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2.9.3 Management of non-radioactive waste

Contents
2.9.3.1 Classification of non-radioactive waste
2.9.3.2 Treatment of non-radioactive wastes

Non-radioactive wastes may be known as ‘controlled waste’ and includes waste arising from domestic, industrial and commercial premises, as well as hazardous waste. Non-radioactive wastes derived from site investigations are controlled waste. The ways of managing these wastes are rapidly changing, with more emphasis on reducing the volumes sent to landfill by recycling, and pre-treating that which is landfilled.

Site waste management plans (SWMPs) are designed to manage waste, improve environmental performance, help regulation and provide evidence to regulators and clients. Currently, site waste management plans can be voluntary codes of practice. However, legal requirements are rapidly changing in most countries, and legislation can be expected in the near future. Once site waste management plans become mandatory they are anticipated to apply to projects and will affect anybody in the construction chain. How such a site remediation project will be defined by this legislation is uncertain, but if site characterisation works are classed as part of major construction and demolition projects on radioactively contaminated sites then site waste management plans can be expected to be required, or adhered to as part of the management of a larger project.

2.9.3.1 Classification of non-radioactive waste

In most countries regulations exist for landfill waste dumps for pollution prevention and to control the non-radioactive waste disposal. These regulations will continue to develop and will have a significant impact on the management of wastes.
Main impacts on waste producers may be that:

  • Certain kinds of wastes cannot be sent to landfill for disposal (e.g., liquids, chemical substances arising from research and development which are not identified, and explosive and reactive materials);
  • Biodegradable wastes are to be increasingly diverted from landfills;
  • Landfills are classified according to whether they can accept hazardous, non-hazardous or inert wastes. Wastes may only be accepted at a particular landfill if they meet the relevant waste acceptance criteria (WAC) for that class of landfill; and
  • Most wastes must be treated before they can be landfilled.

The organization(s) that will take the responsibility for the wastes produced during site remediation should be identified at an early stage in the project. These are most likely to be the consultants managing the project, but in some circumstances it may be either the site-remediation sub-contractor or the site management.

The waste producer is responsible for ensuring that basic characterisation of the waste is undertaken to establish its key characteristics, as specified by regulations. In particular, details of the chemical composition and leaching behaviour of the waste may be required.

Once the waste is characterized, management options can be considered in accordance with the waste hierarchy. Waste minimisation, reuse, recovery and final disposal should be considered in that order. Where disposal by landfill is identified for all or part of the waste, the producer will need to consider appropriate treatment options.

In order to determine whether the waste is hazardous waste or non-hazardous waste the producer should first consult the national hazardous waste list (if existing) derived from the European Waste Catalogue. This may list all waste streams and may mark waste streams that are hazardous.

Having identified whether the material is hazardous or not, if the producer wishes to dispose of the material at landfill, further characterisation is likely to be required against the waste acceptance criteria (WAC) to determine if it is acceptable at a given landfill. The waste should then be periodically checked to ensure that those properties have not changed. When treated waste is consigned to a landfill, the landfill operator will carry out on-site verification at the site on each load to ensure that the waste is as described by the producer.
The full waste acceptance criteria consist of:

  • A list of acceptable inert wastes;
  • Leaching limit values; and
  • Analysis of various organic compounds including mineral oil, polycyclic aromatic hydrocarbons and polychlorinated biphenyl, as well as total organic carbons and/or loss on ignition.

For inert wastes there may be a list of acceptable wastes. If the waste is a single waste stream comprising waste on the list of acceptable inert waste, and uncontaminated by other materials, then it may be accepted at an inert landfill without testing. For wastes that may be inert, but are not on this list, testing must be undertaken against leaching limit values, and also limit values for other criteria, including total organic carbon, to demonstrate that it is inert.

There are no leaching limit values for non-hazardous waste, because the primary requirement is to ensure that the waste is not hazardous. For hazardous wastes there may be a hazardous waste list. If the waste is on this list then, if it is to be disposed of at landfill, it needs to be subject to leaching tests and meet the limit values and other criteria in order to allow it to be disposed of off-site. Guidance on definition and classification of hazardous wastes has been provided in Section 2.9.4.

2.9.3.2 Treatment of non-radioactive wastes

Waste destined for landfill must be subject to prior treatment. Landfill regulations may provide definitions of treatments from which the following test (the ‘three-point test’) has been derived. Any potential treatment must fulfill all of these three criteria, but need only meet one of the four objectives of the third point:

  • It must be a physical/thermal/chemical or biological process including sorting.
  • It must change the characteristics of the waste.
  • It must do so in order to:
    • Reduce its volume, or
    • Reduce its hazardous nature, or
    • Facilitate its handling, or
    • Enhance its recovery.

The waste producer makes the initial decisions about the management of their wastes and therefore in the best position either to treat or secure its treatment by others. If waste is to be sent to landfill after treatment then, depending on the treatment, testing to confirm whether the material should still be classified as hazardous waste must be carried out to establish its acceptability at landfill. Of particular relevant to site characterisation generated wastes is that simple physical dilution, without any concurrent chemical or physico-chemical changes, is not an acceptable treatment process. Therefore, the dilution of contaminated soil with other soils in order to lower the concentrations of contaminants of concern below those for hazardous waste is unacceptable. Mixing waste to achieve a physico-chemical change, in pursuance of the third criterion, may be acceptable.