Waste Management in the United Kingdom

FS II 89-408

Waste Management in the United Kingdom

by

Richard M acrory" and Sonia Withers

Prepared for the Wissenschaftszentrum Berlin für Sozialforschung.

sje

Centre for Extension Studies, University of Technology, Loughborough, Leicestershire.

Wissenschaftszentrum Berlin für Sozialforschung gGmbH (WZB)

Reichpietschufer 50, 1000 Berlin (West) 30

1. General Overview 3

1.1 Waste as an Environmental Issue 3

1 .2 Features of Waste Management in the UK 5

1.2.1 Major Influences 5

1.2.2 Characteristics of Waste Management 6 1.2.3 UK Waste Management: Strengths and Problem Areas 8

2. The Legal Framework 10

2.1 Development of Laws 10

2.1.1 The Main Laws 11

2.1.2 Implementation and Enforcement of Laws 15

2.2 Administrative Organisation 16

2.2.1 The Department of the Environment 16

2.2.2 Local Government 17

2.2.3 2.2.4

Other Central Government Departments and Official Agencies

Private Sector Organisation

19 20

2.3 Economic Instruments 20

3. Types of Waste and Disposal Options 22

3.1 Waste Classifications 22

3.1.1 Waste Statistics 23

3.1.2 Statistical Details 24

3.2 Disposal Routes 26

3.2.1 Landfill 26

3.2.2 Incineration 29

3.2.3 Marine Disposal 30

3.2.4 Chemical and Physical Treatment 30

3.2.5 Waste Exports and Imports 31

3.3 Public Participation 32

4. Recycling and Clean Technologies 34

4.1 UK Recycling Policy 34

4.1.1 Municipal Waste Recycling 34

4.1.2 Energy Recovery 37

4.2 Industrial Examples of Recycling 38

4.3 Clean Technologies 39

5 . Conclusions and Summary 40

References 43

1. General Overview

1.1 Waste as an Environmental Issue

Despite the growth of the service sector, the UK remains a predominantly industrial country generating significant quan­

tities of industrial wastes alongside increasing quantities of commercial and municipal wastes. In recent years consider­

able progress has been made in waste management, particularly in respect of hazardous wastes such that environmental stan­

dards of the best practices stand comparison with those of other EEC countries. Over 90% of waste arisings are disposed of by landfill, the disposal system being underpinned by a basically sound system of control. Despite the virtual ab­

sence of any significant pollution incidents offering threats to public health or the environment attributable to wastes, this has not prevented waste from becoming a subject of live­

ly public concern in the UK and one of considerable contro­

versy on the public agenda.

Public attention is often first aroused by the perception that wastes present a hazard or risk which is being inad­

equately addressed or imperfectly controlled. The concern ex­

pressed over the recent increases in waste imports, although small in actual quantity both in relation to UK total waste arisings and to the amounts of waste exported or imported by some European countries, is one example. Litter and flytip­

ping - illegal wayside dumping of waste - especially waste materials from building sites, are seemingly intractable problems where adverse public comment seems ill-relected in private or commercial practice. Public awareness of the h a z ­ ards posed by landfill gas was heightened following several incidents where seeping gas exploded, calling into question current arrangements for the long-term control of gas gener­

ation in landfill s i t e s . I n s t a n c e s of sub-standard practices have caused overall standards of waste disposal or of treat-

ment facilities to be questioned as have cases of contamina­

tion of land used in the past for waste disposal or for in­

dustrial purposes.

Such issues have overshadowed the undoubted success of p r o p ­ erly designed and operated landfill facilities that meet e n ­ vironmental protection standards and serve the purpose of re­

habilitating derelict land. The government view is that land­

fill which is properly designed, engineered, operated and monitored, is likely to continue to be an environmentally ef­

fective and acceptable method of waste disposal with the ad­

ditional advantage of reclaiming land for recreational or in­

dustrial use from exhausted mineral or quarry workings.

In the last century a degree of protection for the community from wastes was provided by the Public Health Act of 1 848.

Legislation to deal with the vast increase in industrial emissions was enacted later in the 19th century, but the first legislation specific to the management of "toxic"

wastes was not passed until the 1970’s. Controls were con­

siderably strengthened in the late 1 9 4 0 's by the enactment of land use planning legislation which required prior authoris­

ation of any change in existing land use for whatever p u r ­ pose, including the creation of new waste disposal sites.

In recent years a number of official and Parliamentary in­

quiries have commented on country wide variations in stan­

dards of enforcement and control. Many of the policy p r o ­ posals now emerging are therefore aimed at tightening up the existing framework of controls. This will exert pressure on licence holders and regulatory authorities who do not meet adequate standards to mend their ways. In the long-term it will ensure an overall improvement in professional waste m a n ­ agement standards including site after-care and restoration.

In the UK local government has traditionally assumed the prime responsibility for waste regulation, successfully ad­

dressing issues of local accountability and in preventing, largely through landuse planning, a legacy of large-scale abandoned dumps of the type seen in some other countries.

There is now debate as to whether central government should not take a direct role in regulation, under a more clearly defined central strategy. Central government's view is that the disposal of wastes is a business opportunity which should be operated with due regard for environmental and human health protection but without the support of government sub­

sidies. Whilst recognising the community aspect of waste col­

lection and disposal authority operations would be required to run on business principles.

1.2 Features of Waste Management in the UK

1.2.1 Major Influences

A profound influence on the development of the UK system of waste management has been the long established industrial tradition, and attendant industrial waste and effluent g e n ­ eration. Disposal of these wastes has been inevitably in­

fluenced by the geography and geology of the UK. Geographi­

cally, the UK is an island sharing no land frontiers or river systems with other countries, apart from the Republic of Ire­

land, an island moreover where the relatively short and fast flowing rivers discharge direct into the sea. This feature has allowed the regenerative capacity of rivers to be util­

ised and, it must be said, at times overburdened. UK geology and hydrogeology are such that even though exploitation for landfill has been and remains the dominant disposal option for solid wastes, and some liqued wastes (Section 3), the country has suffered only relatively minor water resource contamination or contaminated land problems.

Custom and practice have also experted and continue to exert a powerful influence on waste management in the UK where the long history of pollution control legislation predates the quantum increase in industrial activity brought about by the industrial revolution in the 18th century. And act prohibit­

ing the unconfined burning of coal in London in 1273 is p o s s ­ ibly one of the earliest examples of measures taken curtail air pollution. Subsequent and successive legislation to p r o ­ tect the environment has allowed a complex web of legal and administrative mechanisms (Section 2) to build up over the years. The continuity of environmental controls, inadequate though early laws may appear by the standards of modern waste management legislation, has been a major factor in protecting the UK from the legacy of unkown, abandoned disposal sites found in many other countries.

1.2.2 Characteristics of Waste Management

Shaped by such diverse influences, UK waste management has developed characteristics that reflect national political, social, ecological and technological factors. One striking feature is the dominant role of local government despite the ever-growing body of legislation and increasing technical complexity of waste management.

Central government's objective is that waste should be m a n ­ aged at the lowest possible resource cost to the community consistent with environmental protection and according to ad­

ministrative and regulatory procedures laid down in the legislation. All direct regulation of wastes is delegated to local authorities, with central government being responsible for developing legislation, auditing the local authority re­

gulatory function and the provision of technical advice.

In the UK, there is no documented national strategic plan for wastes, nor does central government interfere in local government strategic decisions concerning waste disposal in its area. Central government does not direct how or where particular wastes should be dealt with, or use economic in­

struments such as subsidies or other fiscal measures to in­

fluence disposal methods. Treatment or disposal decisions are currently made by the waste generator in keeping with legis­

lative requirements and taking account of central govern­

ment's technical advice.

Nationwide, no shortage of sites which can be engineered to be technically suitable for landfill in compliance with the demands of increasingly stringent environmental standards, is envisaged, even though the UK is relatively small in area and densely populated. Landfill is expected to remain the primary route of disposal for the majority of wastes in the forsee- able future.

In addition to the public sector landfill sites operated by all local authorities, a large number of private enterprise sites operate under licence conditions set by local auth­

orities. The latter own all UK treatment plants, handle most of the difficult wastes and also a proportion of municipal and non-hazardous industrial waste.

An expression of the democratic process is the period of con­

sultation to which draft legislative proposals, reviews of existing legislation or the wording of new regulations, are subject. Central government invites views from all interested parties who may typically be local government officials, waste generators, private enterprise site operators, special

interest groups, or individuals.

1.2.3 UK Waste Management: Strengths and Problem Areas

Foremost of the strengths of the UK system of waste manage­

ment is the longstanding requirement of prior land use plan­

ning permission for any waste treatment or disposal activity, interlocked with a site licensing procedure that takes due account of water quality protection. Planning permission and site licensing regulate both the locations where and the con­

ditions under which waste may be treated or deposited and provide a permanent record of all such operations.

Also, a structurally sound legal framework exists for the control of wastes by local government regulatory forces, who it is argued, have local knowledge of waste producing, waste treatment and disposal activities. Futhermore, they are ac­

countable to local councillors freely elected by the com­

munity .

Finally, for the purposes of control, no distinction is made between hazardous, industrial, commercial or municipal wastes. All such wastes are termed Controlled Wastes regard­

less of origin or content. Additional cradle to grave con­

trols are applied to difficult wastes requiring special care on account of the hazards they present.

Weaknesses in the UK waste management system are the reverse side of the coin. The extent of devolution of regulation to local government level is such that there are no published mandatory national standards for landfill disposal sites, for example, landfill gas production and migration, site engin­

eering requirements, or the monitoring of leachate quality.

On these and related matters, central government technical publications are guidelines that do not have the force of law.

Inevitably, the structurally sound legal framework is not always fully exploited or properly applied. Local authorities vary greatly in size, in expertise and in the resources they devote to waste management. Dramatic differentials exist b e ­ tween site licencing conditions imposed by various auth­

orities as well as between inspection and monitoring stan- dards or enforcement strategies. 2

Where local authorities operate their own landfill sites, these are often in competition with private sector disposal operations. It has been demonstrated that overall operational standards can suffer from distorted competition resulting from local authority uncommercial disposal pricing policies.

Reliance on standard setting by the waste producing industry, the lead local authorities, or on self-regulation by trade or professional bodies, has not yet proved successful in con­

trolling the maverick element of the waste generating or operating industry.

Structural and administrative changes already introduced or proposed for local authorities profoundly alter the scope of their responsibilities. Their impact on waste management has not been fully appraised.

Consequent on the EEC directive to decrease permitted levels of contaminants in groundwater, some currently acceptable UK landfill sites may have to be upgraded. Monitoring the effec­

tiveness of remedial work however will be complicated by p r o ­ posed changes in national water pollution control arrange­

ments .

Of the problem areas which are current environmental issues, the continued rise in waste imports which has aroused much public and media concern, is at variance with the government and the waste industry's view that imports represent a busi­

ness opportunity. A strategic decision by the government to

control imports is likely. Concern over the hazards presented by landfill gas migration is exemplified by the estimate that some 1,300 active and closed landfill sites - there are cur­

rently some 4,000 active sites - appear to have made inad­

equate current or future provision for landfill gas control.

2. The Legal Framework

2.1 Development of Laws

In the UK, during the 19th century and the first half of the 20th century, problems arising from poor waste disposal prac­

tices were controlled by a variety of nuisance and public health laws. Applied by local authorities and largely r e ­ active in nature, these foundations stemmed from efforts to curb and control the widespread pollution from industrial e f ­ fluents and hazardous wastes following the industrial revol­

ution. 1947 saw a key change in approach with the additional introduction of a comprehensive land-use planning system r e ­ quiring prior planning permission for new developments, in­

cluding sites used for waste treatment and disposal.

These controls remain in force, but by the late 1 960s were officially recognised as insufficient in themselves and needed to be supplemented by specialised forms of regu- lation. The issue, however, remained low on the political agenda until a series of highly publicised illicit waste dumping incidents, discovered by conservation groups, forced the government in 1972, to rush through in three weeks, the first legislation specific to waste disposal.

This law was expanded into the current basic framework for site licencing now contained in Part I of the Control of Pol­

lution Act, 1974. These provisions provided a model for the

first EEC Directive concerned with waste, the 1975 Framework directive - a rare example of Britain playing an enthusiastic and positive role in EEC environmental policy development.

2.1.1 The Main Laws

Despite a highly complex array of laws which often interlock and overlap, in the UK regulation is essentially based on a system familiar in many European countries: the licencing, monitoring and inspection of individual treatment and dis­

posal facilities, with special controls over the movement of wastes deemed to be particularly difficult or hazardous. R e ­ sponsibility for the application and enforcement of controls is decentralised to local authorities. Central government r e ­ stricts itself to an audit and advisory role and, in common with much of British pollution control law, the legislation is silent on mandatory environmental standards or strategic principles such as obligations to re-use a waste or to follow a specific disposal route. It concentrates on setting out basic procedural requirements such as the need for a licence to operate a waste facility and the assignment of general r e ­ sponsibilities. Properly applied - a main concern at present - the present legal controls provide an effective and com­

prehensive basis for regulation.

f a ) S ite L i c e n c i n g

Any treatment or disposal facility, such as a landfill site, transfer station or incinerator, requires individual land-use planning permission under the Town and Country Planning Act, (TCPA). Where it involves domestic, industrial or commercial waste, in law described as "Controlled Waste", a site specific licence under the Control of Pollution Act 1974, (COPA) is needed. The same local authority is responsible for

issuing both permits (with a right of appeal by operators to central government), and applications are often handled con­

currently. Land-use planning controls focus on the suit­

ability of land from locational and amenity perspectives of new or extended facilities. Since there is no general right to develop land, each application is treated on a case by case basis and the process provides the principle focus for public attention and participation.

The TCPA controls determine whether a paricular site should be used for any type of waste facility, and also provide the main basis for regulating agricultural and mining wastes which are excluded from the COPA system. For Controlled Wastes the additional requirement of a COPA site licence is the main means of regulating engineering, operational and post-closure aspects of the facilities (again with an appli­

c a n t s ’s right of appeal to central government if dissatis­

fied) . It should be stressed that these fundamental COPA p r o ­ visions make no distinction as to a waste's origin or between those deemed to be hazardous or non-hazardous. To dispose of Controlled Waste without a site licence or in breach of licence conditions is a criminal offence. The law gives com­

plete discretion to local authorities concerning the condi­

tions they impose and since only licence applicants have the legal right to appeal to central government against unsatis­

factory conditions, the present arrangements provide few means of reviewing the actions of lax authorities.

Local authorities often operate their own waste disposal facilities. The above controls apply to such facilities and the law permits the authorities to licence themselves. D e ­ spite a general legal obligation to comply with their own re­

quirements, thus there is justified scepticism as to the e f ­ fectiveness of such a system of self-regulation, and cer­

tainly not all authorities play fair.

(b ) M o v e m e n ts o f W a ste s, I n c l u d i n g Im p o r t a n d E x p o r t

The 1980 Special Waste Regulations of COPA came into force (in 1981) to permit local authorities to monitor the m o v e ­ ment, from generation to ultimate disposal, of shipments of wastes designated by the regulations as particularly hazard­

ous. The controls, effected by a complex consignment note system, are intended to provide advance warning of movements of these wastes so that stray consignments failing to reach their authorised destination can be tracked. The actual transportation of wastes are covered by controls applied gen­

erally to the transport of dangerous goods and substances.

As to waste imports and exports, the legal controls reflect current central government policy that transnational trade in waste offers a business opportunity which is unexceptional provided there is effective monitoring and supervision.

Special Waste imports have been subject to the consignment note system and in 1988, additional controls over the import and export of defined categories of hazardous waste were introduced to implement the 1984 EC Directive on the Trans­

frontier Shipment of Wastes.

The regulations require importers to provide 28 days notice of the shipment and the intended disposal facility, in order to allow the relevant local authority to raise objections if the disposal would be contrary to legal requirements. Under the same regulations, any export of hazardous wastes to non- EC countries requires central government consent which will not be granted without the written agreement of the country of destination.

Non-hazardous wastes such as municipal waste which fall out­

side the above categories are not subject to any specialised waste laws though such wastes may be caught by public health controls. Unfavourable and mainly local public opinion rather

than legal controls, has been the main deterrent to a number of recent private sector proposals to import large amounts of municipal waste for disposal in the UK. More explicit laws which restrict waste imports to those which require pretreat­

ment, have been announced.$

fc ) O th e r S p e c i a l i s e d C o n tro ls

In addition to TCPA and COPA permits, industrial incinerators are regulated under air pollution controls enforced by the central government through Her M a j e s t y ’s Inspectorate of P o l ­ lution (HMIP). The current law imposes only a general duty on operators to reduce and contain emissions, with HMIP provid­

ing authoritative guidance on best practice including emis­

sion standards. Similarly, current law concerning emissions from municipal incinerators contains no numerate standards though these are likely to be introduced for all incinerators following EC proposals.

As a result of an international policy agreement reached in 1987, disposals of waste at sea are gradually being phased out as a disposal option. Such disposals currently require licences from the Ministry of Agriculture, Fisheries and Food. Central government also controls the disposal of radio­

active wastes by means of a licencing system under special­

ised legislation.

(d ) D is p o s a l P la n s

Although there is no national written strategic plan concern­

ing wastes, COPA requires each designated local authority to draw up a formal Waste Disposal Plan covering waste arisings within their area, present and future disposal capacity and options. These plans, however, have little legal significance

which goes some way to account for the small number - 23 out of 79 authorities, who have completed their plans in 12 years. Central government now intends to secure completion of the remainder by the end of 1989.

2.1.2 Implementation and Enforcement of Laws

A theme of a number of recent reports has been that while the UK legal framework is conceptually sound, implementation and enforcement of the legislation by the local authorities re­

main extremely variable across the c o u n t r y . L o c a l government expertise in waste management varies for many reasons: the resource priorities, the population served, the terrain, local industry wastes and the politics of the elected council members. Variation in enforcement standards, and practice can also reflect differing internal administrative structures or even the personalities of key officers.

One particularly worrying issue is the adequacy of super­

vision local authorities provide for their own (i.e. public sector) sites. Such facilities are not necessarily subjected to the same degree of supervision as those in the private sector which it is their duty to monitor and inspect. Differ­

ing approaches towards enforcement are another area of con­

cern. Whilst there exist technical difficulties in proving offences under current laws, some authorities are more ag­

gressive in taking legal proceedings than others. Even where criminal prosecutions are brought, generally by the local authority, courts have often imposed low penalties, though again there are variations m practice. 7

The higher public profile given to the subject of waste dis­

posal in recent years has and is likely to continue to place political pressure on central government to take steps to en­

sure consistent and vigorous national standards of enforce­

ment .

2.2 Administrative Organisation

2.2.1 The Department o f the Environment

In England, the Department of the Environment (DOE) is the arm of central government most concerned with waste disposal, with equivalent central government Departments existing in Wales, Scotland, and Northern Ireland. The DOE, though, exercises little direct control. It does not, for example, licence or operate any waste disposal facilities itself. It does not play a direct enforcement role nor insist on p a r ­ ticular disposal routes for certain wastes. This is not to say that central government does not influence the overall system but its policies and priorities will be channelled down via a variety of less direct routes.

The DOE's main functional roles at present are to develop and promote legislation, to conduct international negotiations (especially with the EEC), to commission research, to hold and determine administrative appeals and to publish technical and advisory material. These last two activities in particu­

lar, can influence the direction of waste management policy and practice.

Increasing awareness of the technical complexity of waste management and the potential hazards which wastes pose to people and the environment, reinforced by involvement in EEC policy-making, has forced the DOE to take a more explicit role in recent years. This development goes against the grain of the philosophy of the present central government which has been to lessen the burden of regulation of industry and to reduce public sector expenditure. Yet despite real concern that DOE current staffing levels and resource allocation are inadequate for its waste management responsibilities, the trend towards greater centralisation seems likely to grow.

In 1981, a small Hazardous Waste Inspectorate (HWI) was set up within the DOE. Dealing initially only with hazardous waste, H W I ’s role was to audit current practice and provide expert advice, but its unusually critical and highly publi­

cised Annual Reports on the state of UK hazardous waste m a n ­ agement gave the issue of waste disposal a particularly high political profile.

IN 1987, the HWI was subsumed into a new inspectorate located in the DOE, called Her M a j e s t y ’s Pollution Inspectorate (HMIP) and its remit broadened to include all Controlled Waste. Apart from the direct regulation of industrial in­

cinerator emissions, HMIP functions still remain advisory in the field of waste management. Significantly, though, central government, in 1988, proposed that HMIP should take over direct responsibility for pollution control in respect of certain classes of industry, including processes generating large amounts of Special Wastes - the first time central government would have exercised control over generators of such wastes. One of the aims is to ensure that waste manage­

ment be considered in the round from the outset of the design of a p l a n t .8

2.2.2 Local Government

As indicated in 2.1.2, elected local government bodies play the primary role in the application of the controls for waste treatment and disposal. Under the Control of Pollution Act, specific local authorities are designated W aste D is p o s a l A u t h ­

o r i t i e s CWDAsJ, responsible for granting or refusing all li­

cence applications for waste disposal treatment or disposal facilities, enforcing controls and operating facilities them­

selves. With the creation of W D A s , waste management functions were taken on by a large number of existing local authorities in addition to their other responsibilities, and in 1986 a

complex reassignment of waste disposal responsibilities in England, generally to a lower level, followed central govern­

m e n t ’s abolition of the higher tier of local government in seven major conurbations. There is now considerable concern that the existing structure of local bodies is ill-matched to current demands of waste management and regulation, and some discussion as to whether the situation would be improved by the establishment of single-purpose regional or local waste disposal agencies along the lines of the Water Authorities (WAs), who were set up to deal with water management and water pollution control.

F ig u r e 1 : W aste D is p o s a l A u t h o r i t i e s in th e UK

E n g la n d Non-metropolitan Areas 39 County Councils

Metropolitan Areas 41 District or Borough Councils London + 6 major conurbations + some co-ordination bodies W ales

S c o tla n d

37 District Councils

56 District/Island Councils

N o rth e r n I r e l a n d 28 District Councils

Local authorities are also the C o lle c tio n A u t h o r i t i e s with re­

sponsibility for ensuring collection of domestic and trade waste. Apart from England, the same level of local authority acts both as Disposal and Collection Authority, but in E n g ­ land the collection function has been assigned to a lower level of local government - a split arrangement that some have criticised as tending to inhibit recycling and other initiatives demanding separation at source, since the col­

lection authority is likely to be concerned solely with ef­

ficient collection for transfer to the disposal authority rather than with effective waste management and the possible reduction of waste arisings.

2.2.3 Other Central Government Departments and Official Agencies

Aside from the DOE, two other departments of central govern­

ment have waste management responsibilities. The Ministry of Agriculture, Fisheries and Food (MAFF) is responsible for licencing the disposal of sewage and other wastes at sea.

Less directly MAFF can play a role in developing policies to minimise problems arising from agricultural wastes. The De­

partment of Trade and Industry (DTI) takes the lead respon­

sibility for co-ordinating recycling and reclamation policy, a change introduced following strong criticism in 1984 that the issue was ineffectively handled because it fell within the remit of several different departments.

There are two further official bodies of importance. The Health and Safety Executive (HSE), a central government agency independent of policy departments, is responsible for developing and enforcing legislation concerning health and safety at work. They have extensive powers of inspection and enforcement over management practices affecting health and safety at waste facilities. WAs whose responsibilities in­

clude the protection of all surface and ground water, are consulted by WDAs at the site licence application stage. A

q

recent survey concluded that where landfill was concerned, WAs were felt to exert a stronger influence on WDA policy than any other external influence.

Central government proposals for to privatise the water in­

dustry include the creation of a National Rivers Authority responsible for controlling inland water pollution. Whether these new arrangements will jeopardise the existing inter­

action between waste and water authorities is not yet known.

2.2.4 Private Sector Organisation

In the UK, private waste treatment and disposal enterprises dominate many areas of waste transportation and disposal, particularly for hazardous wastes, as Section 3 below in­

dicates. At one end of the spectrum are responsibly managed companies both large and small, operating in a legal and often sophisticated manner; at the other end are numbers of small and sometimes semi-criminal contractors who operate without due regard for the law. An on-going policy p r e ­ occupation is how to eliminate these "cowboy" elements w i t h ­ out introducing too many bureaucratic controls. As yet, dis­

posal sites are licenced to the person who is going to use the licence, though current proposals are to introduce a re­

gistration system for waste carriers including those in- volved in the transportation of waste. 1 0

It is also proposed to place an explicit legal duty on care of producers and holders of wastes to ensure their legal disposal or reclamation; i.e. that wastes are removed by reputable contractors to authorised sites. Over two thirds of those involved in private sector waste treatment and dis­

posal belong to two national trade associations one of whom has published a "voluntary code of practice". But neither have formal supervisory powers nor do they yet see them­

selves as exerting an informal policing role on their m e m b e r s .

2.3 Economic Instruments

In the UK, the annual turnover of the waste business has been estimated at t 5 billion and growing. Central govern­

m e n t ’s underlying economic approach is that waste producers should pay for the full costs of disposal in line with the

"polluter pays principle", but should have the opportunity

to seek the lowest cost disposal option under unsubsidised and competitive market conditions operating within a frame­

work of effective control. Central government is resistant to any form of direct public subsidy whether for reclamation or recycling, or for particular forms of waste treatment or disposal options. Properly sited, engineered and operated landfills remain the cheapest and therefore the most common disposal route for most types of waste.

UK landfill charges average fc 5.0 per tonne (and prices as low as t 2.0 per tonne have been quoted), rarely rising above t 5.5, compared to fc 25.0 per tonne in France or West Germany and in places where landfill sites are at a premium in the United States, t 70.0 per tonne for municipal wastes.

In contrast, the cost of incinerating hazardous wastes in the UK ranges from E 120 to t 2,000 per tonne depending on the waste. Central government has acknowledged that the low level of charges "implies that the correct level of m a n ­ agement is not being applied to landfill practices". Not only do variations in operating standards and enforcement distort competition, but the situation is exeerbated by WDA facilities operating in the same market, using different ac­

counting procedures and possibly subsidizing costs from other local government revenue.

The role of private waste management enterprises within a free market as a continuing feature of the UK system is likely to increase, with the private sector assuming greater responsibility for municipal waste disposal, though not yet to the same extent as in France. Central government is con­

cerned to ensure that charges for disposal reflect true costs. The private sector will in future be required to pay the costs involved in granting and monitoring site licences;

the public sector will have to put out to competitive tender all services, including waste collection and disposal,

whilst both sectors will be subject to an equal level of supervision and control.

When these measures are introduced, costs of landfill will inevitably rise - the DOE has estimated that charges will almost double if these were to finance the required standard of engineering, management, restoration and aftercare. None­

theless, landfill will still remain economically the most attractive disposal option for most forms of waste. Various modest though potentially significant central government initiatives are aimed at raising general standards. An annual grant of t 150,000 goes to the Recycling Advisory Unit established at the DTI in 1987, and increased funds to stimulate research and technical innovation will be chan­

nelled through the recently set up DOE Environmental Tech­

nology Scheme.

3. Types of Waste and Disposal Options

3.1 Waste Classifications

In the UK, no official definition of " h a z a r d o u s " in a waste management context has been formulated, and the term has no legal significance. Neither do the terms to x ic w a s te , c h e m ic a l w a s t e , or d a n g e r o u s w a s te currently have precise legal mean­

ings since the view is taken that potential hazards arising from wastes depend on the situation of the waste as well as on its properties. The various classifications used to de­

scribe waste in the UK for legal or administrative purposes refer for convenience to the source of the waste rather than to its characteristics, a procedure which can give rise to misconceptions about the nature of certain wastes. For example, a large proportion of industrial waste is inert but the classification, "industrial waste" is often perceived to

be synonymous with ’’hazardous waste". The Royal Commission commented in their 11th Report^ that the term "chemical waste", sometimes used in EEC documents, has mistakenly and, in their view unfortunately, given rise to the belief that

"chemical" is, ip s o f a c t o , hazardous and that therefore only the chemical industry makes hazardous waste.

The basic legal distinctions made in the UK under the Con­

trol of Pollution Act, are between Controlled Wastes, (pri­

marily industrial, domestic and trade waste) and their sub­

set, Special Wastes. The latter comprise a list of named classes of chemical compounds considered difficult or dangerous to dispose because of the potential hazards they pose to human health. Current proposals are to add five new classes of Special Wastes identified as having potential to cause environmental damage which will bring the UK classifi­

cation of wastes needing special care more in line with EEC thinking that both the possibility of harm to people and damage to the environment must be taken into account.

3.1.1 Waste Statistics

Controlled Wastes are not subject to measurement by the d i s ­ posers, therefore the total quantity generated in the UK in any year can only be estimated. A degree of statistical u n ­ certainty when computing total UK waste generation from all sources is therefore inevitable. The statistical uncer­

tainties concerning Controlled Wastes are compounded by d i f ­ fering practices such as the use of non-uniform conversion factors from volumetric measures to weight; the double counting of some hazardous wastes sent for treatment when the non-toxic residue is ultimately landfilled; the separ­

ation of wastes for recycling from mixed loads sent through transfer stations; and the fact that the weight of many loads is estimated since only a minority of waste generators

and waste disposal facilities are equipped with weighbridges actually to weigh the waste.

All WDAs are required to keep records of Special Wastes by documenting their copy of the consignment note giving ad­

vance notification of the intended movement of such waste, but implement this requirement in a variety of ways. Some authorities additionally record wastes classified by them as hazardous, using a categorisation under legislation now repealed.

3.1.2 Statistical Details

Figures taken from the Royal Commission 11th Report show the proportion of wastes from each sector that contributes to an estimated total of waste arisings from all sources, in the UK, of just under 500 m tonnes per year. Disposal routes for the estimated 150 m tonnes annual arising of Controlled Wastes are shown in F ig u r e 2 .

F ig u r e 2

1.6% Incineration

7%

5*« D itp o u l

0-3% Daap burial.

/

HMIP (then the Hazardous Waste Inspectorate), who - it should be noted - have no statutory right to demand statis­

tical returns from local authorities, estimated total hazar­

dous waste arisings in England and Wales during 1986 at 3 . 9 m tonnes of which Special Wastes accounted for about 1.58 m tonnes. Comparisons with 1 984 and 1 985 are given in F ig u r e s 3 a n d 4.

F ig u r e 3 : W aste A r i s i n g s 1986187: H a za r d o u s a n d S p e c ia l W astes

F ig u r e k : W aste A r i s i n g s 198k - 1986: H a za r d o u s W aste

3.2 Disposal Routes

3.2.1 Landfill

Disposal to land, the predominant waste disposal route, in­

cluding the direct deposition of wastes such as mineral or agricultural wastes not consigned to engineered waste dis­

posal sites, accounts for about 88? of all wastes in England and Wales and 971 of the total amount of waste generated in Scotland.

According to DOE estimates 1 3, approximately 100 m tonnes of Controlled Wastes are generated each year of which over 90?

is landfilled. 80? of that amount, i.e. some 72 m tonnes, is dealt with by the Waste Disposal Authorities. Of the 3.9 m tonnes of hazardous and Special Wastes generated in 1986/7, about 79? were disposed of by direct landfill, almost en­

tirely at private sector sites. This compares to 91? and 85?

in preceding years. 1 2 If the 3.0? of hazardous or Special Wastes which are treated prior to landfilling by solidifica­

tion, and the 1? disposed of to mineshafts are taken into accont, then 83? of hazardous wastes were disposed of to landfill in 1986/7.

Controlled co-disposal is practiced in the UK whereby certain mainly liquid, industrial or difficult wastes are co-disposed with municipal or dry industrial wastes in engineered landfills. The technical justification for this technique is based on results from a DOE funded research programme which suggests that co-disposal, through physical, chemical and natural biodegredation, renders such wastes environmentally acceptable. Co-disposal is operated at some fifteen major sites.

Emphasis of DOE commissioned research for which the current annual funding is L 2m, into technical aspects of Controlled Waste management, remains focussed almost entirely on land­

fill.14 Results from this research has increased understand­

ing of landfill biodegredation and attenuation processes. A not inconsiderable research programme was also undertaken by some lead private sector companies. One consequence was that both landfill administrative systems and operational tech­

niques have been considerably developed and improved in recent years.

Included in the DOE research programme are pilot-scale studies into composting but so far, this disposal method is seen generally as a higher cost alternative requiring the elimination of heavy metals from the waste before its de­

position on land, a situation which is reflected in the fact that currently only one such composting plant is in oper­

ation .

Experience in the UK has shown that landfill carried out to a high professional standard can result in environmental benefits, the most obvious being the reclamation of derelict land or former mineral workings for beneficial use. Public acceptance of the landfill operation is generally positive if certain conditions are met. These are that the site en­

gineering and disposal operation is carried out to high technical standards and every opportunity is taken to inform and involve the general public in the vicinity. The public generally respond positively to a policy of open management.

When, as all too often, neither good landfill precepts nor the opportunities afforded by the system of controls set up in the UK to licence, monitor and control landfill sites, are fully utilised, expressions of public dissatisfaction quickly follow.

There is no doubt that the sub-standard nature of some land­

fill operations in the UK have given rise to wide media antagonism and public apprehension about this method of dis­

posal. Examples of dramatically bad practice are presented

as, or may be perceived to be the norm. Although blackspots do exist, it is our view that, unfortunately but not unex­

pectedly, their impact on the public is far greater in ex­

tent than the number or seriousness of recorded pollution incidents would appear to warrant.

The DOE stated that in only a few instances in recent years has waste disposal led to significant environmental pol- lution. 1 3 It is recognised that the technology is still evolving which in part accounts for some of the problems which are being experienced. For example, although much has been learnt about leachate generation and control, there is still some uncertainty about the long-term environmental ef­

fects from leakage.

An additional t 1/2 m has been allocated by the DOE specifi­

cally for research into landfill gas migration and HMIP have drafted a tough set of recommendations for landfill gas con­

trol. It is estimated that over 60% of the 1,300 currently active landfill sites and 75% of those closed in the last ten years, are generating gas in sufficient quantities to require continuing professional surveillance. However, there appears to be confidence that landfill gas is a problem now under control.

For landfill to retain its pre-eminence, practices will u n ­ doubtedly alter in line with improved understanding of the standards which have to be met as well as in response to changes in waste composition and quantities consequent on the expansion of new high technology industries and the diminution of the UK's traditional manufacturing base.

The official view is that direct landfill will continue to be the environmentally most desirable, practical and econ­

omical method for the disposal of the majority of wastes.

Nationally, no shortage of sites suitable for engineered

landfills (mainly the rehabilitation of former mineral w o r k ­ ings) is foreseen for waste arisings for several gener­

ations . $

3.2.2 Incineration

Public concern in the UK regarding waste incineration centres mainly on the risks from incinerator stack emis­

sions, particularly dioxins and hydrogen chloride from the burning of certain plastics. In England and Wales, 10% of household and commercial waste, amounting to 2 m tonnes a year, is incinerated in local authority facilities. Stricter regulation of emissions has caused the closure of some facilities which either lacked stack scrubbing facilities or needed upgrading to run at temperatures higher than 850 C hitherto considered adequate for plants of this type. It is estimated that about a further 35 incinerators need m o d i ­ fication .

In 1986/7, some 63,000 tonnes (about 1.6%) of hazardous wastes were incinerated at land based plants, about the same proportion as in 1985, at three commercial facilities oper­

ating close to capacity. Planning permission for the first of a new generation of rotary kiln and liquid injection in­

cinerators has been obtained to augment or replace existing fixed hearth incinerators. Three new facilities are planned, which should provide a total incineration capacity suf­

ficient to remove fears of the improper landfill of inciner- able wastes. Some 60 chemical waste incinerators are on-site facilities associated with process plants.

3.2.3 Marine Disposal

Marine disposal, currently the second most used disposal route in tonnage terms for hazardous wastes, is planned to be phased out according to the agreement reached at the Sec­

ond International Conference on the Protection of the North Sea, London, 1987. In 1986/7, in addition to approximately 10m tonnes of sewage sludge, about 579,000 tonnes of waste half of it estimated to be hazardous, were dumped at sea and 3,754 tonnes incinerated at sea; in total some 7.6% of UK hazardous wastes. Marine incineration has operated under international control exercised through the 1972, Oslo and 1975, London, Dumping at Sea Conventions. However, consider­

able pressure to cease this method of disposal was brought to bear at the 1987 London Conference. Marine incinerators operate without the necessity for a scrubbing system to clean the stack emissions and thus have an in-built commer­

cial advantage over land based facilities. But at the London Conference strong doubts were expressed about the waste de­

struction efficiency of marine incineration and possible ecological damage from the unscrubbed emissions.

3.2.4 Chemical and Physical Treatment

It was noted under 3.1, that included in the amounts of waste consigned to landfill in the UK, were wastes subjected to chemical fixation by various solidification processes.

Prime considerations for wastes treated by this method are to ensure the physical stability of the treated waste through complete solidification, and that no fraction of the waste leaches out of the solidification matrix. For liquid wastes deposited in underground cavities such as mine shafts, integrity of the diposal site and the isolation of the waste from groundwater, are the primary concerns.

Other forms of chemical pre-treatment which are practiced such as neutralisation, oxidation or reduction to render a waste environmentally acceptable for landfilling, often coupled with physical treatment to de-water the wastes to reduce their volume, are applied to about 0.8% of corrosive or reactive wastes. If all types of chemical pre-treatment other than solidification are taken into accout, the esti­

mated total throughput at some 16 treatment plants ap­

proaches 700,000 tonnes a year, approximately 40? of their estimated total capacity.

In the competitive free market waste disposal economy which prevails in the UK, the long-term viability of chemical treatment must remain in jeopardy whilst the direct landfill of such wastes in their untreated form is allowed. This is reflected in the relatively small quantities of waste which undergo pre-treatment.

3.2.5 Waste Exports and Imports

A significant transfrontier trade has developed in exporting wastes for recovery (Section 4), but as far as can be as­

certained, the UK does not export hazardous/special wastes for final disposal other than the small quantity of very toxic materials sent for container storage in salt mines in Europe. Public indignation at reported attempts to dump UK wastes in Africa was superseded by mounting concern over waste imports into the UK, reinforced by media statements that the UK was becoming the "Dustbin of Europe".

To put waste imports into context, F ig u r e 5 shows waste im­

ports 1981 - 1986.

F ig u r e 5 : W aste Im p o r ts 1981 - 1986

In 1986/7, some 53,000 tonnes of hazardous or special wastes, over 802 of them from other EC Member States, were imported for treatment or incineration and some 130,000 tonnes for landfilling. Public concern appears to focus on the lack of clear legal powers, or indeed the government's wish, to prohibit the import of special wastes for which there are adequate UK treatment facilities. However, the government has responded to public pressure by putting for­

ward a consultation paper proposing waste disposal law amendments that would limit non-special waste imports.

3.3 Public Participation

At present in the UK, the only formal public participation is when planning permission is sought for individual waste disposal or treatment sites. At that stage the Waste Dis­

posal Authority (WDA) has to seek public comment. Local authorities must also publish their draft strategic plans for dealing with waste in their area for public comment.

Site licences, once granted, are placed in public registers open to inspection.

Three main forms of informal public participation in waste matters can be distinguished. Participation by public re­

sponse to media publicity concerning waste incidents can in­

duce a government reaction. We have already noted that the first legislation specifically directed at hazardous wastes resulted from this type of public participation. Another example are the new proposals to tighten controls over waste imports at the port of entry. $ The second form of partici­

pation comes about through the strong time honoured UK tra­

dition of consultation. Consultation Papers, which are cen­

tral government publications, often specifically invite the views of industry and of local government who, along with special interest groups and individual members of the p u b ­ lic, may comment on the proposals. Anyone is at liberty to submit comments to Parliamentary or government appointed committees such as the Royal Commission, in the form of evidence to these bodies.

The third form of public participation was noted in a 1984 R e p o r t ^ which pointed out the value of public enquiries as a means of ensuring public debate. To that recommendation may be added the value of involvement in waste issues at local level by councillors responding to constituents' con­

cerns at local council meetings, or by members of the public at open public meetings. Where strategic decisions which have implications that go beyond local considerations are concerned, such as the first time planning permission granted for a new generation of rotary kiln incinerators, local public influence on the outcome is less certain.

4. Recycling and Clean Technologies

4.1 UK Recycling Policy

In the UK, the government’s belief is that recycling is the most environmentally beneficial waste management practice but that it must be economic if resources are to be allo­

cated efficiently. This view is in line with the govern­

m e n t ’s policy of no direct intervention as to preferred methods of waste disposal or financial support for particu­

lar processes. Opportunities for recycling, including re­

source recovery, therefore have government approval but there is as yet little evidence of an outspoken commitment to produce a vigorous recycling industry that takes environ­

mental benefits into account when considering economic fac­

tors. In general, respective decisions are made on a stricly commercial basis.

Pressure from many sources, including industry, environmen­

tal groups and the general public, led the government to set up an interdepartmental committee co-ordinated by the D e ­ partment of Industry (DTI) to promote recycling. Official encouragement is by means of a campaign to increase aware­

ness including a series of "Commitment Conferences" which when completed will have covered glass, plastics, paper and oil. The modest funds of fc 1 50,000 are available for re­

search and for pilot schemes on the basis that industry in its own self interest is involved. The Warren Spring Labora­

tory of the DTI carry out research on recycling and provide technical advice to industry through its Recycling Unit.

4.1.1 Municipal Waste Recycling

The 1984 Parliamentary Report "The Wealth of W a s t e " ^ esti­

mated that in 1983 some 20 m tonnes of waste were generated

in the UK, equivalent to about 11 kg per household per week.

Municipal waste of typical analysis by weight contained, as potentially recyclable materials, about 33% paper, 7.0 metals, 8.0% glass and 1.0% plastics. For 1988, the poten­

tial for resource and energy recovery from urban waste is shown in F ig u r e 6 .

Most WDAs have designated amenity sites where the general public can take unwanted items. At the generally older so- called Class 1 sites, little on-site segregation or separ­

ation takes place, but at Class 2 sites, bottles, other glass objects, paper and card, textiles and plastics are segregated and sold for reclamation. Other opportunities for segregation activities such as bottle banks or the collec­

tion of cans and paper are by no means evenly distributed across the country. Interest in secondary materials has gen­

erally declined since the market price for such materials, when recovered from mixed refuse, barely exceeds their en­

ergy value and current strategies concentrate on recovering the energy potential of the waste before disposing of the residue. The UK inclines to the view that there are landfill benefits in the reduction in volume and hazard of the re­

sidue, offered by this route.

This view is borne out by F ig u r e 6 which shows that the esti­

mated maximum value of municipal waste is t 21.14 per tonne, ignoring the practical difficulties of achieving this figure. The upper limit theoretical energy value (as refuse derived fuel) of a tonne of unsorted municipal waste is fe 14.82. Selling the non-combustible fractions of the waste at their theoretical recycling values, increases the energy value to t 19.98. The conclusion is that although recycling of consumer waste has increased in recent years, segregation at source before contamination on mixing clearly has a key role to play in the future of UK municipal waste management strategies.

As received assay

wt %

Moisture content

wt %

Dry weight per tonne of input

kg

Possible price (merchant) b/tonne (d ry)

Value per tonne o f input

b

Comment

Paper 33 30 231.0 35 8.09 Mixed waste paper grade

P la s tic film 3 25 22.5 100 2.25 Not necessarily as single polymer

Dense p la s tic 3 15 25.5 100 2.55 Not necessarily as single polymer

T e x tile 4 25 30.0 50 1.50 Mixed

Hisc comb 5 25 37.5 20 0.75 Fuel

Hisc non-comb 5 15 42.5 5 0.21 As t ip cover/hard core

Glass 9 10 81.0 25 2.03 Mixed c u lle t

Ferrous 7 15 59.5 15 0.90 Mainly can stock

Non-ferrous 1 10 9.0 200 1.80 Mainly aluminium

P utrescible 20 65 70.0 10 0.70 Compost or s o il cond itio n e r

-10 mm 10 40 60.0 6 0.36

Total 100 33 668.5 21.14 21.14

Source: Barton, J.R., "Mechanical Sorting Technology for Municipal Solid Waste", Harwell Waste Management Symposium, Environmental Safety Centre, Harwell Laboratory, O x ­

fordshire, May, 1988.

4.1.2 Energy Recovery

Waste disposal sites provide a source of energy in the form of landfill gas, a resource which is increasingly exploited.

Britain is second only to the United States in using land­

fill gas and the government currently predicts that the en­

ergy equivalent of 1 m tonnes of coal per annum will be ob- tained from this source in the 1990’s.1 8

Considerable progress has been made in the field of refuse derived fuel (RDF) production and use in the UK. However, compared to some European countries relatively few examples exist of RDF used as a source of energy, or of waste in crude form in mass waste burning incinerators. The Parlia­

mentary R e p o r t ^ stated that there were less than ten energy recovery refuse disposal plants in operation in the UK but that there was potential for more than a hundred. So far, less than 5% of household refuse is used for energy re­

covery .

The first three commercial scale plants producing RDF p e l ­ lets were commissioned in the early 1 9 8 0 ’s and their p r o ­ duction can be considered to be an operationally reliable technology. However, since RDF has about half the calorific value of coal, industrial customers conurbations are likely to alter the balance of the economic equation.

Refuse incineration units with energy recovery built in the UK in the mid 1 9 7 0 's are now considered to be performing in a cost effective manner. There is confidence now that a modern energy recovery incinerator is an environmentally ac­

ceptable option for municipal waste disposal. Combustion trials are also under way at some municipal incinerators which do not yet have energy recovery, aimed at proving that waste can be burnt without causing environmental damage from polluting emissions. 1 9

4.2 Industrial Examples of Recycling

The UK industry already uses a high proportion of its waste as secondary raw materials with in some cases, a waste from one process becoming the raw material for a different p r o ­ duct. Scrap processing and reclamation was employing some 90,000 people and had a 1986 sales value of fc 2.1 billion.

The Warren Spring Laboratory estimate that in 1985/6 some 82% of ferrous metal was recycled. F ig u r e 7 shows the amounts of aluminium, copper lead and zinc recycled in 1987 compared with the production from primary raw materials.

F ig u r e 7: P r o d u c tio n o f P r im a r y a n d S e c o n d a r y M e ta ls , 1987

Primary Secondary Direct Use of Scrap

Aluminium 281 . 0 110.8 33.1

Copper 138.9 68.0 138.0

Lead 347.0 201 .1

Zinc 81 .0 53.0

Source: World Bureau of Metal Statistics, 1988.

Some 25% of the paper and board industry’s output is in the manufacture of printing and writing papers, yet only 5% of the 2 m tonnes of waste paper that is recycled annually comes from this sector. A DTI grant was awarded to the Paper Industry Research Association to establish a number of pilot schemes with the objective of increasing the use of paper waste in that sector. In 1985/6 47% of scrap paper and board were either recycled in the UK or exported to be recycled elsewhere.