CMPS&F - Environment Australia
Appropriate technologies for the treatment of scheduled wastes
Review Report Number 4 - November 1997
It is important to recognise the practical constraints associated with materials handling in the treatment of scheduled wastes. Wastes are often in diverse forms, particularly when contaminated soils, demolition equipment, and process wastes are involved. Such materials can present difficult handling problems, and pretreatment systems or specific technologies may need to be applied to such materials. In some cases, the development of an appropriate materials handling strategy and pretreatment system can be a more difficult and costly problem than the treatment itself. This is clearly illustrated by the stocks of hexachlorobenzene (HCB) wastes held at Botany, NSW, where the diversity of physical forms and composition requires a flexible treatment system.
A more widespread example involves OCP wastes arising from community chemical collections. Such wastes may include a range of scheduled and non-scheduled wastes in a range of physical forms such as powders, aqueous solutions, formulations containing volatile solvents and emulsions. Frequently such wastes are returned in small packages which complicates the materials handling issues. For many systems, prior to treatment consideration must be given to appropriate sorting and segregation of wastes, and to the removal of wastes from small packages. It is possible that more than one technology may be required to treat the range of physical forms.
To date, waste treatment companies have focused on the most easily identified and serviced segment of the waste treatment market, that of PCB liquids. In general, the treatment of liquids is a relatively easy task, and can be accomplished using the currently available treatment systems and, it is expected, by most of the technologies which are proposed for establishment in Australia.
Treatment facilities with a broader range of application, (eg. to capacitors, soils, and polymerised materials) are only now being implemented. It will still be several years before facilities are in place which have been demonstrated to be able to treat all types of scheduled wastes.
In some cases, scheduled wastes may be present in conjunction with other contaminants and this can influence the selection of treatment technology. The most common example of mixed contamination is found in mixtures of organochlorine pesticides and inorganic pesticides, such as arsenic. In many cases, corrosion of the waste containers can also result in elevated concentrations of iron in the wastes to be treated. Iron can reduce the effectiveness of some waste treatment process.
Wastes arising from community chemical collections are complex mixtures, both in terms of composition and physical form. Historical waste consolidation practices, which reflected the expectation that such wastes would be destroyed using high temperature incineration, have contributed to the complexity of waste mixtures. As a relatively extreme example of the waste mixtures that can arise from community collections, the following was measured in a sample from a drum of mixed wastes resulting from a community collection:
||20 - 30%|
||0 - 7%|
With the exception of stabilisation/contaminant technologies such as In Situ Vitrification, most processes designed to treat scheduled wastes are not effective in treating inorganics.
In considering the fate of iron and arsenic in most scheduled waste treatment processes, the contaminant may:
Examples of the impact of inorganic contaminants on scheduled waste treatment processes are outlined as follows:
The applicability and availability of the various treatment technologies is dependent on the location of treatment systems and whether the wastes are practically able to be transported to the facility.
The Queensland BCD system is portable although, in practice, it has been largely operated as a centralised facility to date 1. The Victorian BCD facility is licensed as a fixed facility. The Eco Logic system is relocatable, and approval has been obtained for operation of the Eco Logic system in NSW for waste treatment applications. An important feature of the National Strategy at this time is that scheduled wastes are transported from State to State for treatment. Whether wastes are transported interstate is dependent on the availability of intrastate treatment systems, and the quantities and economics involved. While it is desirable to minimise transport of scheduled wastes, it is not practical to eliminate transport, as this could preclude or delay the treatment and disposal of significant quantities of waste. From the perspective of those holders of waste who desire to have the waste treated and disposed of, it is important that interstate transport remains an option, as this can allow the most cost effective and appropriate treatment strategy to be adopted.
20.4.1 Current Status of Scheduled Waste Treatment Industry in Australia
The implementation of treatment facilities for scheduled waste is currently under way in Australia, and from a few initial facilities which have been purpose-built for particular wastes, more widely applicable facilities are gradually evolving. In practice the development of systems of broad capability has been considerably slower than hoped and expected.
While not all categories of scheduled wastes are able to be treated at this stage, new facilities are currently being established which will increase the range of wastes for which treatment is available. Through the implementation of a small number of treatment systems which are now operating albeit treating a restricted range of wastes, it is becoming clear that installation of new facilities or expansion of excisting facilities to address the full range of scheduled wastes should be possible.
CMPS&F notes that the strategy of facilitating the development of smaller, local or transportable treatment systems rather than a larger, centralised facility (such as a high temperature incinerator) has limited the range of wastes that can be treated (at least in the short term). The smaller, transportable or local systems are typically less energy intensive than HTI and reliant on specific chemical reactions. As a result, the smaller, local or transportable units are tailored to specific wastes.
This is a significant improvement on the situation which existed several years ago. Difficulties encountered in establishing a centralised, integrated waste treatment facility raised doubts as to whether it would be possible to install any scheduled waste treatment facilities in Australia, and export of wastes for overseas destruction seemed the only practical solution.
It can be seen from this overall perspective that there has been a significant advance over the past several years in the capacity to treat scheduled waste in Australia.
Notwithstanding these comments, it should be recognised that the excisting scheduled waste treatment capacity in Australia involves relatively small and poorly resourced operations and is insufficient to deal with the volumes and types of scheduled waste which require treatment. This is most marked in the south-east of Australia.
While several waste treatment companies have become or are becoming established, in practice competition is limited by the following:
However, compared to the cost of export which includes shipment and insurance, costs are still low. Comments from some waste holders suggest that while cost, and increases in some sectors, are of concern, the ability to reliably get wastes treated within a reasonable time frame is of greater concern.
The most obvious lack of treatment capability lies in the absence of facilities which are able to handle large quantities of soil and waste materials with diverse physical properties (such as the HCB waste held at Botany and some types of collected farm and household chemicals). However, some waste treaters (with partially developed soil treatment capabilities) have noted limited demand for treatment of soils contaminated by scheduled contaminants (although others may argue that the waste volumes will become apparent once a cost effective treatment technology is available).
Further, it is not at all clear that adequate treatment facilities will become available in the medium term (eg. 10 years) in reasonable proximity to all areas where wastes are located. However, it can be expected that one or two general purpose treatment facilities will become available within this time period.
There has been a general trend by technology suppliers to quote indicative treatment costs during the technology development phase which are much less than the costs which apply when treatment facilities are established. There are a number of reasons for this, the most common being the inability to anticipate all of the materials handling and processing requirements in advance, inexperience, and the desire to be seen to be competitive with alternative systems. It is important not to rely on costs quoted by technology providers during process development and establishment. More recently, technology proponents are avoiding quoting costs where processes are less developed, noting instead that costs depend on a wide range of factors.
20.4.2 Comments from Industry
Submissions and comments were sought from a number of persons and groups (eg EMIAA, Maier, Waid, Miller, Hawkes, Guerin, Krynen, and Nadebaum, 1995) involved in the development and application of scheduled waste treatment technologies regarding the impediments that they saw in developing and applying these technologies in Australia. The comments reflect specific experiences and perspectives, and not all were consistent.
Because the question put to these various individuals sought information regarding the impediments in developing and applying waste treatment technologies, the comments made tend to be negative (ie. they identify impediments rather than where there have been advances and facilitation). In order to maintain a balance and a perspective, the comments have been framed within the context of a general discussion. CMPS&F cautions that this discussion is necessarily subjective in nature, and is intended as a focus for discussion rather than forming a substantiated and considered position.
In the following sections, the comment made by those contacted has been placed in italics.
(a) There are Insufficient Waste Volumes which Require Treatment
The uncertainty regarding the waste market, and how much income can be generated, is a major issue for waste treatment companies. Clearly, if a significant market can be assured, then investment will flow. However, the market is uncertain, and the outcome of this is seen in the scheduled waste treatment companies that have commenced operations in Australia to date. These can be grouped into two categories:
Of those waste treatment companies that have entered the market, it is not clear that all groups are managing to obtain the return on investment necessary to provide for a sustainable business.
It is interesting that the larger, established industrial waste treatment companies such as Cleanaway and BFI have not entered the Australian scheduled waste treatment market to any significant degree. This probably reflects a hesitancy regarding the size of the market, and access to appropriate technology. ADI Limited, a major company with access to appropriate technology, has focussed on overseas opportunities with only limited attention being paid to the application of schedule waste treatment technologies in Australia.
It is clear that without significant subsidy or some attractive market entry situation, the establishment of further scheduled waste treatment operations can be expected to be restricted to relatively small operations involving either expansion of an excisting facility, or new niche operations. This then runs the risk that the waste holders may not have confidence (rightly or wrongly) that such groups have the capacity and resources to complete significant waste treatment projects. On this basis, there are opportunities for excisting major waste contractors to link with technology providers; however, the return on the investment for such groups would be uncertain.
There has been extensive debate over the exact size of the waste market in Australia. In practice, the volume of the market is dependent on the criteria which define the wastes requiring treatment, the cost of treatment, and the imperatives on the holders of wastes to dispose of their wastes.
These relationships can be illustrated by considering the cattle dip sites in north eastern Australia which are contaminated with DDT. These sites involve quite large volumes of contaminated soil. However, whether and when these will require treatment is dependent on the soil acceptance criteria, availability and cost of landfill disposal and alternative methods such as in situ treatment; and the regulatory imperatives which would cause the sites to be cleaned up and the costs associated with the contamination realised. Because large sums of money are involved, there is likely to be little action on the majority of the sites until it is clear that action has to be taken, and the lowest cost approach has been established. Note, however, that the National Strategy is principally focussed on stockpiles of waste and not on contaminated soil which is dealt with through other policy mechanisms.
Some other impediments cited by those in the industry also reflect this need to more clearly establish and secure the market:
This comment is made by some treatment companies, and reflects thinking that if stringent standards are set for the definition and disposal of scheduled wastes, then a greater quantity of waste materials will require treatment. This will increase the waste market available to them. However the contrary argument may also be valid; that flexibility in waste assessment allows for a range of more cost effective treatment and/or management strategies to be considered.
This comment is a subset of the more general comment regarding the inadequate focus on standards, and reflects the uncertainty in Australia regarding the concentrations of wastes and soils which can be disposed of to landfills. However, in the case of PCBs for example, the picture has become clearer with the release of the PCB Management Plan and the EPAs in Victoria and NSW, for example, setting limits on material which can be disposed of to landfills. As further scheduled waste management plans are developed (eg. for pesticides), the landfill standards for scheduled wastes will become clearer.
Of course, if more stringent landfill acceptance criteria are set, the quantity of scheduled waste requiring treatment will be increased. As such, the comment above probably reflects a hopefulness on the part of some of the waste treatment companies that stringent landfill acceptance criteria will be set as an outcome of the regulatory and consultative process, and therefore increase the waste market available to them.
Counter to this, the holders of scheduled waste seek practical and not unnecessarily stringent criteria for landfill disposal, so that they will not be saddled with unnecessary costs for waste disposal.
In seeking to reach a conclusion as to whether the lack of standards is an impediment to establishing a waste treatment facilities in Australia, CMPS&F notes that:
CMPS&F concludes that the implementation or otherwise of more stringent standards is not an impediment as such to the treatment of wastes. However, stringent, uniform standards may be used as a policy instrument to, say, subsidise treatment while achieving an appropriate level of environmental protection.
(b) The Costs for Developing and Demonstrating New Technologies are Too High
Comment: Analytical uncertainty due to the difficulty of analysing particular environmental media, and differences in analytical laboratory methods and standards can significantly increase the costs of programs.
Comment: Regulatory authorities can require excessive monitoring programs.
Comment: Prospective users of a treatment technology require the technology to have been demonstrated convincingly at a commercial scale and for it to be certain that the process will be cost effective and operate with the required degree of efficiency. Satisfying this can be costly and involve considerable risk.
Comment: The time frame for carrying out feasibility studies and full scale demonstration trials is significant and can be unacceptably long for some prospective users.
These comments reflect a number of issues:
CMPS&F concludes that the comments above regarding the costs of developing and demonstrating new technologies reflect the technical limitations of certain treatment technologies and the technically difficult nature of the scheduled waste treatment problem, rather than reflecting any deficiency in the National Strategy for the Management of Scheduled Waste.
Many waste holders are interested in getting their wastes treated, not developing technologies, and hence have a strong preference for proven, demonstrated technologies. In contrast, technology providers frequently want some guarantee of waste to be treated before committing to the expense of demonstration of the process. In the extreme some waste holders want several proven established technologies available to engender competition before committing to treatment contracts. The corresponding waste treatment contractor typically seeks a significant contract for treatment of wastes prior to establishment of the process in Australia. In this context, establishment of new technologies, particularly the high capital cost processes such as ISV and PACT, can depend on there being at least one major treatment contract.
CMPS&F recommends that governments assist in the demonstration of technologies to aid their development (refer programs in the United States and Canada, and the demonstration of the BCD process in New Zealand).
(c) Perceptions Regarding Treatment Processes and Treatment Companies
This has happened to some extent, and has come about through some treatment technologies being initially proposed in one capacity, and then later being extended to wider applications. An example is the case of in-flight plasma systems, where the system has been discussed and demonstrated in direct treatment of wastes which necessarily have to be liquid or gaseous, and only more recently has been proposed in conjunction with pretreatment processes such as thermal desorption for the treatment of physically diverse wastes.
CMPS&F considers that while such perceptions may temporarily limit the application of particular technologies, it is not so widespread as to be a significant impediment to the treatment of scheduled waste in Australia.
There is probably substance to this comment in that the regulatory authorities may well adopt a cautious approach when dealing with apparently under-resourced companies. However, it is difficult to judge how significant this issue is. Because the Australian scheduled waste treatment market is serviced by small companies which do not have (and cannot afford) a high level of technical support, this comment reflects a situation which applies to a significant portion of the industry. The fire at the BCD facility in Melbourne may have resulted in greater caution by regulatory agencies.
CMPS&F concludes that the small size and limited technical resources of the waste treatment companies active in the Australian scheduled waste treatment market may slow, but is unlikely to seriously impede, the implementation of treatment facilities in Australia.
(d) Regulatory Impediments
This comment was made by waste treatment companies which are involved in setting up treatment facilities. These companies are uncertain as to just what will be required by the regulatory authorities in order to gain approval.
In some jurisdictions, regulatory authorities adopt a works approval process in approving and licensing new treatment facilities. This is a simple technical review process, and has evolved out of environmental regulatory practice over many years. While the works approval process can be criticised, it does ensure that any proposal is subjected to critical scrutiny before construction. This assists in avoiding the difficult situation where a facility is constructed and is found not to work, and pressure is brought to bear on the regulatory authority to accept an operation which does not meet regulatory requirements.
A National Protocol for Approval/Licensing of Commercial Scale Facilities for the Treatment/Disposal of Schedule X Wastes, endorsed by ANZECC, has been in place for 3 years. This is routinely used by regulators in developing approvals for new scheduled waste treatment facilities. This has assisted in clarifying regulatory requirements. Also, information is routinely shared between State regulatory authorities, and this avoids the need to duplicate the assembly of information when approvals are sought to establish an operation in more than one state.
Because of the potentially hazardous nature of scheduled waste, it is important for regulatory authorities to critically scrutinise the ongoing operation and expansion of the scheduled waste treatment facilities. In doing this they must ensure that the systems are operated as intended, and that there is an appropriate level of monitoring and control. It would, for example, be a serious set back if there were to be a major accident and release of scheduled waste at one of the treatment facilities. The fire at the BCD facility in Melbourne, while not major, has had an impact on the industry.
CMPS&F concludes that technical review is a necessary part of the overall approvals process as is the ongoing monitoring of the facility operations. Such regulation should not impede the establishment of scheduled waste treatment facilities in Australia. Notwithstanding this, some waste contractors have chosen to focus the initial implementation of their processes in New Zealand where they report that the regulatory environment is more favourable. The consent process developed under the auspices of the Resource Management Act which focuses on discharges to the environment is a component of this. However, concern has been expressed in New Zealand regarding the potential for processes which do not result in a discharge to the environment to be established without regulatory review and approval.
There has been a trend in Australia towards risk based performance criteria, rather than prescriptive standards or technology based criteria. Risk based criteria are less certain than prescriptive standards, however, they are more flexible, as they have potential to facilitate the implementation of technologies.
Those treatment companies that are promoting treatment processes which achieve a very high destruction efficiency are those that are likely to support the above comment, as relatively stringent and prescriptive performance criteria will favour their processes.
In general, CMPS&F considers that the Australian regulatory approach is potentially very flexible and should not, in general, pose a serious impediment to the implementation of new scheduled waste treatment facilities in Australia.
(e) Community Consultation
The principle of community consultation has been generally accepted by the regulatory authorities in Australia, and has been particularly applied when projects are large or controversial. A National Protocol for Community Consultation on Scheduled Wastes (November, 1994) has been prepared on behalf of ANZECC.
While the technical review aspect of approvals is not necessarily a problem, delays and uncertainty can arise if community concerns become a significant issue, and if third party appeals are lodged against a proposal. There is a strong feeling within the industry that when the community and the media become involved, the regulatory approvals process can bog down, and the regulatory performance requirements or "goal posts" can change. This is indicated by the following comments:
Comment: The need for community consultation at each location of use makes the use of portable treatment systems impractical.
Comment: "Community" consultation is a misnomer; community consultation as it is practised in Australia is more a process of placating potentially influential individuals or small groups, rather than satisfying the community at large. As such, the approvals process does not maintain a balance and work towards the overall good of the community.
Notwithstanding these comments, there are a number of cases where a community consultation process has resulted in a successful outcome with a minimum of additional time and expense. The consultation process which has accompanied the development of scheduled waste management plans is an example of a successful consultation program.
While community consultation is cited as an impediment by some representatives from industry, this is not unanimous. There are divergent opinions as to the reasons for the difficulties that have been associated with community consultation for some projects. Some industry representatives suggest that the consultation process itself is flawed in that it focuses on special interest groups rather than the community as a whole. Others argue that it is community opinion and attitudes that have resulted in difficulties for specific projects, but that the process is sound and the groups consulted are legitimate representatives of the community. It does appear that the process of community consultation for the siting of new treatment facilities is not well understood.
The outcome of community consultation appears to depend on the position of certain influential stakeholders, and whether they choose to and are able to affect and determine the outcome of the process. For example, an environmental interest group may have a defined policy to oppose a particular technology (eg high temperature incineration), and may adhere to this policy rather than judging a new proposal on its technical merit. Another example is where there are commercial interests involved (eg a competing waste treatment company), and objections are raised and concerns circulated publicly during the approvals process to preclude or delay approval, as a means of avoiding market competition. Both of these examples have been cited as reasons why particular scheduled waste treatment technologies or proposals for facilities have not been accepted in Australia.
In Australia, proposals to implement high temperature incineration facilities have failed at the community consultation step, even in cases where the regulatory bodies had agreed that the proposal was consistent with their normal approval requirements for industrial facilities, and would not pose an unacceptable risk. This has extended to facilities which have been proposed in extremely remote areas. This has led to an effective outlawing of the incineration of scheduled wastes in Australia.
Community consultation has been less of a concern with regard to the non-incineration scheduled waste treatment processes (such as Eco Logic and BCD). This appears to be a result of several factors: the facilities pose a lesser risk because they are smaller and the process is more contained; the key stakeholders have not formed a strong policy position against these processes; and the companies involved have learnt to negotiate their way through the consultation process.
The implementation of the Eco Logic process in Kwinana by ESI was facilitated through the Department of Environmental Protection (DEP) Works Approval process. In the first instance the proposal was advertised along with the intention to proceed with a Works Approval. The public were given three weeks to object to the level at which the assessment should be undertaken (ie whether a Works Approval was sufficient, or whether a more detailed evaluation was required). No objection was received and hence the Works Approval proceeded. As part of the Works Approval, the DEP nominated twelve organisations, representing national and local environmental groups, local government and industry organisations, with which ESI was required to consult. After discussions with each of the nominated groups, a Works Approval was granted and the implementation of the Eco Logic process continued.
In the case of portable treatment systems, the problem with requiring licensing on an individual site basis, and the consultation that is then required, has been recognised by the regulatory authorities. Some of the authorities are reviewing this process and have considered establishing a process which involves technical and environmental performance appraisal at a State or national level (as opposed to local) with a site by site approval being issued by the relevant planning authority. Community consultation would occur at two levels: broad consultation at the technology appraisal stage, and local consultation on planning issues. If this approach is adopted on a uniform basis, it may reduce the problems associated with site by site licensing.
As treatment facilities are now in place and operating successfully, extending the capacity of these facilities is a practical alternative to establishing new facilities and is less likely to be opposed by local communities. Nevertheless, consultation and transparency is still needed to ensure local acceptance.
While a detailed discussion of approaches to the management of community consultation processes is beyond the scope of this report, based on experience with the implementation of scheduled waste treatment facilities, some of the factors affecting the success of such programs would appear to include:
CMPS&F concludes that community consultation is a critical aspect of the establishment of scheduled waste treatment facilities in Australia. With non-high temperature incineration processes, it appears that community consultation will not result in insurmountable obstacles and, in itself, is not sufficient to preclude investment by companies that propose to install a treatment facility. In the case of high temperature incineration, community opinion is likely to continue to preclude the establishment of a facility.
(f) Cost of Treatment
The cost of treatment of concentrated scheduled wastes in Australia are considerable, and typically in the order of $2000 to $8000 per tonne. These costs are higher than indicated by the technology suppliers prior to establishment of their processes. This probably reflects the difficulty of anticipating the full treatment requirements, and a desire to project costs which are competitive.
An accurate comparison of costs for treatment of scheduled wastes is difficult to undertake given many waste treaters are reluctant to provide costs on a generic basis, preferring to quote on a job by job basis.
Lower costs of treatment of wastes apply at some overseas facilities. It will be interesting to see whether Australian treatment costs will reduce over time, or whether the costs reflect local constraints, (such as the relatively small systems, and the technologies' complexity and developmental nature).
Some waste holders claim the cost of treatment has risen in recent times (due to reduced competition following the fire at the Melbourne BCD facility and process difficulties with the Eco Logic process). In contrast, waste treaters claim the cost of treating liquid PCBs and PCBs in oil has decreased, although the cost of treating transformers and capacitors has increased.
In comparison the cost for export of wastes and destruction in a high temperature incinerator is expected to be in the order of $15,000/tonne for PCB fluids and $29,000/tonne for lighting capacitors (based on New Zealand experience).
In the first instance, the ability to get wastes destroyed (ie the capacity of the waste treatment market) is raised as a more significant concern than the cost of treatment.
20.4.4 Facilitating the Establishment of Scheduled Waste Treatment Facilities in Australia
The establishment of adequately resourced waste treatment facilities which are able to treat the full range of wastes is gradually taking place. However, this is occurring slowly and the investment levels may not be sufficient to assure success in the short to medium term.
In order to facilitate this process, the following actions can be considered:
Such actions could include:
- mandatory requirements for waste identification and reporting; and
- establishing of low cost scheduled waste treatment facilities, as the availability of a low cost treatment facilities will encourage groups holding wastes to consign them for disposal.
2 Currently in New Zealand a consent is only required if a discharge to the environment occurs. In the context of scheduled wastes some regard this as a loophole allowing facilities to be developed without an appropriate approvals process.
|Chapter 19 - Pretreatment Technologies||Chapter 21 - Conclusions|