach

Remarks regarding RF Standards Nogliki Landfill Smirnykh Landfill Korsakov Landfill

(up to five years) and requirements for mandatory validation. In practice the Russian requirements exceed EU standards

Annex III Control and Monitoring Procedures in Operations and Aftercare Phases

Annex III.2

Meteorological Data

Requires daily (operations) and periodic (post closure) meteorological data to be collected covering precipitation, wind, humidity and evaporation.

Sakhalin Energy has not made any provisions for collection of this data on a site-specific basis.

No meteorological data collection requirements are applied under Russian regulations.

Every Municipal area under RF legislation collects meteorological data from the RosHydroMet website according to the RF legislation.

Annex III. 3

Emission Data: Water,

Leachate and Gas

Control

Requires emission sampling and analysis on a monthly or quarterly basis during operation for surface water and leachate (volume and composition), and potential gas emissions (CH4, CO2, O2, H2S, H2)

Sakhalin Energy’s upgrade programme provides for regular sampling of sampling and analysis of surface water and leachate. The frequency is dictated by the capacity of the operator and local authorities having jurisdiction.

According to the RF legislation the Scope of work of environmental monitoring is defined by SanPin 2.1.7.1038-01 (Sanitary Norms and Rules).

None of the upgraded landfills initially (prior the landfills upgrade work) had monitoring provisions.

Every 2 years Operators of the landfills review Monitoring program and approve it by RTN and RPN which in their turn check the normative against RF requirements. After obtaining approval landfill Operators conclude contracts with the certified laboratory for sampling and analysis.

Annex Protecti Groundwater flow The Sakhalin Energy As above Comply with RF and partially with ECC standard.

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Standards Comparison of the Upgraded Non-Hazardous Waste Landfills (and potential future new facilities) against EC Landfill Directive EC 1999/31/EC (updated 2003/33/EC)

Ref Design aspect/issue

EU Directive Requirements

Sakhalin Energy’s approach

Remarks regarding RF Standards Nogliki Landfill Smirnykh Landfill Korsakov Landfill

III.4 on of Groundwater

requires sampling at a minimum of three points (one upstream and two downstream); at least three samples taken prior to opening of the cell to establish baseline.

Level of groundwater is recorded every six months.

landfill modernization program provides the groundwater monitoring with the number of points meeting or exceeding those established in the EU standard. The frequency is dictated by the capacity of the operator and local authorities having jurisdiction.

The environmental monitoring programme has been approved by Rostekhnadzor.

Samples taken from control wells installed in the up of the landfill along the groundwater flow characterize their background condition. 50-150 m down from the landfill along the flow of the ground water control wells are installed to identify the potential impact of the landfill on the groundwater. The content of ammonia, nitrites, nitrates, chlorides, cadmium, lead, mercury, arsenic, cyanides and others are identified. No exceedance of concentrations has been revealed so far. This testifies the impermeability of the landfill body

Annex III.5

Topography of

the Site: Data on

the Landfill Body

Requires evaluation of structure/composition of the landfill body and degree of settling on an annual basis during operation.

Sakhalin Energy incorporates inspection of landfill topography into its environmental monitoring plans

As above Not implemented due to replacement of the landfill operator.

Comply Topography is made.

All contractors are currently using landfills complying with the RF requirements and standards (licences) for Class 4-5 waste disposal.