Select Committee on Environment, Food and Rural Affairs Appendices to the Minutes of Evidence


Memorandum submitted by SITA Holdings UK Limited (E5)


Background to SITA

  SITA is Europe's leading waste service operator and the third largest in the world. The Group's activities span the waste management chain, including collection, sorting, recovery, treatment and ultimate disposal of hazardous, domestic, commercial and industrial wastes.

  SITA has provided waste management services in the UK since 1989. The Company has grown to become the country's largest service provider, operating more than 100 municipal service contracts, 103 landfill sites, several recycling and recovery facilities along with energy from waste facilities at Edmonton in North London, Cleveland on Teesside and at Kirklees.

  Landfilling within the context of the Government's emerging waste management strategy and the Landfill Directive (LFD) is therefore a significant and critical component of SITA's portfolio of waste management services in the UK. SITA landfills approximately 6.5 million tonnes of waste per year in the UK in 60 operational landfill sites, of which approximately 300,000 tonnes comprises special waste, difficult waste, or wastes that will be banned from landfills from 16 July 2002. While this tonnage appears small relative to the total, the revenue generated from these waste streams is significant.

Scope of this Memorandum

  SITA is currently assessing the likely impact of the Landfill Directive (LFD) on its hazardous waste market in the UK, drawing on our operational experience in alternative treatment options in Europe and elsewhere. For example, SITA operates ten stabilisation/solidification plants internationally, treating 400,000 tonnes of hazardous waste per year. The largest facility in Europe is located at the landfill site in Villeparisis, France, with a capacity of 100,000 tonnes per year. SITA also operates bioremediation and soil washing/stripping facilities, in addition to hazardous waste incinerators, co-incineration and solvent recovery plants.

  This memorandum presents our views on four issues connected with the implementation of the LFD in the UK:

    —  the requirements for alternative treatment options, with respect to both type of option and national capacity;

    —  analytical issues concerning tests for the measurement of waste acceptance criteria;

    —  the application of the waste acceptance criteria to a range of waste types, and the landfilling decisions that result thereof;

    —  the timing of a ban on the co-disposal of hazardous and non-hazardous waste.

  We have sourced waste arisings and capacity data from available Environment Agency statistics, and particularly from the report published by the DETR in 2000 entitled Implications of the Landfill Directive on the Disposal of Hazardous and Liquid Waste in the UK, commissioned from the Babtie Group. We understand this report is currently being updated. We have supplemented the published information with a preliminary in-house analysis of current practices in hazardous waste management in the UK, and have made additional assumptions to allow for gaps in the available data.

  We are constrained by the same data gaps and uncertainties experienced by the rest of the waste management industry and indeed by Government, and therefore cannot claim any greater accuracy for our estimates. Our intention was to paint a broad canvas at this stage.

Treatment Options—Types and Capacities

  SITA has assessed the likely movement of hazardous wastes from landfilling to other forms of treatment. Environment Agency statistics suggest annual waste arisings of 4.9 million tonnes, but this includes "grey" waste categories such as construction and demolition waste (1.1 million tonnes per year). The Babtie study assesses annual hazardous waste arisings at 4.6 million tonnes but this includes 300,000 tonnes of non-hazardous liquids. We have therefore based our analysis on an annual arising of 4.3 million tonnes of which 2.1 million tonnes are landfilled (Figure 1). Translating the generic waste description of significant special waste solid and sludges currently being deposited in landfills into their nearest European Waste Catalogue (EWC) equivalent, we developed a matrix of alternative treatment options as shown in Table 1. Finally, taking into account the potential for routing a proportion of the banned liquids to wastewater treatment works, we arrived at estimates for alternative treatment requirements listed in Table 2. Coupled with tonnages currently treated in the UK, column 5 in Table 2 lists our estimate of the total tonnage of wastes that will require treatment from July 2004. Our estimates of current treatment capacity are listed in column 6 of Table 2.

  Tables 1 and 2 point up several potential features of a post-2004 hazardous waste management regime:

    —  High temperature incineration capacity is currently at or near saturation. Our preliminary analysis suggests that additional capacity of some 170,000 tonnes might be required post-2004.

    —  Co-incineration in kilns and boilers appears to offer a disposal route for a significant proportion (170,000 tonnes) of the re-routed waste. This option has thus far not been incorporated explicitly into a hazardous waste strategy for the UK, despite the potential that it offers as a safe alternative under appropriately controlled conditions.

    —  Our analysis suggests that solvent recovery will not be impacted appreciably by the diversion of hazardous wastes from landfills.

    —  Physicochemical treatment is appropriate for an additional 230,000 tonnes of hazardous waste post-2004. With an estimated installed capacity of 1,500,000 tonnes only 50-60 per cent utilised, we believe that the excess installed capacity will be sufficient to meet post-2004 demands, albeit with the possibility of process changes to enable the product to meet the relevant waste acceptance criteria (see below).

    —  Stabilisation/solidification could be appropriate for 800,000 tonnes of hazardous waste, and additionally has the potential to treat a further 525,000 tonnes of contaminated soil depending on the type and degree of contamination present. Where this treatment is practised in continental Europe, the product is landfilled.

  While these figures would seemingly indicate a reasonable basis on which to make future investment decisions, Table 1 highlights some of the uncertainties that SITA and the rest of the waste industry are currently facing, for example:

    —  Some waste streams are amenable to treatment by more than one alternative route. For example, the contaminated soil component of construction and demolition waste can be incinerated, directly landfilled, bioremediated or subjected to thermal desorption depending on the nature and degree of contamination and on the economic viability of the redevelopment. If market conditions were such that stabilisation was not a viable option, then potentially 60 per cent of a national installed stabilisation capacity of 1,400,000 tonnes would not be utilised. Stated differently, 525,000 tonnes of treatment capacity distributed across a range of alternative treatment options would represent, for options where this makes up the dominant waste stream, a highly unstable and unpredictable market.

    —  These overlaps also result in double counting of required treatment capacity, particularly between stabilisation/solidification and physicochemical treatment, and between high temperature incineration in dedicated facilities and co-incineration in industrial kilns.

    —  In addition, changes to the Hazardous Waste List will most likely increase both the volumes and types of waste that will be classified as hazardous. It is not known at this stage what quantitative effect of these changes might have on current waste tonnages, especially in the light of the large number of mirror codes in the EWC.

  Crucially, waste producers have not been market tested for price sensitivity. If the incremental cost of treatment is significant, generators are likely to alter their processes or as a minimum adopt more effective waste management practices (for example, segregating their waste streams or pretreating in order to declassify the non-hazardous component) and thus reduce the quantities coming forward for treatment in merchant facilities. While SITA will certainly not discourage such moves, the lack of information on industry's perspective on the LFD does nevertheless add a significant degree of uncertainty to merchant waste management investment plans.

  Finally, it should be noted that diversion of specific hazardous waste streams such as batteries will require the development of alternative collection and segregation facilities which are linked to municipal waste contracts rather than to hazardous waste management contracts.



  Central to the implementation of the LFD is the development of waste acceptance criteria (WAC) which determine the waste quality required for deposition of relevant waste streams in inert, non-hazardous or hazardous waste landfills. The Technical Adaptation Committee (TAC) of the European Commission published a Working Document on WAC on 21 March 2002. The numeric WAC are based on the analysis of eluate from leach tests conducted on the waste, at liquid to solid (L/S) ratios of 2 and 10.

  As a first step in developing in-house WAC analytical procedures, SITA has assessed whether the standardised analytical determination methods noted in the Working Document (ENV 12506 and ENV 13370) and their embedded procedures are appropriate for the determination of parameter concentrations in the eluate to the levels stipulated in the WAC lists.

Results and Discussion

  Columns 2-5 of Table 34 summarise the WAC eluate thresholds for hazardous waste deposited into non-hazardous and hazardous waste landfill sites, in relation to the analytical parameters listed in column 1. The detection limit (DL) and/or quantification limit (QL) for each standard procedure in ENV 12506 and ENV 13370 are listed in columns 5 and 6 of the table. The quantification limit (QL) generally corresponds to the detection limit (DL) multiplied by a factor of 3 to 5. Correctly determining concentrations for a given parameter requires that the QL is at least 20 per cent-30 per cent below the desired value. In the remaining columns of the table we have listed various analytical techniques and their ability to meet the lowest thresholds required by the WAC. The terms are explained in the key attached to the table. For the analysis of metals, most modern waste management laboratories would be equipped with an atomic absorption spectrometer (AAS) or an inductively coupled plasma (ICP), the latter with the capability of rapid simultaneous analysis of a range of metals concentrations in the test eluate.

  Table 3[4] can be interpreted as follows:

    —  Metals: We do not envisage difficulty in determining analytical WAC for arsenic (As), barium (Ba), total chromium (Cr), copper (Cu), molybdenum (Mo), nickel (Ni), lead (Pb) and zinc (Zn) concentrations in the test eluate using standard methods with AAS and/or ICP equipment.

    —  Mercury: The ICP-AES method cannot be used to determine mercury concentrations at the proposed thresholds for acceptance at non-hazardous waste landfills (ie 0.002-0.02 mg/l). Mercury concentrations may be determined using the AAS hydride technique, ie the method specified in eluate analysis standards (which specify a quantification limit of 0.0001 mg/l).

    —  Cadmium: Depending on the thresholds selected for acceptance of cadmium (Cd) at non-hazardous waste landfills (the two thresholds currently proposed differ by a factor of 10), some methods specified in the two eluate analysis standards (for example ICP and direct AAS) may not be suitable for determining the WAC concentration levels. It should be noted that organic matter and some metals interfere with the latter method (eg. iron at concentrations above 1 mg/l).

    —  Antimony (Sb) and Selenium (Se): The two eluate analysis standards do not take account of Sb and Se. ICP-AES is used as the standard method to determine concentrations of these two parameters in water.

    —  Salts: Relative to the methods listed in the two eluate analysis standards (see Table 3[5]), there are no particular problems in analysing proposed thresholds for chlorides, fluorides and sulphates. Chloride concentrations may be determined using volumetric titration with silver nitrate (subject to interference when bromides or iodides are present) and using ion chromatography. Fluoride concentrations may be determined using ion chromatography and kits, but are subject to interference problems. Fluoride concentrations may also be determined using specific electrode potentiometric analysis. Sulphate concentrations may be determined by ion chromatography, which is rapid but subject to interference when samples are discoloured or turbid, or by the gravimetric method, which is less subject to interference but takes up to 24 hours to obtain results.

    —  Organic parameters (TOC in liquids, TOC in solids and Loss on Ignition, LOI): For the proposed thresholds, there are no particular problems in analysing Total Organic Carbon (TOC) in liquids, TOC in solids and LOI. The 5 per cent threshold for TOC in solids and sludges will have a marked impact on the acceptance of these waste types at both non-hazardous and hazardous waste landfills.

  The WAC parameter Dissolved Organic Carbon (DOC) corresponds to the TOC in eluates. The analytical method proposed for TOC analysis in the TAC is not a standard method and has yet to be discussed at a European level. Although the proposed method may be justified for organic matter found in the soil, it is not justified for industrial organic matter, nor specifically in the case of stabilised waste with neutral pH, requiring the addition of very significant acidity, which does not correspond to any realistic environmental scenario given the high buffering capacity of stabilised waste. The proposed WAC thresholds for the pH-neutral TOC parameter should therefore be removed.


  Concerning acceptance of waste at hazardous waste landfills, WAC thresholds can be assessed with ICP-AES. Quantification limits obtained with AAS are close to the proposed thresholds and may require refinement using a hydride technique, which is much more difficult and constraining to implement than the direct method.

  For acceptance of waste at non-hazardous waste landfills, the AAS method cannot be directly applied to determine WAC thresholds, and the ICP-AES method can be used to determine concentrations only up to the threshold limit, depending on the performance of each apparatus and the sample matrix.

  Significant additional analysis costs could be generated by the addition of new parameters not normally analysed on a regular basis (antimony, barium, molybdenum, selenium, chlorides, fluorides, sulphates) for hazardous waste acceptance and especially by the appearance of parameters for non-hazardous waste acceptance, with some very low corresponding thresholds (eg mercury, antimony, selenium).

  Finally, we note the absence of numeric WAC thresholds for solidified, monolithic treated products, a significant information gap given that stabilisation/solidification appears capable of treating a wide range of diverted hazardous wastes streams. We understand the TAC is currently considering this issue, as well as the relevance of physical WAC such as compressive strength for stabilised waste.

The Influence of the WAC on Treatment Options

  In order to gauge the effect of the numeric WAC on waste disposal practices, we analysed twenty waste types which were amenable to stabilisation/solidification as a tertiary treatment option. We then compared the test eluates against the WAC thresholds for acceptance into a non-hazardous waste landfill (albeit in a separate cell) and in a hazardous waste landfill. Eluates from both treated and untreated wastes were tested for a range of WAC parameters for which analytical facilities were already available at SITA laboratories. Thus, barium, molybdenum, selenium and antimony were excluded from the test protocol.

  The results are shown in Table 4[6]. The table can be interpreted as follows. Against each of the L/S ratios:

    —  The letter A signifies whether the parameter criterion is passed for deposit of the waste into a non-hazardous waste landfill, without further tertiary treatment.

    —  The letter B signifies that the parameter criterion is passed for deposit of the waste into a hazardous waste landfill, without further tertiary treatment.

    —  The letter C signifies that the parameter criterion is passed for deposit of the waste into a hazardous waste landfill, but only after stabilisation.

  The table indicates that for some waste types (for example, N waste (flyash) and M waste (bottom ash)) the suite of parameters analysed do not produce a consistent outcome, in that some parameters fail the WAC test for disposal into non-hazardous waste landfills, while others pass the test. Furthermore, application of the WAC test with a L/S ratio of 2 can in some cases result in a different outcome to a test conducted with a L/S ratio of 10. For example, A waste (sludge from inorganic chemistry), I waste (sludge from organic chemistry) and Q waste (foundry dust) would be accepted in hazardous waste landfills without stabilisation by applying an L/S ratio of 10, but would require stabilisation if an L/S ratio of 2 was applied in the eluate test. Testing for the remaining metals would not alter this basic picture.

  Thus, it would appear that an eluate test conducted with an L/S ratio of 2 is more restrictive for landfill disposal and/or requires pre-treatment before landfill disposal. Clearly, further work is required to better understand the impact of the WAC thresholds on treatment options and eventual acceptance of the treated waste into landfills.

  There remains the issue of applying waste acceptance criteria representing Final Storage Quality (FSQ) to wastes destined for landfills. FSQ has yet to be developed into a set of numeric criteria, but the concept is one that SITA supports in relation to hazardous waste management, if by meeting the relevant quality criteria an operator is, by implication, released from future liabilities attached to the site. If the aftercare provisions of the LFD cannot be amended (ie. the requirement to monitor and manage closed sites for 30-40 years), then it would appear to SITA that no advantage would be gained in treating hazardous waste to a standard stricter than the current WAC requirements, which will inevitably add further cost to the treatment process.

Timing of the Ban on Co-disposal

  For a number of hazardous waste streams, the LFD will begin to take effect from 16 July 2002, in particular the banning of hazardous liquids from landfills. With spare capacity at existing physicochemical treatment plants, SITA believes the needs for this particular waste stream should be met, especially since the sludges resulting from such treatment can continue to be co-disposed in landfills.

  The key issue is how the ban on co-disposal, currently scheduled to take effect from July 2004, should be managed from a regulatory standpoint. If the UK wishes to adhere to this date, then:

    —  All players need to gain a better understanding of the waste streams affected, the measures to be taken by waste generators on their production sites, incremental treatment costs, and the net effect on waste arisings and associated treatment needs. Also to be assessed is the effect on hazardous waste arisings following changes to the Hazardous Waste List.

    —  Waste acceptance criteria, together with standard protocols for measurement and interpretation, must be in place for all treated waste types, including stabilised monolithic waste forms. In the absence of numeric WAC, landfill operators will not accept liability resulting from the deposit of hazardous waste into either hazardous waste landfills or into separate cells created in non-hazardous waste landfills.

    —  Alternative treatment options must be substantially in place, either in terms of new facilities, or by refurbishment of existing treatment capacity.

  Government must ensure that the regulatory regime and the market conditions it engenders do not disadvantage alternative treatment schemes. SITA believes that the present two-year transition period to July 2004 during which co-disposal will continue to co-exist with alternative treatment, could in itself discourage investment in new plant, given the disparity in disposal costs that additional treatment will impose. We expect landfill prices to fall as landfill operators seek to maximise hazardous waste deposits, especially into sites scheduled to close by July 2004, while waste producers will continue to use the least cost (legal) option of landfilling.

  Any further delay in implementing the ban on co-disposal is likely to exacerbate this tendency, but at the same time SITA recognises the practical and logistical difficulties in gearing up for a July 2004 date. We therefore suggest the following:

    —  July 2004 should still be the preferred date for implementation of the ban on co-disposal, and should be targeted as such in any action plan developed by the Environment Agency and DEFRA.

    —  The ban should be implemented from a single date rather than being phased in geographically or over time, and in conjunction with the relevant waste acceptance criteria.

    —  There may be a need for the UK to seek derogations on one or more of the numeric waste acceptance criteria, perhaps linked to specific waste types and say for a further two years, to allow time for the development of appropriate treatment processes. These might include flyash (and perhaps bottom ash) residue from incineration and other thermal treatment processes with respect to chloride and sulphate levels in the test eluate, and total/dissolved organic carbon (TOC/DOC)) in industrial sludges.

    —  Concurrently, Government must take measures to streamline the planning and permitting process in order to reduce determination times which currently can run to 2-5 years depending on the type of facility.

  We note in passing that monies from the Landfill Tax Credit Scheme have almost exclusively been directed towards enhancement of the management of municipal, commercial and non-hazardous industrial waste in the UK. The challenges faced by waste producers and by the waste management industry with respect to hazardous waste are as daunting, with solutions required in a far shorter timeframe.


  Notwithstanding the challenges in readying for a ban on co-disposal from July 2004, SITA considers a more prolonged continuation of co-disposal alongside more costly alternative treatment options to be counterproductive, and less likely to achieve the objective of providing alternative facilities.

    —  We recommend that Government continues to regard July 2004 as the target date for the implementation of a ban on co-disposal. Work is required both nationally and through the Technical Adaptation Committee to complete the development of waste acceptance criteria, final storage quality and associated test procedures for treated waste (including monolithic products) in order for these to be applied simultaneously with the ban on co-disposal nationally, and on a single date.

  There are large uncertainties in the data and information pertaining to the arisings and management of hazardous waste in the UK. In particular, the surveys conducted to date have not elicited much information on the waste producers' preparations for the LFD and its effect on their production processes, disposal practices and costs.

    —  We recommend that Government constitutes a working group comprising the relevant industry associations, to arrive at a consensual position between waste producers and the waste management industry as to the net effect of the LFD on waste arisings, associated treatment requirements and disposal costs. The present uncertainties must be addressed before the waste management industry accelerates the investment decisions necessary for the UK to implement a ban on co-disposal.

  This is an immediate need for Government and other stakeholders to consider whether derogations are to be sought for some waste types and/or WAC parameters.

    —  We recommend that the working group considers this as a priority issue, and that the appropriate negotiations are commenced through the TAC and the European Commission.

  The ultimate challenge is to convert strategies and plans into operating facilities. The waste management industry has for many years faced inordinate delays in achieving planning and permitting for its facilities, be they incinerators or "greener" alternatives such as recycling and compost plants.

    —  We recommend that Government develop systems and procedures that conflate the planning and permitting process into a shorter timeframe, while retaining the checks and balances required to ensure appropriate scrutiny of the applications and protection of the environment.


    May 2002

Table 1


Waste Type

Contaminated soil/C&D waste
Oil/Water separator sludge
Sludge from industrial WTP
Still bottoms and residues (org chem)
Sludge from pet. refining
Drilling muds
Used oils
Bleach solutions
Production of org preservatives and biocides
Waste containing fuel (cleaning and transport)
Sludge from mechanical surface treatment

SSP = Stabilisation/solidification processes
INC = High temprature incineration and co-incineration
PC = Physicochemical treatment
S = Solvent recovery
L = Direct landfilling
BM = Bioremediation (of contaminated soil)
TDES = Thermal desorption (of contaminated soil)

Table 2


Treatment Option
Diverted Tonnage Requiring Treatment (Post 2004)Tonnage% of Total
Annual Tonnage Presently Treated
Total Tonnage for Treatment (Post 2004)
Estimated Annual Current Capacity (Tonnes)

Solvent Recovery
W W T Works
525,000 (contam. soil)

4   Not printed. Back

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