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Sustainable waste management -a case study from the uk water industry
~
Pergamon
WDl. ScL T~ch. Vo1.38. No. II. pp. SI-S8. 1998.
C 19981AWQ
Published by Elsevier Science LId. Printed in Orw Britain. AU righll reserved
PIT: S0273-1223(98)00639:8
0273·1223198 S19'00 + 0-00
SUSTAINABLE WASTE MANAGEMENT• A CASE STUDY FROM THE UK WATER INDUSTRY J. M. Burton North West Water. Lingley Mere. Lingley Gr~:n Avenue. Great Sankey. Warrington, WA53LP. UK
ABSTRACf Waste disposal practices were developed at a time before the implementation of waste regulation. When the first control came the industry found that it was its own waste regulator and so its own practices were not closely examined. Privatisation of the water industry overturned this situation and the disposal practices of the past came under the full spotlight of regulatory control. This was just at a time when waste disposal legislation itself was going through a process of revision to take account of European and Global environmental initiatives. North West Water's response to this was to instigate a thorough review of waste management practice across the Company. This has resulted in a totally new approach to waste management and the creation of a dedicated waste management organisation. The primary role of this organisation is to manage. to the best financial and environmental benefit of the Company. all its waste streams. This management must provide a high level of protection for the receiving environment, take account of cost, and strive to achieve the aims of sustainable development
KEYWORDS Disposal; landfill; polluter pays; sustainable development; waste hierarchy; waste management.
INTRODUCI10N The paper will examine the influences that have been responsible for changing the way waste is now perceived and dealt with within the privatised water industry of England and Wales. It will take a practitioner's view of these changes, describing the regulatory and other pressures that have been brought to bear on traditional approaches to waste disposal. The types of waste in question are sewage sludge, grit, screenings, ash, water treatment sludge and excavation spoil from both water and sewerage mains repair, and spoil from capital projects. The paper will describe what North West Water (the privatised water and wastewater company for the North West region of England) has done in order to adapt to this change.
WASTE DISPOSAL PRACI1CE IN THE PAST Prior to the Deposit of Poisonous Waste Act (1972) and the Control of Pollution Act (1974) (COPA) there was no legislation directed primarily at waste disposal in England and Wales other than the requirement for planning permission for disposal activities. The only form of control over waste activities rested with local authorities. They had powers, under public health legislation, to take action against those creating a nuisance. The local authority was also likely to be the body responsible for sewage collection and treatment, Sl
52
I.M.BURTON
and in some cases, water supply. This meant that wastes generated by sewage and water treatment were disposed of and policed by the same botly. It was also common practice for the local authority to use a sewage works site for the disposal of community domestic refuse.
In 1974, the newly created Water Authorities became responsible, inter alia, for the functions of water supply, sewage collection and sewage treatment. Within the Water Authorities responsibility for the disposal of wastes generated from these functions rested with each waste producer and very often it was left to individual site managers to organise their own disposal requirements. Waste was managed in a somewhat parochial manner with co-operation existing within some functions but with no fully co-ordinated approach. For example, sewage sludge disposal was well co-ordinated. A network of sites with storage capacity had been established and sludge was held in lagoons before application to agricultural land. This operation was managed so as to maximise the agricultural outlet but a system of sludge disposal to sea was also in place. Over the years, this method of sludge disposal became more heavily relied upon especially for sludge generated in urban areas where agricultural land was scarce. In this climate of minimal waste control, where individual site managers dealt with their own wastes, a variety of disposal practices were established. These commonly included: Wastewater practices On-site burial of grit and screenings - these wastes, taken out of sewage in preliminary stages of treatment and notorious for being unpleasant, were quickly buried in a trench and fill operation. Use of lagoons - these held sludge prior to off site disposal or re-use in agriculture but often became disposal outlets in themselves. When full the sludge was simply dug out and lost on site. Water treatment practices Where an outlet to sewer for liquid sludge waste was not possible, mechanical dewatering was often employed to reduce water content, producing a cake that was disposed of on site. Excavation spoil practices Excavation spoil arising from the repair of the water and sewerage distribution networks was often given away, for example, to fill hollows in farmer's fields. It might also have been used to provide cover for the community refuse disposal site within the sewage works. Each of these practices was cheap, easy and virtually problem free, making waste disposal a low profile task. The Control of pollution Act (1974) introduced waste disposal regulation through a comprehensive licensing system for all industrial and commercial waste activities. It prohibited unlicensed disposal and imposed more severe penalties if the waste was poisonous, noxious or polluting, or likely to give rise to an environmental hazard. The newly created Water Authorities became statutory consultees on waste disposal licence applications and had powers to refer an application to the Secretary of State if the proposed activity presented an unacceptable risk, for example, to groundwater. The question must then be asked as to how the introduction of waste disposal legislation, and the separation from local authority control of water and sewage treatment, affected waste disposal practices. The answer is hardly at all. Regulations made under COPA gave Water Authorities certain privileges that took some wastes and disposal practices out of licence control but North West Water Authority (the predecessor of North West Water) did take out a number of waste disposal licences under the new legislation. These were mainly for the disposal of excavation spoil but some licences were sought for sites acting as local disposal
Sustainable waste management
S3
~utlets for waste generated at other treatment works. Sites only disposing of their own waste were not hcensed even though a close examination of the legislation would have indicated a licence was necessary.
At this time North West Water achieved some degree of waste management through a system of Tipping Plans'. These plans were updated each year to address the issue of disposal capacity so that when a disposal outlet was reaching the end of its life another one could be found. The outlets selected were usually the on• site methods discussed earlier or licensed landfills owned and operated by the Water Authority. Therefore waste disposal was an internal activity managed to a large extent without the need for external contractors and so it was cheap. With tipping plans in place incorporating the practices described above, and a secure outlet to sea for large volumes of wastewater sludge, waste disposal looked after itself. It was unusual for detailed disposal records to be kept and very unusual for anyone to question aspects of environmental concern. For these reasons no one knew the true cost of waste disposal. After the implementation of COPA, waste regulation rested with Waste Disposal Authorities, part of the local authority system. Various pieces of waste related legislation were enacted but nothing that was to dramatically affect the Water Authorities. Wider issues of enyironmental concern At this time, the late 1980's and early 1990's, a variety of other environment related issues were beginning to be debated on a Global basis and within Europe, Directives were being developed and implemented that would have a significant impact on waste disposal. These included:The Brundtland Commission report of 1987, Our Common Future (1987), prepared for the World Commission on Environment and Development The publication in September 1989 of A Community Strategy for Waste Management (1989) This Common Inheritance (1990), Britain's Environmental Strategy, 1990 The European Community's Fifth Action Programme on the Environment (1993) Revision of the Waste Framework Directive (1975) The first attempts at a Landfill Directive (1991) The 1991 Hague Resolution on Groundwater Protection (1991) In 1989 the water industry of England and Wales was privatised and Water Authorities became Water Companies. All assets were transferred to the newly created Water Companies including land ownership. Privatisation meant that funding for improvements in water and wastewater services was no longer solely at the discretion of Government but could be financed from market sources. It also meant that the earlier waste disposal privileges granted to Water Authorities were no longer relevant The privatised Water Companies would have to operate under the same rules as the rest of commerce and industry. However, these rules were themselves being subjected to influences coming from Europe and beyond. Legislation was starting to reflect these influences by incorporating certain principles that are now familiar. However, at the time the combined effect of all this change on established waste disposal practice could not be foreseen. These principles are: 'Sustainable Development' - Development that meets the needs of the present without compromising the ability of future generations to meet their own needs. The 'Polluter Pays' Principle - Full environmental costs are borne by those directly responsible. The 'Precautionary' Principle - Action will be taken to limit the potential for pollution. The 'Preventative' Principle - Certain processes have to be operated under terms and conditions that aim to prevent pollution. The 'Waste Hierarchy Approach to ~aste Management' - ':- method of ranking waste management options which takes into account envIronmental benefit or dlsbenefit.
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I.M.BURTON
The 'waste hierarchy' approach to waste management encourages waste producers to choose waste management options towards the top of the hierarchy. The most favoured option is waste Reduction, followed by Re-use. and then Recovery. Landfill is considered to be the least sustainable option and is at the bottom of the rankmg. Waste producers are persuaded to move up the hierarchy and away from landfill through fiscal, and other measures designed to increase the cost of landfill. These include taxing waste going to landfill and the in~oductio? of legislation requiring higher standards of landfill design and operation. The.se push up the p~ce of dIsposal and so make the polluter pay. while achieving higher standards of envIronmental protection.
RECOVERY Recycling Compo sting E ergy Recove DISPOSAL
The waste hierarchy.
Indirect influences At the same time, other environmental issues were being addressed which would also have an influence on disposal practices. These include:The Urban Wastewater Treatment Directive (1991) - This would increase the volume of wastewater sludge to be disposed of AND put an end to the disposal of sewage sludge at sea. A green paper on a system for Civil Liability for Damage Caused by Waste (1991) - This proposed retrospective liability and compensation for damage caused by waste. Development of Environmental Standards and the move towards the use of Environmental Policies and Environmental Management Systems. The general increases in public awareness of environmental issues and the resultant public expectation of improvement. lust as these issues were being debated on the European and World environmental arena, the UK Government brought out its Environmental Protection Act of 1990. This piece of legislation held the first real threat to established disposal practices. It was evident that Government was committed to the principles described above as their influence was found within its pages. Part I of the Act introduced Integrated Pollution Control for certain industrial processes while Part II enhanced the system of waste disposal legislation begun by COPA. The terminology was changed, with waste disposal becoming waste management, in a deliberate attempt to change perception and encourage waste producers to realise that waste disposal was not the only option available. A stricter system of waste mana2ement licensin2 Under the 1990 Act, licensing has been extended to cover the treatment and keeping of waste as well as its disposal. Those applying for waste management licences have to pass a suitability test to prove they are 'fit and proper'. This means that they have to prove their 'technical competence' at operating the facility, show they have adequate 'financial provision' to care for the site, and have no record of 'relevant convictions' for environmental offences. Unlike COPA the Act requires that a waste management licence once issued, cannot
Sustainable waste management
55
be surrendered 'until the condition of the land is unlikely to cause pollution of the environment or harm to human health'. These provisions have significantly increased the costs and liabilities associated with waste management operations, especially landfill, and make the polluter pay. But the full impact of this was not realised until the introduction of licensing regulations in 1994. The waste mana~ement licensin~ re~ulations 1994 These regulations took away many of the privileges of the past. Nearly all the on site disposal practices became illegal without the benefit of a licence. Only certain types of activities relating to sludge within a sewage treatment works were still permitted without a licence. However, even this was not a given right as these regulations also contained the transposed script of the European Waste Directive. This set out certain key objectives, one of which states that all waste activities must be carried out 'without (i) (ii) (iii)
risk to water, air, soil, plants or animals; or causing nuisance through noise or odours; or adversely affecting the countryside or places of special interest; .. '
This posed a very serious question for Water Companies. Were current waste activities posing such a risk? Investigations of this sort had not been necessary in the past and so the answer was a worrying uncertainty. To compound this, the Environmental Protection Act (1990) also contained provisions to make regulations that would identify areas of 'contaminated land'. The government had previously commissioned work prior to the introduction of these regulations that had listed sewage works and sewage farms as likely candidates. The protection of groundwater was also given particular attention with a specific regulation structured so as to tie in with the UK Groundwater protection Policy (1992) which had been developed as a result of the 1991 Hague Resolution on Groundwater Protection (1991). It was clear that the new regulations placed a high emphasis on environmental protection. North West Water's reaction to these new regulations was similar to other Water Companies, and turned out to be a balance between two basic options. Apply for waste management licences for those activities that now required them, or change operational practice to avoid the need for a licence. Some practices could not be changed and so licences were sought, but other activities, such as on site disposal, were stopped and waste disposal contractors engaged. Both these options involved significant additional cost. Off site disposal had an immediate budgetary impact, and the long-term implications of holding waste management licences also posed significant ongoing costs. The weight of the various influences was beginning to be felt and North West Water decided it was time to take a strategic look at its waste management. A WASTE STRATEGY FOR NORTH WEST WATER In the autumn of 1995 approval was given for a small team to develop a Waste Strategy for the Company. The key drivers were: Stricter waste management legislation increasing the cost of disposal The introduction of a landfill levy The ending of the sludge to sea disposal route The increase in waste volumes as a result of the Urban Wastewater Treatment Directive (1991) Concerns about regulatory compliance The move towards the waste hierarchy approach to waste management. The team consulted with people from all aspects of the business in the development of the strategy. The first requirement was to carry out a waste audit to establish a baseline of waste type, waste quantity, method of disposal and disposal costs. This revealed that for the financial year 1994/5 the Company had spent £17.7 million on the management and disposal of 4.8 million tonnes of waste. Landfill was the favoured outlet for
S6
I.M.BURTON
most wastes apart from wastewater sludge where 75% was disposed of to sea with most of the remainder recycled onto agricultural land. These statistics came as somewhat of a surprise but when the information was then used to project costs five years ahead the shock was worse. By the year 200112 costs were predicted to rise to £30 milJion even though a shift from liquid sludge to dewatered cake, and a reduced input of construction waste, would reduce overalI volumes of waste produced. With this information the team set about developing a waste strategy that was, in the end, to be influenced by other developments. These were the commitment at a Board level to the development of an Environment Policy, and the timely publication of the Governments White Paper on sustainable waste management for the UK, Making Waste Work (1995). In this paper many of the influences discussed earlier were put into Government policy with the waste hierarchy approach to waste management being the central theme. As if to compliment this the Board Environment Policy gave a commitment that the Company would reduce its adverse environmental impacts and look towards more sustainable operational practices including waste management. Under these influences the team set about developing its strategy which was to include four high level strategic goals. Specific waste streams were linked back to specific business areas and each business area given the task of developing its own waste plan to achieve the goals. The four goals are listed below with their associated high level statements. Each statement would subsequently be supported by fully developed business plans including targets and estimates of costs savings and benefits. NORTH WEST WATER'S WASTE STRATEGY GOALS GOAL 1: to provide secure, sustainable, flexible routes for waste 1.1 1.2 1.3 1.4 1.5 1.6
Develop maximum sustainable capacity and protect the sludge to agriculture outlet. Develop maximum capacity for sludge and other waste used in land restoration. Develop reduction and recycling of excavation spoil. Secure external landfill capacity for bjode~radable wastes, which cannot be recycled with options to increase capacity to cover other, less secure outlets. Secure external and internal landfill capacity for non-bjodejp'adable wastes, which cannot be recycled. Develop new alternative beneficial routes.
GOAL 2: to comply with all legislative and regulatory requirements 2.1
Ensure compliance with all legislation and regulations.
GOAL 3: to optimise environmental, fmancial and operational benefit and risk 3.1 3.2 3.3 3.4
Establish current and future potential liabilities from waste management operations. End NWW operated landfilling of biodegradable waste. Achieve the environmental and operational targets while limiting waste management costs. Ensure that cost of waste management is borne by the producer ('producer pays' principle) through management information systems and budgetary controls for all wastes by end 1996.
GOAL 4: to increase the overall proportion of waste managed towards the top of the waste hierarchy 4.1 4.2
Reduce production of waste overall by 41 %. Increase recovery/recycling of waste produced overall from 17% in 1994/5 to 50% by 200112.
It is evident from these statements that the influences moving waste disposal away from landfill have been effective. What is not evident is the approach the Company has taken to the ending of the sludge to sea
Sustainable waste management
disposal route .. I~c~neration has been chosen ~. the most secure replacement option with emphasis being placed on maxlmlsmg all other re-use opportumtles for the sludge before choosing the incineration route. A p~oportion of the ashes from incineration will need to be landfilled but it is hoped that in the long tenn there Will be some form of re-use for this waste. However, landfill is still recognised as a major and necessary outlet for some years to come and for this reason the Company is negotiating long-term contracts with external landfill operators to secure this outlet. It is also evident from the strategy statements that the need to assess potential liability from previous disposal practices has been recognised. In conjunction with the Environment Policy Team, the Waste Strategy Team has begun a survey of sites to establish where there may be risk of pollution from previous (and current) waste related activities. This will result in a prioritised list of sites to be looked at in more detail. It is anticipated that by taking a proactive approach to searching out the legacies of the past, the Company will be in a good position to carry out its obligatio,s when the full details of the contaminated land regulations are known. It is ironic that under the new reguihtions it will be local authorities that will have a duty to inspect land in their area for contamination, as they were the bodies responsible for disposal activities at treatment works in the past. One of the major factors of note within the waste strategy goals is the recognition that the polluter must pay. Passing responsibility for the development of waste plans back to specific business areas (polluters) was recognition of this and the start of a dramatic change in approach to waste management. The Waste Strategy Team recommended that a dedicated department should be set up to manage waste activities so as to achieve optimum financial and environmental benefit for the Company. In simple terms this department or organisation would receive the wastes as generated from the various business areas and direct them into the most beneficial outlets. The waste producer would agree an economic unit price for this waste management service, but the waste producer would be under pressure to ensure the waste met the specification required by the waste organisation. If it failed the penalty would be higher charges. This method of controlling the quality of waste would give the waste organisation confidence to develop outlets for re-use and recycling and provide the incentive for waste producers to think about, not only the quantity of waste produced, but also its quality. A WASTE MANAGEMENT ORGANISATION FOR NORTH WEST WATER At the time of writing, North West Water's waste management organisation, named Environmental Services, has been in existence for approximately nine months. The new organisation has brought together the waste management expertise that was previously spread across the business. Environmental Services is establishing data collection systems that have revealed that the estimates given in the initial waste survey were themselves unreliable - another reflection on the quality of waste related data in times past. Figures Collated by Environmental Service, show that North West Water disposed of 5.8 million tonnes of waste last year (1997/8) at a cost of £29.8 million. This year, through the influence of Environmental Services, it is anticipated that a cost saving of £1.8 million will be achieved. Having the people with the relevant skills, expertise and knowledge all working together with the same objectives and goals, it is expected that Environmental Services will continue to provide cost effective waste management services while making environmental improvements. Part of the task ahead is to quantify environmental improvement so that these too can be 'valued'. The scope of the organisation could be expanded to offer waste management services commercially in the market place. Whether this happens or not, North West Water has taken a pro-active approach to dealing with the problem of ever tightening waste regulation in a way that is totally in harmony with the expectations of National Government and Global environmental objectives.
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I.M.BURTON
CONCLUSIONS For many years the water industry was shielded from the need to examine its waste disposal practices. As a consequence there was a lack of awareness of the changing face of waste regulation. Even when the industry was pri vatised in 1989 the disposal methods of the past were not examined. The global move towards achieving sustainable development has influenced many issues on the environmental agenda and prompted the adoption of certain principles that drive progress in the right direction. These include the 'polluter pays' principle and the adoption of a waste hierarchy approach to waste management. These are now being reflected in UK legislation and for the first time water companies are having to take a close look at all their waste management practices. As a result of this, North West Water chose to instigate a thorough review of waste management. A waste strategy, taking on board all the factors and pressures influencing waste management today, was developed. It was the most comprehensive review of waste related activities ever attempted by the Company and resulted in the creation of a new organisation within the Company whose primary role is to manage, to the best financial and environmental benefit of the Company, all waste streams. For the first time there will be a co-ordinated, Company view of waste management, with aims, goals and targets being set, reviewed and achieved in a consistent, co-ordinated and sustainable way. The result will be a framework for waste management within which it will be possible to achieve financial self-sufficiency and sustainability by working in eqUilibrium with the limitations of the receiving environment. A truly sustainable approach to waste management. ACKNOWLEDGEMENTS The author wishes to thank Mr John Wilson, North West Water's Waste Strategy Manager, for his assistance. The views expressed in this paper are those of the author and not necessarily those of North West Water.
REFERENCES A Community Strategy for Waste Management (1989). SEC(89)934. European Commission. Civil liability for damage caused by waste (1991). Proposal/or a Council Directive on civil liability caused by waste. 911C 192/04. European Commission. Control of Pollution Act (1974). London, H.M.S.O. Deposit of Poisonous Waste Act (1972). London, H.M.S.O. Environmental Protection Act (1990). London. H.M.S.O. Fifth Action Programme On The Environment (1993). European Commission. Hague Resolution on Groundwater Protection (1991). European Commission. • Landfill Directive Proposal (1991). Proposal/or a Council Directive 011 the landfill 0/ waste. COM(91) 102. European Commission. Making Waste Work (1995). It Strategy lor Sustainable Waste Management ill England and Wales. London. H.M.S.O. . Our Common Future (1987). The Brundtland Commission report prepared lor the World Commissioll on EnVironmental Development. This Common Inheritance (1990). Britain's Environmental Strategy· London. H.M.S.O. UK Groundwater Protection Policy (1992). Policy And Practice For The Protection O/Groundwater, National Rivers Authority. Urban Wastewater Treatment Directive (1991). Directive 911271IEEC. European Commission Waste Framework Directive (1975). Council directive 7S/442/EEC on waste as amended by Directive 9J/JS6IEEC. European Commission. Waste Management Licensing Regulations (1994). London. H.M.S.O.
Pergamon
WDl. ScL T~ch. Vo1.38. No. II. pp. SI-S8. 1998.
C 19981AWQ
Published by Elsevier Science LId. Printed in Orw Britain. AU righll reserved
PIT: S0273-1223(98)00639:8
0273·1223198 S19'00 + 0-00
SUSTAINABLE WASTE MANAGEMENT• A CASE STUDY FROM THE UK WATER INDUSTRY J. M. Burton North West Water. Lingley Mere. Lingley Gr~:n Avenue. Great Sankey. Warrington, WA53LP. UK
ABSTRACf Waste disposal practices were developed at a time before the implementation of waste regulation. When the first control came the industry found that it was its own waste regulator and so its own practices were not closely examined. Privatisation of the water industry overturned this situation and the disposal practices of the past came under the full spotlight of regulatory control. This was just at a time when waste disposal legislation itself was going through a process of revision to take account of European and Global environmental initiatives. North West Water's response to this was to instigate a thorough review of waste management practice across the Company. This has resulted in a totally new approach to waste management and the creation of a dedicated waste management organisation. The primary role of this organisation is to manage. to the best financial and environmental benefit of the Company. all its waste streams. This management must provide a high level of protection for the receiving environment, take account of cost, and strive to achieve the aims of sustainable development
KEYWORDS Disposal; landfill; polluter pays; sustainable development; waste hierarchy; waste management.
INTRODUCI10N The paper will examine the influences that have been responsible for changing the way waste is now perceived and dealt with within the privatised water industry of England and Wales. It will take a practitioner's view of these changes, describing the regulatory and other pressures that have been brought to bear on traditional approaches to waste disposal. The types of waste in question are sewage sludge, grit, screenings, ash, water treatment sludge and excavation spoil from both water and sewerage mains repair, and spoil from capital projects. The paper will describe what North West Water (the privatised water and wastewater company for the North West region of England) has done in order to adapt to this change.
WASTE DISPOSAL PRACI1CE IN THE PAST Prior to the Deposit of Poisonous Waste Act (1972) and the Control of Pollution Act (1974) (COPA) there was no legislation directed primarily at waste disposal in England and Wales other than the requirement for planning permission for disposal activities. The only form of control over waste activities rested with local authorities. They had powers, under public health legislation, to take action against those creating a nuisance. The local authority was also likely to be the body responsible for sewage collection and treatment, Sl
52
I.M.BURTON
and in some cases, water supply. This meant that wastes generated by sewage and water treatment were disposed of and policed by the same botly. It was also common practice for the local authority to use a sewage works site for the disposal of community domestic refuse.
In 1974, the newly created Water Authorities became responsible, inter alia, for the functions of water supply, sewage collection and sewage treatment. Within the Water Authorities responsibility for the disposal of wastes generated from these functions rested with each waste producer and very often it was left to individual site managers to organise their own disposal requirements. Waste was managed in a somewhat parochial manner with co-operation existing within some functions but with no fully co-ordinated approach. For example, sewage sludge disposal was well co-ordinated. A network of sites with storage capacity had been established and sludge was held in lagoons before application to agricultural land. This operation was managed so as to maximise the agricultural outlet but a system of sludge disposal to sea was also in place. Over the years, this method of sludge disposal became more heavily relied upon especially for sludge generated in urban areas where agricultural land was scarce. In this climate of minimal waste control, where individual site managers dealt with their own wastes, a variety of disposal practices were established. These commonly included: Wastewater practices On-site burial of grit and screenings - these wastes, taken out of sewage in preliminary stages of treatment and notorious for being unpleasant, were quickly buried in a trench and fill operation. Use of lagoons - these held sludge prior to off site disposal or re-use in agriculture but often became disposal outlets in themselves. When full the sludge was simply dug out and lost on site. Water treatment practices Where an outlet to sewer for liquid sludge waste was not possible, mechanical dewatering was often employed to reduce water content, producing a cake that was disposed of on site. Excavation spoil practices Excavation spoil arising from the repair of the water and sewerage distribution networks was often given away, for example, to fill hollows in farmer's fields. It might also have been used to provide cover for the community refuse disposal site within the sewage works. Each of these practices was cheap, easy and virtually problem free, making waste disposal a low profile task. The Control of pollution Act (1974) introduced waste disposal regulation through a comprehensive licensing system for all industrial and commercial waste activities. It prohibited unlicensed disposal and imposed more severe penalties if the waste was poisonous, noxious or polluting, or likely to give rise to an environmental hazard. The newly created Water Authorities became statutory consultees on waste disposal licence applications and had powers to refer an application to the Secretary of State if the proposed activity presented an unacceptable risk, for example, to groundwater. The question must then be asked as to how the introduction of waste disposal legislation, and the separation from local authority control of water and sewage treatment, affected waste disposal practices. The answer is hardly at all. Regulations made under COPA gave Water Authorities certain privileges that took some wastes and disposal practices out of licence control but North West Water Authority (the predecessor of North West Water) did take out a number of waste disposal licences under the new legislation. These were mainly for the disposal of excavation spoil but some licences were sought for sites acting as local disposal
Sustainable waste management
S3
~utlets for waste generated at other treatment works. Sites only disposing of their own waste were not hcensed even though a close examination of the legislation would have indicated a licence was necessary.
At this time North West Water achieved some degree of waste management through a system of Tipping Plans'. These plans were updated each year to address the issue of disposal capacity so that when a disposal outlet was reaching the end of its life another one could be found. The outlets selected were usually the on• site methods discussed earlier or licensed landfills owned and operated by the Water Authority. Therefore waste disposal was an internal activity managed to a large extent without the need for external contractors and so it was cheap. With tipping plans in place incorporating the practices described above, and a secure outlet to sea for large volumes of wastewater sludge, waste disposal looked after itself. It was unusual for detailed disposal records to be kept and very unusual for anyone to question aspects of environmental concern. For these reasons no one knew the true cost of waste disposal. After the implementation of COPA, waste regulation rested with Waste Disposal Authorities, part of the local authority system. Various pieces of waste related legislation were enacted but nothing that was to dramatically affect the Water Authorities. Wider issues of enyironmental concern At this time, the late 1980's and early 1990's, a variety of other environment related issues were beginning to be debated on a Global basis and within Europe, Directives were being developed and implemented that would have a significant impact on waste disposal. These included:The Brundtland Commission report of 1987, Our Common Future (1987), prepared for the World Commission on Environment and Development The publication in September 1989 of A Community Strategy for Waste Management (1989) This Common Inheritance (1990), Britain's Environmental Strategy, 1990 The European Community's Fifth Action Programme on the Environment (1993) Revision of the Waste Framework Directive (1975) The first attempts at a Landfill Directive (1991) The 1991 Hague Resolution on Groundwater Protection (1991) In 1989 the water industry of England and Wales was privatised and Water Authorities became Water Companies. All assets were transferred to the newly created Water Companies including land ownership. Privatisation meant that funding for improvements in water and wastewater services was no longer solely at the discretion of Government but could be financed from market sources. It also meant that the earlier waste disposal privileges granted to Water Authorities were no longer relevant The privatised Water Companies would have to operate under the same rules as the rest of commerce and industry. However, these rules were themselves being subjected to influences coming from Europe and beyond. Legislation was starting to reflect these influences by incorporating certain principles that are now familiar. However, at the time the combined effect of all this change on established waste disposal practice could not be foreseen. These principles are: 'Sustainable Development' - Development that meets the needs of the present without compromising the ability of future generations to meet their own needs. The 'Polluter Pays' Principle - Full environmental costs are borne by those directly responsible. The 'Precautionary' Principle - Action will be taken to limit the potential for pollution. The 'Preventative' Principle - Certain processes have to be operated under terms and conditions that aim to prevent pollution. The 'Waste Hierarchy Approach to ~aste Management' - ':- method of ranking waste management options which takes into account envIronmental benefit or dlsbenefit.
S4
I.M.BURTON
The 'waste hierarchy' approach to waste management encourages waste producers to choose waste management options towards the top of the hierarchy. The most favoured option is waste Reduction, followed by Re-use. and then Recovery. Landfill is considered to be the least sustainable option and is at the bottom of the rankmg. Waste producers are persuaded to move up the hierarchy and away from landfill through fiscal, and other measures designed to increase the cost of landfill. These include taxing waste going to landfill and the in~oductio? of legislation requiring higher standards of landfill design and operation. The.se push up the p~ce of dIsposal and so make the polluter pay. while achieving higher standards of envIronmental protection.
RECOVERY Recycling Compo sting E ergy Recove DISPOSAL
The waste hierarchy.
Indirect influences At the same time, other environmental issues were being addressed which would also have an influence on disposal practices. These include:The Urban Wastewater Treatment Directive (1991) - This would increase the volume of wastewater sludge to be disposed of AND put an end to the disposal of sewage sludge at sea. A green paper on a system for Civil Liability for Damage Caused by Waste (1991) - This proposed retrospective liability and compensation for damage caused by waste. Development of Environmental Standards and the move towards the use of Environmental Policies and Environmental Management Systems. The general increases in public awareness of environmental issues and the resultant public expectation of improvement. lust as these issues were being debated on the European and World environmental arena, the UK Government brought out its Environmental Protection Act of 1990. This piece of legislation held the first real threat to established disposal practices. It was evident that Government was committed to the principles described above as their influence was found within its pages. Part I of the Act introduced Integrated Pollution Control for certain industrial processes while Part II enhanced the system of waste disposal legislation begun by COPA. The terminology was changed, with waste disposal becoming waste management, in a deliberate attempt to change perception and encourage waste producers to realise that waste disposal was not the only option available. A stricter system of waste mana2ement licensin2 Under the 1990 Act, licensing has been extended to cover the treatment and keeping of waste as well as its disposal. Those applying for waste management licences have to pass a suitability test to prove they are 'fit and proper'. This means that they have to prove their 'technical competence' at operating the facility, show they have adequate 'financial provision' to care for the site, and have no record of 'relevant convictions' for environmental offences. Unlike COPA the Act requires that a waste management licence once issued, cannot
Sustainable waste management
55
be surrendered 'until the condition of the land is unlikely to cause pollution of the environment or harm to human health'. These provisions have significantly increased the costs and liabilities associated with waste management operations, especially landfill, and make the polluter pay. But the full impact of this was not realised until the introduction of licensing regulations in 1994. The waste mana~ement licensin~ re~ulations 1994 These regulations took away many of the privileges of the past. Nearly all the on site disposal practices became illegal without the benefit of a licence. Only certain types of activities relating to sludge within a sewage treatment works were still permitted without a licence. However, even this was not a given right as these regulations also contained the transposed script of the European Waste Directive. This set out certain key objectives, one of which states that all waste activities must be carried out 'without (i) (ii) (iii)
risk to water, air, soil, plants or animals; or causing nuisance through noise or odours; or adversely affecting the countryside or places of special interest; .. '
This posed a very serious question for Water Companies. Were current waste activities posing such a risk? Investigations of this sort had not been necessary in the past and so the answer was a worrying uncertainty. To compound this, the Environmental Protection Act (1990) also contained provisions to make regulations that would identify areas of 'contaminated land'. The government had previously commissioned work prior to the introduction of these regulations that had listed sewage works and sewage farms as likely candidates. The protection of groundwater was also given particular attention with a specific regulation structured so as to tie in with the UK Groundwater protection Policy (1992) which had been developed as a result of the 1991 Hague Resolution on Groundwater Protection (1991). It was clear that the new regulations placed a high emphasis on environmental protection. North West Water's reaction to these new regulations was similar to other Water Companies, and turned out to be a balance between two basic options. Apply for waste management licences for those activities that now required them, or change operational practice to avoid the need for a licence. Some practices could not be changed and so licences were sought, but other activities, such as on site disposal, were stopped and waste disposal contractors engaged. Both these options involved significant additional cost. Off site disposal had an immediate budgetary impact, and the long-term implications of holding waste management licences also posed significant ongoing costs. The weight of the various influences was beginning to be felt and North West Water decided it was time to take a strategic look at its waste management. A WASTE STRATEGY FOR NORTH WEST WATER In the autumn of 1995 approval was given for a small team to develop a Waste Strategy for the Company. The key drivers were: Stricter waste management legislation increasing the cost of disposal The introduction of a landfill levy The ending of the sludge to sea disposal route The increase in waste volumes as a result of the Urban Wastewater Treatment Directive (1991) Concerns about regulatory compliance The move towards the waste hierarchy approach to waste management. The team consulted with people from all aspects of the business in the development of the strategy. The first requirement was to carry out a waste audit to establish a baseline of waste type, waste quantity, method of disposal and disposal costs. This revealed that for the financial year 1994/5 the Company had spent £17.7 million on the management and disposal of 4.8 million tonnes of waste. Landfill was the favoured outlet for
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most wastes apart from wastewater sludge where 75% was disposed of to sea with most of the remainder recycled onto agricultural land. These statistics came as somewhat of a surprise but when the information was then used to project costs five years ahead the shock was worse. By the year 200112 costs were predicted to rise to £30 milJion even though a shift from liquid sludge to dewatered cake, and a reduced input of construction waste, would reduce overalI volumes of waste produced. With this information the team set about developing a waste strategy that was, in the end, to be influenced by other developments. These were the commitment at a Board level to the development of an Environment Policy, and the timely publication of the Governments White Paper on sustainable waste management for the UK, Making Waste Work (1995). In this paper many of the influences discussed earlier were put into Government policy with the waste hierarchy approach to waste management being the central theme. As if to compliment this the Board Environment Policy gave a commitment that the Company would reduce its adverse environmental impacts and look towards more sustainable operational practices including waste management. Under these influences the team set about developing its strategy which was to include four high level strategic goals. Specific waste streams were linked back to specific business areas and each business area given the task of developing its own waste plan to achieve the goals. The four goals are listed below with their associated high level statements. Each statement would subsequently be supported by fully developed business plans including targets and estimates of costs savings and benefits. NORTH WEST WATER'S WASTE STRATEGY GOALS GOAL 1: to provide secure, sustainable, flexible routes for waste 1.1 1.2 1.3 1.4 1.5 1.6
Develop maximum sustainable capacity and protect the sludge to agriculture outlet. Develop maximum capacity for sludge and other waste used in land restoration. Develop reduction and recycling of excavation spoil. Secure external landfill capacity for bjode~radable wastes, which cannot be recycled with options to increase capacity to cover other, less secure outlets. Secure external and internal landfill capacity for non-bjodejp'adable wastes, which cannot be recycled. Develop new alternative beneficial routes.
GOAL 2: to comply with all legislative and regulatory requirements 2.1
Ensure compliance with all legislation and regulations.
GOAL 3: to optimise environmental, fmancial and operational benefit and risk 3.1 3.2 3.3 3.4
Establish current and future potential liabilities from waste management operations. End NWW operated landfilling of biodegradable waste. Achieve the environmental and operational targets while limiting waste management costs. Ensure that cost of waste management is borne by the producer ('producer pays' principle) through management information systems and budgetary controls for all wastes by end 1996.
GOAL 4: to increase the overall proportion of waste managed towards the top of the waste hierarchy 4.1 4.2
Reduce production of waste overall by 41 %. Increase recovery/recycling of waste produced overall from 17% in 1994/5 to 50% by 200112.
It is evident from these statements that the influences moving waste disposal away from landfill have been effective. What is not evident is the approach the Company has taken to the ending of the sludge to sea
Sustainable waste management
disposal route .. I~c~neration has been chosen ~. the most secure replacement option with emphasis being placed on maxlmlsmg all other re-use opportumtles for the sludge before choosing the incineration route. A p~oportion of the ashes from incineration will need to be landfilled but it is hoped that in the long tenn there Will be some form of re-use for this waste. However, landfill is still recognised as a major and necessary outlet for some years to come and for this reason the Company is negotiating long-term contracts with external landfill operators to secure this outlet. It is also evident from the strategy statements that the need to assess potential liability from previous disposal practices has been recognised. In conjunction with the Environment Policy Team, the Waste Strategy Team has begun a survey of sites to establish where there may be risk of pollution from previous (and current) waste related activities. This will result in a prioritised list of sites to be looked at in more detail. It is anticipated that by taking a proactive approach to searching out the legacies of the past, the Company will be in a good position to carry out its obligatio,s when the full details of the contaminated land regulations are known. It is ironic that under the new reguihtions it will be local authorities that will have a duty to inspect land in their area for contamination, as they were the bodies responsible for disposal activities at treatment works in the past. One of the major factors of note within the waste strategy goals is the recognition that the polluter must pay. Passing responsibility for the development of waste plans back to specific business areas (polluters) was recognition of this and the start of a dramatic change in approach to waste management. The Waste Strategy Team recommended that a dedicated department should be set up to manage waste activities so as to achieve optimum financial and environmental benefit for the Company. In simple terms this department or organisation would receive the wastes as generated from the various business areas and direct them into the most beneficial outlets. The waste producer would agree an economic unit price for this waste management service, but the waste producer would be under pressure to ensure the waste met the specification required by the waste organisation. If it failed the penalty would be higher charges. This method of controlling the quality of waste would give the waste organisation confidence to develop outlets for re-use and recycling and provide the incentive for waste producers to think about, not only the quantity of waste produced, but also its quality. A WASTE MANAGEMENT ORGANISATION FOR NORTH WEST WATER At the time of writing, North West Water's waste management organisation, named Environmental Services, has been in existence for approximately nine months. The new organisation has brought together the waste management expertise that was previously spread across the business. Environmental Services is establishing data collection systems that have revealed that the estimates given in the initial waste survey were themselves unreliable - another reflection on the quality of waste related data in times past. Figures Collated by Environmental Service, show that North West Water disposed of 5.8 million tonnes of waste last year (1997/8) at a cost of £29.8 million. This year, through the influence of Environmental Services, it is anticipated that a cost saving of £1.8 million will be achieved. Having the people with the relevant skills, expertise and knowledge all working together with the same objectives and goals, it is expected that Environmental Services will continue to provide cost effective waste management services while making environmental improvements. Part of the task ahead is to quantify environmental improvement so that these too can be 'valued'. The scope of the organisation could be expanded to offer waste management services commercially in the market place. Whether this happens or not, North West Water has taken a pro-active approach to dealing with the problem of ever tightening waste regulation in a way that is totally in harmony with the expectations of National Government and Global environmental objectives.
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CONCLUSIONS For many years the water industry was shielded from the need to examine its waste disposal practices. As a consequence there was a lack of awareness of the changing face of waste regulation. Even when the industry was pri vatised in 1989 the disposal methods of the past were not examined. The global move towards achieving sustainable development has influenced many issues on the environmental agenda and prompted the adoption of certain principles that drive progress in the right direction. These include the 'polluter pays' principle and the adoption of a waste hierarchy approach to waste management. These are now being reflected in UK legislation and for the first time water companies are having to take a close look at all their waste management practices. As a result of this, North West Water chose to instigate a thorough review of waste management. A waste strategy, taking on board all the factors and pressures influencing waste management today, was developed. It was the most comprehensive review of waste related activities ever attempted by the Company and resulted in the creation of a new organisation within the Company whose primary role is to manage, to the best financial and environmental benefit of the Company, all waste streams. For the first time there will be a co-ordinated, Company view of waste management, with aims, goals and targets being set, reviewed and achieved in a consistent, co-ordinated and sustainable way. The result will be a framework for waste management within which it will be possible to achieve financial self-sufficiency and sustainability by working in eqUilibrium with the limitations of the receiving environment. A truly sustainable approach to waste management. ACKNOWLEDGEMENTS The author wishes to thank Mr John Wilson, North West Water's Waste Strategy Manager, for his assistance. The views expressed in this paper are those of the author and not necessarily those of North West Water.
REFERENCES A Community Strategy for Waste Management (1989). SEC(89)934. European Commission. Civil liability for damage caused by waste (1991). Proposal/or a Council Directive on civil liability caused by waste. 911C 192/04. European Commission. Control of Pollution Act (1974). London, H.M.S.O. Deposit of Poisonous Waste Act (1972). London, H.M.S.O. Environmental Protection Act (1990). London. H.M.S.O. Fifth Action Programme On The Environment (1993). European Commission. Hague Resolution on Groundwater Protection (1991). European Commission. • Landfill Directive Proposal (1991). Proposal/or a Council Directive 011 the landfill 0/ waste. COM(91) 102. European Commission. Making Waste Work (1995). It Strategy lor Sustainable Waste Management ill England and Wales. London. H.M.S.O. . Our Common Future (1987). The Brundtland Commission report prepared lor the World Commissioll on EnVironmental Development. This Common Inheritance (1990). Britain's Environmental Strategy· London. H.M.S.O. UK Groundwater Protection Policy (1992). Policy And Practice For The Protection O/Groundwater, National Rivers Authority. Urban Wastewater Treatment Directive (1991). Directive 911271IEEC. European Commission Waste Framework Directive (1975). Council directive 7S/442/EEC on waste as amended by Directive 9J/JS6IEEC. European Commission. Waste Management Licensing Regulations (1994). London. H.M.S.O.