Information Paper

East Sussex, South Downs and Brighton & Hove and Minerals Development Plan Document

Information Paper 7 and Low Level

June 2012

Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

Introduction Introduction

This Information Paper on 'Hazardous Waste', is one in a series that has been produced to support the preparation of the Waste and Minerals Development Framework (WMDF). The WMDF will contain planning documents that will guide how and where waste should be managed and minerals produced in East Sussex, Brighton & Hove and the South Downs National Park in the future (up to 2026). More information about them can be found at:

www.eastsussex.gov.uk/environment/planning/development/mineralsandwaste www.brighton-hove.gov.uk/index.cfm?request=b1148434

This Information Paper is concerned with hazardous waste and draws on a detailed study prepared by Scott Wilson in 2009 updated by URS/Scott Wilson in 2011. More detailed information on low-level radioactive waste in covered in a separate study carried out by URS/Scott Wilson in 2011. In 2012 URS/Scott Wilson also completed a study that considers the future availability of facilities beyond the Plan Area for the ongoing management of hazardous and low-level radioactive waste.

The Information Papers are being used provide evidence for the development of the WMDF and to support consultation and discussion with members of the public and key stakeholders who are concerned with waste and minerals in East Sussex and Brighton & Hove.

The Papers are ’living drafts’ which present the evidence as it stands at this stage and are periodically updated with any new information that comes to light. This ensures the Authorities’ knowledge and understanding of waste and minerals remains robust and the evidence base for the WMDF is ‘sound’.

The Information Papers were first published and consulted upon in July 2007, and were then republished in February 2008, October 2009, October 2011 and February 2012 to coincide with public consultations on the Waste & Minerals Plan. This sixth version (May 2012) has been published to accompany the submission of the Plan for public examination.

Details of the other Information Papers that have been produced are included in Appendix 1.

If you would like to comment on or add to the WMDF evidence base that is presented in this Information Paper, please visit the consultation website http://consult.eastsussex.gov.uk and follow the instructions for the Information Papers. Alternatively you can e-mail [email protected] or write to: Waste & Minerals Planning Policy C4-AP FREEPOST Economy, Transport & Environment East Sussex County Council Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

Introduction

County Hall Lewes, BN7 1UE

Please make sure that you refer to the section and paragraph numbers that your comments relate to. Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

Hazardous Waste Hazardous Waste

What is hazardous waste?

2.1 Waste is generally categorised using three broad classifications, as follows:

'non-inert’ waste: (described as 'non-hazardous waste' in EU Directives) is potentially biodegradable and may undergo significant physical or biological change if deposited at a site. Waste from households, commerce, and industry mainly falls into this category;

‘inert’ waste: includes materials such as rock, concrete, brick, sand, soil or certain arisings from road building or maintenance. Inert waste does not normally undergo any significant physical, chemical or biological change. The majority of construction and is inert; and

‘hazardous’ waste: can be generally described as waste which may be hazardous to health or the environment, either now or in the future. It was previously referred to as 'Special Waste'. The terms ‘special’ and ‘hazardous’ are, to a large degree, synonymous, the former being established by the Special Waste Regulations 1996 and being superseded by the latter with the implementation of the Hazardous Waste (England and Wales) Regulations 2005(1). Hazardous waste now includes everyday items such as fluorescent tubes, batteries and some waste electronic/electrical items, as well as tyres, discarded oils and lubricants. Hazardous waste is estimated to comprise around 2% of total waste arisings in the UK (2).

2.2 A common source of hazardous waste is clinical waste which arises from the healthcare sector. Some of this waste can be managed as non-hazardous, but infectious and higher risk waste must be dealt with as hazardous waste, for example hypodermic needles/sharps, swabs, and prescription-only medicines. The most common method of managing hazardous clinical waste is by .

2.3 Waste produced through industrial processes is also often classified as hazardous; this can include solvents, acids, alkalis, waste oils, asbestos, and pesticides.

2.4 Hazardous waste can also include low level radioactive waste.

2.5 For further information see the Environment Agency guide ‘What is a Hazardous Waste’ (3), as well as information on the Defra website: www.defra.gov.uk/environment/waste/business/hazardous-waste/.

1 Each of these regulations are based around different versions of the 'European Waste Catalogue' (EWC), with ‘special’ wastes being slightly fewer in number than hazardous wastes, resulting from a progressive extension of the EWC over time. 2 Waste Strategy 2000 3 What is a Hazardous Waste? (Environment Agency 2007) Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

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Planning for hazardous waste

2.6 Planning for the provision of facilities to deal with hazardous waste raises complex issues, not least because of the plethora of definitions and categorisations used in legislation and by different organisations. This makes it difficult to make an accurate assessment of management capacity and facility requirements at regional and local levels.

2.7 Hazardous waste can pose greater risks during collection, bulking, handling, storage and transport than for non-hazardous waste as it may be explosive, flammable, toxic, corrosive, or infectious. This can generate concern and anxiety from communities about perceived health and environmental impacts.

2.8 Many of the controls and regulations regarding hazardous waste are beyond the remit of the planning system, however they are often closely linked. The Waste Planning Authority (WPA) is responsible for determining planning applications for development to manage waste, but it is the Environment Agency (EA) which is responsible for issuing a permit concerned with the control of pollution. WPAs can advise that an environmental permit must be obtained for a development, but the enforcement and monitoring of the permit is the remit of the EA.

2.9 Certain planning applications for related developments also require an Environment Impact Assessment (EIA). An EIA requires the developer to compile an Environmental Statement, which must describe the likely significant effects of the development on the environment and proposed mitigation measures, before planning permission can be granted. Statutory consultation bodies must be consulted on the Environmental Statement, and their comments must be taken into account. Determining the threshold for requiring an EIA is complex, but as a general guide an EIA is required if the development could potentially have significant effects on the environment. “Significant” is defined in the EIA regulations. In addition to an EIA, some proposals may also need a Health Impact Assessment (HIA), which examines potential impacts on human health through a similar process.

2.10 Planning applications for hazardous waste plants that involve the disposal of more than 100,000 tonnes of hazardous waste and/or management by other means of 30,000 tonnes of hazardous waste per year are considered to be applications for major infrastructure projects of national importance and are therefore considered at a national rather than local level. The Planning Act 2008 provided for a new Infrastructure Planning Commission (IPC) to decide applications for major infrastructure projects of national importance(4). That would replace the method of decisions being taken by the Secretary of State following a public inquiry. The main provisions of the Act came into force in March 2010, when the Infrastructure Planning Commission (IPC) was opened to receive applications. The Localism Act 2011 abolished the IPC and replaced it with a new National Infrastructure Directorate (NID), created within the Planning Inspectorate in April 2012. The final decision on major infrastructure applications would revert to the Secretary of

4 See Section 30 of the Planning Act 2008 Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

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State. However, there will be a period before that date when the NID takes the final decision. National Policy Statements set out the basis for decision making at this level.

In July 2011 Defra released the Draft National Policy Statement for Hazardous Waste for consultation which sets out the assessment principles against which the NID will evaluate an application including taking into account:

• Its potential benefits including its contribution to meeting the need for hazardous waste infrastructure, job creation and any long-term or wider benefits; and

• Its potential adverse impacts, including any longer-term and cumulative adverse impacts, as well as any measures to avoid, reduce or compensate for any adverse impacts

2.11 Appendix 2 contains more information regarding the legislative and policy framework affecting hazardous waste.

Management of hazardous waste - the national and international legislative framework

2.11a The legislative and policy requirements for management of waste in the UK are initiated through the various framework directives and strategies developed within, and emanating from, the European Union. Such legislation and policy initiatives are translated into national legislation and strategy for implementation. Appendix 2 details legislation relevant to the management of hazardous waste.

2.12 European Directives are increasingly directing waste away from landfill, imposing greater requirements for (for example all hazardous waste going to landfill must now be pre-treated), and are requiring stricter pollution control of incinerators.

2.12a Since July 2005 the has prohibited the co-disposal of hazardous and non-hazardous wastes at the same landfill. As a result many operators have chosen to deal with non-hazardous waste rather than hazardous for economic reasons, and the result has been a significant fall in the number of hazardous waste landfill sites, although there are some landfill sites in the south-east region with separate engineered cells for the disposal of asbestos. This could raise capacity issues in the future, for example, for the disposal of residues generated by energy recovery facilities which can currently only be disposed of at hazardous waste . The Landfill Directive also sets out 'Waste Acceptance Criteria', which require greater sampling, testing, and treatment of hazardous waste to meet criteria for wastes that can be disposed through landfill. This includes a requirement that, from 30 October 2007, all waste (hazardous and non-hazardous) must be treated before it can be landfilled.

2.13 A Pollution Prevention and Control regulatory system exists to provide an integrated approach to considering the impacts of certain activities in terms of emissions and other impacts to air, water, land that could be harmful to human Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

Hazardous Waste health or the environment. From 6 April 2008 this system has been incorporated into the framework of the Environmental Permitting Regulations (EPR). These regulations have combined the many separate waste and pollution control systems so there are now single environmental permits and common procedures, thus streamlining the process and replacing over 40 pieces of legislation. Environmental Permits are obtained from the Environment Agency..

2.14 Most waste management activities must now have an Environmental Permit instead of a waste management licence. Permits are issued by the EA and have conditions to ensure that the activities do not cause pollution of the environment, harm to human health, or serious detriment to local amenity. Anyone who deposits, recovers or disposes of controlled waste must do so within the conditions of an Environmental Permit (unless the activity is exempt from a permit). The EA regularly visits facilities to ensure that permit conditions are being met. Operators dealing with hazardous waste are also bound by a 'duty of care' to ensure that correct procedures are followed, which is set out in the Environmental Protection Act 1990.

2.15 Furthermore any business producing hazardous waste has a legal duty to register their premises with the EA, and registration must be renewed annually. Since 15 May 2007, the Waste Management (England and Wales) Regulations 2006 (known as the Agricultural Waste Regulations) also apply to agricultural waste. As East Sussex is a relatively rural county with large areas of farmland, this has resulted in agricultural waste (such as plastic feed and seed bags, silage wrap, agrochemicals, and sheep dip) no longer being allowed to be burnt or landfilled on farm sites (5) and instead being eliminated or sent to approved waste management facilities.

2.16 In addition, movements of hazardous waste between sites is strictly monitored by the EA. Consignment notes are required for every movement from 'cradle-to-grave', and must be submitted to the EA for monitoring. The Waste (England and Wales) Regulations 2011 (introduced on 29 March 2011) resulted in minor amendments to the assessment of hazardous waste and to the consignment note procedures and record keeping requirements

2.17 Other key legislation in relation to hazardous waste is the Hazardous Waste (England and Wales) Regulations 2005, which transposes the requirements of the Hazardous Waste Directive (91/689/EEC), setting out requirements for the controlled management of hazardous waste. The 2005 Regulations formally replaced the term ‘special waste’ with ‘hazardous waste’. These were amended on 6 April 2009 to principally widen the scope of the exemption from the need for hazardous waste producer registration.

2.18 On the 2 January 2007, the UK Waste Electrical and Electronic Equipment (WEEE) regulations came into force, requiring all producers or importers of household electrical and to either provide a free in-store take-back

5 Guide to Agricultural Waste Regulations (Environment Agency 2007) Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

Hazardous Waste scheme or to join a take-back scheme (operated by Valpack (6)) to collect the items. The regulations, enforced by the EA, place the responsibility for, and cost of, reducing the environmental impact on those who profit from making the goods. New facilities have been required to process the increased volume of waste resulting from the implementation of these regulations. There is currently only one treatment operation in the Plan area for waste electronic and electrical equipment, located near Lewes, however this a regionally significant facility with a large catchment area that extends beyond the East Sussex and Brighton & Hove.

2.18a Exports of hazardous waste to economically developing countries (those non-EU countries outside the OECD) such as China, India and Indonesia are prohibited, even if being sent for recovery. This is in accordance with the on the Control of Transboundary Movements of Hazardous Wastes and their Disposal.

Other influences on the management of hazardous waste

2.19 A key driver for the management of hazardous waste is the Waste Strategy for England 2007. It suggests that a high proportion of hazardous waste can be re-used, recycled, or otherwise recovered, and that this trend is likely to continue with increased treatment and of hazardous waste electrical and electronic equipment (WEEE) such as televisions and fluorescent tubes and wastes from the construction sector such as contaminated soils (7). It also suggests that it may be appropriate to introduce targets for hazardous waste once a baseline for arisings has been established for 2006/7.

2.20 In March 2010 the “Strategy for Hazardous Waste Management in England” was published. It aims to deliver environmentally sound management of hazardous waste by:

Underpinning the practical application of the revised EC Waste Framework Directive (WFD) (2008/98/WC); Clarifying how the revised WFD should be implemented especially in respect of the revised ; and Facilitating the provision of hazardous waste management infrastructure.

The Strategy comprises:

Six high level principles for the management of hazardous waste; A set of outline decision trees to assist waste producers and waste managers to make the right decisions about the management of their waste and the investment in infrastructure to help move hazardous waste management up the waste hierarchy; A timeline for action on issues relating to the introduction and implementation of the strategy;

6 www.valpack.co.uk 7 Waste Strategy for England, Annex C9 (Defra 2007) Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

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A list of guidance relating to the treatment of hazardous waste; and An updated summary of facility need.

2.21 On 14th June 2011 the “Government Review of Waste Policy in England 2011” was published. In relation to hazardous waste, the review identified that this was an area where “the existing policy is suitably ambitious and its delivery well focussed” given there is an existing hazardous waste strategy and a new National Policy Statement on hazardous waste is being developed and will be subject to a separate consultation.

2.21a The Government is also examining the future management of ‘higher activity’ radioactive waste, with geological disposal the preferred option (8). the management of most radioactive waste is likely to remain beyond the scope of the WMDF.

2.21b The Government position on the management of non-nuclear industry low level radioactive waste is set out in two parts:

Part 1 - dealing with small users producing relatively low volume arisings of wastes containing mainly anthropogenic radionuclides; and Part 2 - specifically for high volume arisings of naturally occurring radioactive material (NORM) wastes

Part 1 was been published in March 2012(9). This Strategy identifies that the disposal network available to the non-nuclear industry for radioactive waste is 'fragile' and non-existent in some parts of the country. In response to this situation the Government strategy is to strengthen the robustness of disposal arrangements for the non-nuclear industry by conserving existing disposal routes and seeking the development or expansion of other appropriate routes as necessary.

2.21c This position reflects a policy statement on LLW management published by Government in March 2007, which stressed the need to minimise the amount of LLW created and effectively utilise existing disposal routes, including the LLW repository near Drigg in Cumbria, controlled burial and incineration. The Government is also examining future arrangements for the management of 'higher activity' radioactive waste.

2.21d The strategy has been developed to be consistent with the framework of principles set out in the 2007 Policy on LLW from the nuclear industry, including:

Use of a risk-informed approach to ensure safety and protection of the environment Minimisation of waste arisings (both activity and mass); Forecasting of future waste arisings, based upon fit-for-purpose characterisation of wastes, and materials which may become waste; Consideration of all practicable options for the management of LLW;

8 Managing Radioactive Waste Safely: A Framework for implementing geological disposal. A public consultation (Defra and DTI 2007) 9 http://www.decc.gov.uk/assets/decc/11/meeting-energy-demand/nuclear/4616-strategy-low-level-radioactive-waste.pdf Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

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presumption towards early solutions to waste management; Appropriate consideration of the proximity principle and waste transport issues; and In the case of long term storage or disposal facilities, consideration of the potential effects of future climate change.

2.21e In common with strategies for non-radioactive wastes, and with the nuclear LLW strategy in mind, the strategy is also founded on the waste hierarchy principle of avoid, minimise (including decay-storage), re-use, and recycle/recover in the first-instance, and then only dispose of what remains, with incineration (with energy recovery) rated higher than final disposal to land, as per the non-radioactive waste hierarchy presented in the Waste Strategy 2007.

2.21f The revised strategy acknowledges that the majority of the NNI waste streams defined as LLW are similar in their physical and chemical nature to the wide variety of other municipal, commercial and industrial wastes. It is distinguished from these directive wastes in that it contains radioactivity which is additional to that which is present naturally and unmodified in the earth’s raw materials (and therefore also in all types of waste). Most LLW produced by the non-nuclear industry contains only very small quantities of this additional radioactivity.

2.21g The Strategy states that "Data has shown that the majority of non-nuclear industry wastes are of very small volume in comparison to the annual volumes of municipal waste (very unlikely to exceed 0.1% by volume, and there is some evidence that it will reduce. Therefore, waste planning authorities are unlikely to need to make any special provisions to cope with an increase in volumes of radioactive waste."

Management of hazardous waste arising in the south-east

2.22 The South East region has historically exported more hazardous waste for management than was managed within the region (i.e. it acted as a net exporter), driven in part by available capacities of the different management facilities within the region and in part by commerce. For example, the region has a significant proportion of the UK’s high temperature incineration provision but virtually no hazardous waste landfill provision .

2.23 The Scott Wilson study, regarding the management of hazardous waste in the south-east(10), found that hazardous waste arisings in the south-east stood at 477,042 tonnes in 2006, rising to 532,116 in 2007. The impact of the economic downturn on these figures for subsequent years is unclear, although it seems reasonable to expect a reduction in arisings. In 2007 the largest proportion of hazardous waste was comprised of oil and oil/water mixtures, accounting for 26% of the total, followed by construction and demolition waste and asbestos, which together accounted for 20%.

10 SEERA Study into the Arisings and Management of Hazardous Waste in the South East Region (Scott Wilson, April 2009) Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

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2.24 In 2007 a total of 330,711 tonnes of hazardous waste was treated, recovered/reused or disposed of in the south-east, around 43%, or approximately 142,351 tonnes of which, was imported. The following trends were identified

Landfill – a 67% reduction since 2004, however 15% increase between 2006 and 2007; Treatment – a 58% reduction since 2004, however 73% increase between 2006 and 2007; Transfer – an ongoing growth trend, with a 24% increase between 2006 and 2007; Long-term storage – down from 44Te in 2004 to 4Te in 2007 – this is a marginal increase from 2006; Recycling/reuse – an ongoing growth trend, with a 16% increase between 2006 and 2007; and Incineration – where 2007 showed a 29% increase over the preceding year.

2.25 In seeking to divert waste away landfill, the ban on landfill sites accepting hazardous waste unless specially permitted, followed by the introduction of dedicated hazardous waste landfills, appear to have had a degree of success, particularly in relation to increased use of recycling/reuse techniques.

2.26 The former Regional Assembly indicated that some additional capacity for managing hazardous wastes in the south east region will be needed over the next 20 years. The South East Plan (Policy W15) identifies the following regional priorities regarding future needs for management capacity of hazardous waste:

Hazardous waste landfill capacity particularly to serve the needs of the south and south-east of the region; Treatment facilities for air pollution control residues (from combustion facilities); Treatment/de-manufacturing plant for waste electrical and electronic equipment, supported by a network of transfer facilities; A sub-regional network of contaminated C&D waste treatment facilities; and A sub-regional network of landfill cells for stabilised non-reactive hazardous wastes.

2.27 It is likely that a range of types and sizes of facilities to deal with hazardous waste will be required across the south-east region. A few of these could be major facilities, such as incinerators or landfill cells, but many could also be much smaller and lower profile operations such as facilities for the disassembly of electronic goods, which can be situated on existing industrial estates. In considering Policy W15 the Panel Report on the draft South East Plan noted that although there is an urgent need to provide additional landfill capacity for hazardous waste, it does not necessarily have to be located in Sussex, Surrey or Kent even though it is needed to serve these parts of the region where it is most urgently needed Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

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(11)

.

2.27a The types and quantities of hazardous waste produced both nationally and in the South East region have been reviewed for 2008 and 2009, as presented in Table 4.2.1 below.

Table 4.2.1 Hazardous Waste Production – Nationally and In South East England

Table 1

EWC Code EWC NATIONAL SOUTH EAST REGION Description 2008 2009 2009 2008 2009 2009 Ranking Ranking

01 Mining and Minerals 13,443 15,389 16 666 2,033 14

02 Agricultural and Food Production 1,366 813 19 56 67 18

03 Wood and Paper Production 2,415 1,248 18 67 29 19

04 Leather and Textile Production 1,218 256 20 18 0 20

05 Petrol, Gas and Refining/Treatment 25,416 28,628 14 1,412 1,127 17

06 Inorganic Chemical Processes 82,838 82,679 11 6,582 6,430 10

07 Organic Chemical Processes 2,140,846 1,079,082 1 27,811 21,949 7

11 Panel report on Draft South East Plan: Waste and Minerals (August 2007) Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

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08 MFSU Paints, Varnish, Adhesive and Inks 97,943 82,967 10 7,511 6,771 8

09 Photographic Industry 13,852 11,189 17 1,755 1,351 15

10 Thermal Process Waste (inorganic) 130,388 145,225 8 13,669 6,601 9

11 Metal Treatment and Coating Processes 127,298 102,851 9 6,055 6,000 11

12 Shaping/Treatment of Metals and Plastics 81,104 60,681 13 6,589 3,827 13

13 Oil and Oil/Water Mixtures 1,025,677 738,833 2 142,319 123,349 1

14 Solvents 23,756 18,874 15 2,026 1,343 16

15 Packaging, Cloths, Filter Materials 70,955 67,468 12 6,211 5,361 12

16 Not Otherwise Specified 579,734 554,978 4 51,989 61,348 4

17 Construction 878,867 465,458 5 106,762 95,701 3 & Demolition Waste & Asbestos

18 Healthcare 181,868 183,448 7 31,067 32,117 5 Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

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19 Waste/Water Treatment and Water Industry 901,941 577,794 3 137,662 103,419 2

20 Municipal and Similar Commercial Wastes 270,596 219,351 6 37,405 27,045 6

TOTAL 6,651,520 4,437,212 - 587,635 505,870 -

From the above table it can be seen that:

An overall reduction in hazardous waste production was seen both nationally and in the South East region, although the decreases nationally were around 33% and only around 14% in the South East;

The top eight waste producing sectors were found to be broadly the same nationally and in the South East region, albeit that the ranking order was different, reflecting Regional traits rather than ‘smoothed’ national patterns;

Nationally, the sector incorporating organic chemical processes (Sector 07) continued to be the biggest waste producer in 2009, although this showed almost 50% reduction over 2008;

In the South East region, the oil and oil/water sector continued to be the largest producer, despite a 13% reduction from 2008;

EWC code 01, Mining and Minerals, showed the largest increase both nationally and in the South East, and this is felt to be primarily due to the introduction of the Mining Waste regulations resulting in more of this waste code being reported;

Nationally, Sectors 01 (Mining and Minerals), 05 (Fuel Refining), 10 (Thermal Processes) and 18 (Healthcare) all showed an increase in the quantity of hazardous waste produced in 2009 compared to increases in Sectors 01 (Mining and Minerals), 02 (Agriculture and Food Production), 16 (Not Otherwise specified) and 18 (Healthcare) in the South East. Increases are most likely due to new mining waste regulations, increased segregation/collection of WEEE and specific sector activity in areas such as healthcare, thermal processing and agriculture/food production; and

The remaining EWC sectors all showed a decrease in the quantity of hazardous waste produced in 2009, where the downward trend can most probably be explained by more careful classification of wastes by the producer to optimise opportunities, and/or an increase in recovery/reuse at Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

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the place of production, driven by the wider economic influences on commerce, industry and the wider commercial market place.

Management of hazardous waste arising in East Sussex and Brighton & Hove

2.28 19,286 tonnes of hazardous waste was produced in the Plan Area in 2009. An assessment of the available capacity for hazardous waste management against predicted capacity requirements has been undertaken. The conclusions from this are as follows:

Landfill

2.29 Comparison with the predicted future capacity predictions indicate that over the life of the plan (ie to 2025/26) the total landfill capacity needed for hazardous materials equates to up to 74,595 tonnes total for capacity based on high growth rates and the ratio of landfill input to other waste management options remaining at 6.9%pa. Thus equates to a maximum annual requirement of 4,631 tonnes per annum.

2.30 In respect of the waste streams being disposed off via landfill, a review of the types of materials landfilled using the 2009 Hazardous Waste Interrogator it is noted that this material is primarily asbestos materials (85%) that can be disposed of via stabilised non-reactive hazardous waste (SNRHW) landfill cells.

2.31 Currently there is no merchant hazardous or SNRHW capacity available in the Area and no potential capacity was identified during the study. In assessing the feasibility of developing appropriate capacity in the Area it was noted that:

The minimum landfill capacity required to make a site feasible is likely to be in the order of 50,000 tonnes for a merchant hazardous landfill facility or 10,000 tonnes for the development of a SNRHW cell in a non-hazardous landfill site;

The minimum landtake requirement for the development of a hazardous landfill site is 20 – 30 hectares with approximately 2 hectares required for development of a SNRHW cell within a non-hazardous landfill site;

Development of landfill capacity is restricted by geological criteria specified by the Environment Agency, particularly in relation to the potential impact on ground water (ie RGN 3) and as such future new landfill void capacity would most likely be restricted to areas within the area with clay as the main geological strata; and

The “Strategy for Hazardous Waste Management in England” (March 2010) identifies that there is sufficient hazardous and SNRHW capacity nationally.

2.32 As such there is insufficient evidence to support the development of hazardous landfill capacity either as merchant hazardous or SNRHW capacity within the Area. Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

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Recycling

2.33 Comparison with the predicted future capacity predictions indicate that over the life of the plan (ie to 2025/26) the total capacity needed for recycling of hazardous materials equates to up to 242,786 tonnes total for capacity based on high growth rates and the recycling targets being met. This equates to a maximum annual capacity requirement of 14,627 tpa.

2.34 The principle waste streams that are recycled include EWC 13 (Oils and Oily Water), EWC 16 (not otherwise specified) and EWC 20 (municipal) including batteries, WEEE and end-of-life vehicles. Current capacity equates to 41,482 tonnes and includes:

Material recycling facility in Lewes; Metal recycling facilities in Brighton, Lewes, Rother and Wealden; and End-of Life vehicle facility in Brighton.

2.35 In analysing waste streams that are exported and imported for recycling purposes it is noted that:

The main waste streams exported are 1829 tonnes of EWC 13 (Oil and Oil Water), 1664 tonnes of EWC 16 (not otherwise specified) and 1209 tonnes EWC 20 (Municipal) including WEEE, batteries and end-of-life vehicles; and

The main waste streams imported are 550 tonnes of EWC 16 (not otherwise specified) and 6,910 tonnes of EWC 20 (municipal) including batteries and WEEE.

2.36 Based on this analysis, there is sufficient evidence to conclude that:

MRS recycling capacity is adequate;

Recycling capacity for WEEE and battery waste streams is felt to be more than adequate for arisings from the Area. Although East Sussex exports these waste streams for recycling, it has been found that a greater volume of the materials is imported for recycling at facilities within the Area and as such it is therefore considered important for ESCC, BHCC and SDNPA to safeguard and promote the release of the current in-area capacity for its exported waste streams where possible; and All oil and oil water wastes (EWC 13) have been identified as being exported for recycling purposes with over 86% of the materials being sent to East of England and elsewhere in the South East. Although this suggests a capacity shortfall in the Area and the “Strategy for Hazardous Waste Management in England” (March 2010) identifies a national need for at least one further 80,000 tpa high quality oil regeneration plant, it is unlikely that this need would be met by a new facility in East Sussex as around 98% of materials would need to be imported to make the facility viable. It is recognised that novel recycling opportunities for this waste stream may become available in future and the Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

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study therefore recommends that ESCC, BHCC and SDNPA accept ongoing export of this waste stream while not discounting the development of novel recovery opportunities in the future.

Other Reuse and Recovery

2.37 Comparison with the predicted future capacity predictions indicate that over the life of the plan (ie to 2025/26) the total capacity needed for recovery of hazardous materials equates to up to 98,357 tonnes total for capacity based on high growth rates and the high reuse/recovery targets being met. This equates to a maximum annual requirement of 6,917 tpa.

The category includes facilities for:

Energy recovery; Solvent recovery; Plasterboard recovery; and Other facilities for material reuse

2.38 In respect to the waste categories being managed through a recovery route, it has been noted that:

11,368 tonnes of EWC 07 (organic chemicals) and 21 tonnes of EWC 14 (solvents) were recovered in the Area – less than 1 tonne of this material was generated in East Sussex. The solvent recovery route is managed by the SRM facility located at Rye, in the Rother district, which has sufficient capacity to manage the low level of solvent/organic that is produced in the Area. Additionally it is noted that this facility acts as one of the national recovery centres for this waste stream and as such safeguarding this capacity for the 11 - 12,000 tpa of waste solvents imported to the Area is critical;

A second recovery operation in the Rother district for a further 336 tonnes of EWC 07 (organic chemicals) in 2009 was located at Rye Oils, however the permit for this facility was surrendered in December 2009;

188 tonnes of EWC 07 (organic chemicals) was sent for incineration with energy recovery in the Rother District. It is understood that this material was also received by the SRM facility located at Rye and was used as recovered solvent fuel for its boilers;

British Gypsum have introduced a plasterboard recycling/recovery process at their Robertsbridge Works that facilitates the recovery of up to 18,000 tpa of plasterboard waste generated on site and recycling of up to 40,000 tpa of imported plasterboard wastes;

Planning permission has been granted for an ‘energy to waste’ plant for disposal of clinical wastes at Eastbourne District Hospital (Planning Application EB/643/CM). This plant also has an environmental permit and is designed to Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

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manage up to 5000 tpa clinical waste streams from EastbourneDistrictHospital and other hospitals in the Area. Once operational this will meet the capacity gap for clinical waste streams currently exported; and

In respect of the management of APC residues that are generated from the Newhaven ERF, these are exported to an appropriately permitted facility for management. It is not expected that a facility for the recovery or disposal of these residues would be developed in the Area.

2.39 Based on the above information there is sufficient evidence to support:

Safeguarding existing solvent recovery capacity in the Rother district as one of the national solvent recovery centres; Safeguarding existing plasterboard recovery capacity at Robertsbridge works to manage both local and imported gypsum based wastes; and Developing new clinical waste management capacity that facilitates recovery of energy either through the proposed facility at EastbourneDistrictHospital or a similar alternative scheme.

Incineration Without Energy Recovery

2.40 Comparison with the predicted future capacity predictions indicate that over the life of the plan (ie to 2025/26) the total incineration capacity needed for hazardous materials equates to up to 14,407 tonnes total for capacity based on high growth rates and the ratio of incineration without energy recovery to other waste management options remaining at 4.7%pa. This equates to a maximum annual capacity requirement of 854 tpa.

2.41 In respect of the available capacity within the Area, it was noted that:

Assessment of the materials incinerated found that these comprise 102 tonnes EWC 07 (organic chemicals), 457 tonnes EWC 18 (healthcare wastes) and 224 tonnes EWC19 (waste/water wastes) and very small volumes (<12 tonnes) of other EWC codes – all these wastes were exported;

The EfW facility in Newhaven; however, this plant is not permitted to accept hazardous waste streams;

Solvent wastes could potentially be managed via the SRM recovery processes in Rye rather than being exported for disposal by incineration;

Waste/water treatment wastes could potentially be managed via the SRM incineration process at the facility in Rye. In reviewing the permit for the SRM facility, it was confirmed that while the site had an overall permitted capacity of 31,250 tpa, this included 6,265 tpa of aqueous wastes (EWC codes 19 02 08 and 19 02 10) for incineration through its thermal oxidiser process; and

Once developed, healthcare wastes can be directed through the new energy from waste facility at Eastbourne. Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

Hazardous Waste

Incineration with energy recovery would be the preferred incineration route as this is higher up the hierarchy and realistically incineration without energy recovery is likely to reduce/cease in future years.

Treatment

2.42 Comparison with the predicted future capacity predictions indicate that over the life of the plan (ie to 2025/26) the total treatment capacity needed for hazardous materials equates to up to 78,518 tonnes total for capacity based on high growth rates and the ratio of treatment input to other waste management options remaining at 23.39%pa. This equates to a maximum annual capacity requirement of 4,682 tpa.

2.43 Currently all hazardous waste that is managed via a treatment route is exported mainly to other areas of the South East with smaller quantities going to the South West, East Midlands and East of England. Treatment is normally used as a pre-treatment prior to final disposal option or to facilitate a recovery process and an assessment of the wastes exported is summarised in the table below.

Table 2

EWC Description Tonnes Comment Exported

060404 wastes containing 0.11 Potential for mercury recycling/recovery

080111 waste paint and varnish 0.03 Potential for containing organic recycling/recovery solvents or other dangerous substances

080115 aqueous sludges 21.15 Potential for containing paint or recycling/recovery although varnish containing organic heavily contaminated will solvents or other most probably go for dangerous substances disposal

110107 pickling bases 14.52 Most likely disposal

110108 phosphatising sludges 18.00 Most likely disposal

110111 aqueous rinsing liquids 1.60 Most likely disposal containing dangerous substances

120109 machining emulsions and 58.52 Most likely disposal solutions free of halogens Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

Hazardous Waste

EWC Description Tonnes Comment Exported

130205 mineral-based 4.15 Potential for non-chlorinated engine, recycling/recovery gear and lubricating oils

130208 other engine, gear and 0.47 Potential for lubricating oils recycling/recovery

130307 mineral-based 25.57 Potential for non-chlorinated insulating recycling/recovery and heat transmission oils

130403 bilge oils from other 108.42 Potential for navigation recycling/recovery

130502 sludges from oil/water 12.25 Most likely disposal although separators may be an element of organic contaminant recovery

130503 interceptor sludges 329.40 Most likely disposal although may be an element of organic contaminant recovery

130506 oil from oil/water 1.00 Potential for separators recycling/recovery

130507 oily water from oil/water 325.76 Potential for separators recycling/recovery

130508 mixtures of wastes from 1045.10 Potential for grit chambers and recycling/recovery oil/water separators

130701 fuel oil and diesel 45.35 Potential for recycling/recovery

130703 other fuels (including 70.33 Potential for mixtures) recycling/recovery

130802 other emulsions 8.60 Most likely disposal

130899 wastes not otherwise 84.90 Most likely disposal specified

140603 other solvents and solvent 0.41 Potential for recovery mixtures Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

Hazardous Waste

EWC Description Tonnes Comment Exported

150110 packaging containing 0.54 Most likely disposal residues of or contaminated by dangerous substances

150202 absorbents, filter 1.16 Most likely disposal materials (including oil filters not otherwise specified), wiping cloths, protective clothing contami

160305 organic wastes containing 0.66 Potential for dangerous substances recycling/recovery

160504 gases in pressure 0.54 Most likely disposal containers (including halons) containing dangerous substances

160506 laboratory chemicals, 0.00 Most likely disposal consisting of or containing dangerous substances, including mixtures of laboratory chemicals

160601 lead batteries 1.09 Potential for recycling

161001 aqueous liquid wastes 131.96 Most likely disposal containing dangerous substances

170204 glass, plastic and wood 2.76 Most likely disposal containing or contaminated with dangerous substances

170503 soil and stones containing 257.14 Potential for recovery of dangerous substances organic contaminants and then reuse of soil or disposal via non-hazardous landfill

180103 wastes whose collection 1565.55 Most likely disposal although and disposal is subject to potential for incineration special requirements in with energy recovery order to prevent infection Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

Hazardous Waste

EWC Description Tonnes Comment Exported

180108 cytotoxic and cytostatic 78.63 Most likely disposal medicines

180202 wastes whose collection 11.75 Most likely disposal although and disposal is subject to potential for incineration special requirements in with energy recovery order to prevent infection

180207 cytotoxic and cytostatic 0.00 Most likely disposal medicines

190810 grease and oil mixture 0.46 Potential for from oil/water separation recycling/recovery other than those mentioned in 19 08 09

200113 solvents 0.03 Potential for recovery

200127 paint, inks, adhesives and 5.23 Most likely disposal resins containing dangerous substances

200129 detergents containing 0.01 Most likely disposal dangerous substances

2.44 Material exported for treatment comprised healthcare waste, construction wastes, oil wastes and wastes not otherwise specified (associated with end-of-life vehicles, batteries, gas bottles, tank cleaning wastes) and export appears to be directed to individual facilities for specific waste streams.

Transfer

2.45 Current hazardous transfer capacity is estimated at 39,720 tpa (71,271tpa) against an average annual transfer requirement of up to 30,000 tpa. This indicates that hazardous transfer capacity is more than adequate for future transfer requirements. It has however, been noted during the study that:

A09 (hazardous transfer stations) capacity annual capacity utilisation is around 70% although only very small volumes of WEEE, hazardous CD&E and hazardous municipal waste streams are passing through such facilities. This indicates that the facilities are mainly being used to transfer non-hazardous rather than being used just for the transfer of hazardous waste;

A11 facilities (ie HCI transfer) are being used for around 95% of the hazardous waste transfer within the Area. This is primarily associated with transfer of Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

Hazardous Waste

WEEE, batteries and chemical waste streams through facilities located at Rother and Wealden.

A13 facilities for clinical wastes streams appear to be taking very small volume of hazardous waste into the facilities although there is evidence of more hazardous waste being sent out of these facilities.

Capacity Conclusions

2.46 Using 2009 data, an assessment of capacity reveals the following:

Hazardous waste from East Sussex and Brighton and Hove disposed of to landfill was 85% asbestos materials and 55% contaminated soils and all of this material was exported from the Area.

Asbestos materials will be disposed off primarily at SNRHW landfill cells and this management route is likely to remain the only or ‘least worse’ route for the management of these materials. In looking at in-Area capacity, although there is currently one operational non-hazardous landfill in the Area, this does not currently provide SNHRW capacity and it is unlikely that such capacity could be released.

Contaminated soils may be disposed of at true hazardous landfills, however, there is no true hazardous merchant landfill capacity in the Area; the closest sites are located to the north in Northamptonshire, and to the west in Wiltshire and Gloucestershire, as previously noted, and these are more than 2½ hours travel-time by road from the Channel coast.

In addition to the specific local considerations the “Strategy for Hazardous Waste Management in England” (March 2010) was reviewed in respect of landfill capacity and this identified there is sufficient SNRHW and hazardous landfill capacity nationally. This evidence on national capacity coupled with the limited opportunity to develop any additional landfill capacity in the Area means that there is insufficient evidence to support any suggestion that development of landfill capacity for SNRHW or merchant hazardous waste is likely during the plan period.

In terms of Newhaven Energy From Waste facility, it should be noted that APC residue from this site is classified as hazardous and is managed beyond the Area. It is unlikely that a facility for managing APC residues would be developed in the Area. In looking at the management of APC residues specifically, the “Strategy for Hazardous Waste Management in England” (March 2010) identified that moving waste further up the hierarchy to recovery rather than disposal accords with the policy approach within the WFD and that there is likely to be a need for around 5 additional APC treatment facilities of 33,000 tpa each on a national basis if all planned energy from waste facilities are delivered. However, given the locality of the Newhaven facility and the volume of APC residue it produces, to locate a new APC treatment/recovery plant in East Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste

Hazardous Waste

Sussex would require import of around 26,000tpa APC residue to make such a facility viable. Therefore in applying the proximity principle, it would be better to locate any new facility closer to the source of the imports (ie outside of the area) and export Newhaven APC.

Hazardous transfer capacity is located across the Area in facilities classified as A09, A11, A12 and A13; this is for bulking and onward transmission to locations for disposal, treatment and/or recycling/recovery elsewhere, although for some there is an element of treatment and/or recycling/recovery on-site. Assuming a worse case that all hazardous waste generated in the Area requires some form of transfer, based on future predictions, there is more than sufficient capacity at the existing sites.

Based on the relative import:export data from 2009, treatment capacity continues to be unavailable in the Area; import/export activity is focussed on oil waste, oil/water mixtures, construction, demolition and asbestos wastes, healthcare wastes and Chapter 16 wastes (e.g. batteries, WEEE). Given the quantities and types of waste being exported for treatment to specific sites there is insufficient evidence to support development of specific treatment facilities in the Area although the Councils should not rule out the future development of novel treatment techniques for specific waste streams or use of mobile treatment plants for CD&E wastes close to source of production.

Based on the 2009 data set, recycling/recovery facility coverage is predominant in Lewes, Rother and Wealden and is focussed mainly on WEEE, batteries and organic waste streams. It was noted that while the area acts as a net importer for recycling and recovery for these waste streams, it also exports similar materials; therefore in relation to future capacity, it is recommended that the site operators are engaged to identify if management of in-Area generated wastes can be increased. The 2009 data shows that around 870 tonnes of organic chemicals was imported for incineration with energy recovery, while wastes exported for incineration were primarily made up from healthcare and oil wastes. In respect of available in-Area incineration capacity there is incineration capacity available at the SRM facility in Rye which should be sufficient for any future arisings. The development of a new waste to energy incinerator for healthcare waste in Eastbourne is expected to address current needs. MRS treatment capacity has been assessed as more than adequate.

Export of hazardous waste for management

2.47 A survey of facility operators, and WPAs has found that it is reasonable to assume that out-of-County facilities will continue to provide for the management of the substantial portion of both the hazardous and low-level radioactive (LLW) waste arisings from within the Council’s area for the Plan period(12).

12 Hazardous Waste – Review of the Future Management Needs - Operator and WPA Survey, URS/Scott Wilson, February 2012 Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste Appendix 1- List of other information papers prepared Appendix 1- List of other information papers prepared

1. The Future Need for Waste Management 2. The Future Need for Minerals Production and Management 3. Sustainable Waste Management 4. Waste Management Methods and Technologies 5. Land Disposal 6. Spatial Portrait of East Sussex, Brighton & Hove and the South Downs 7. Hazardous and Radioactive Waste 8. Transportation of Waste and Minerals 9. Climate Change and Waste and Minerals 10. Waste Water and Sludge Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste Appendix 2 - International and national legislation in relation to this Information Paper Appendix 2 - International and national legislation in relation to this Information Paper

European Directives

The legislative and policy requirements for management of waste in the UK are initiated through the various framework directives and strategies developed within, and emanating from, the European Union. Such legislation and policy initiatives are translated into national legislation and strategy for implementation.

The main directives directly or indirectly affecting the management of hazardous waste in the European Union are:

The Waste Framework Directive (WFD), that provides the basis for the formulation of European and national legislation and strategy – this directive has undergone a review since the ERM study was completed and recommendations have been made in respect of a number of issues including the waste hierarchy, rules on waste treatment, waste status of uncontaminated soils, and classification of waste as hazardous;

The Hazardous Waste Directive (HWD) that provides the basis for the definition and management of hazardous waste and is implemented through the Hazardous Waste Regulations (2005);

The Landfill Directive that provides a framework for the improvement of waste management practice and specifically landfill – since the ERM study was completed, the Regulations have introduced a requirement that all hazardous and non-hazardous waste being sent to landfill must first go through some form of pre-treatment; implications for landfill from this measure are expected to see a lower volume of waste going for final disposal as material is first sent for treatment/recovery. This Directive also details the requirements governing the banning of co-disposal at landfills which has impacted on waste streams such as plasterboard and has prompted the development of stabilised non-reactive hazardous waste (SNRHW) cells at some non-hazardous landfills;

The Waste Incineration Directive (WID) details a framework for the management of waste incineration, aiming to reduce the impact of incineration activities on the environment; and

The Mining Waste Directive (MWD) that provides a framework for regulating mining waste facilities through a permitting regime.

Environmental Permitting Regulations Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste Appendix 2 - International and national legislation in relation to this Information Paper The Environmental Permitting (England and Wales) Regulations 2007 took effect from 6th April 2008, and provide a new permitting framework against which all waste facilities, including hazardous waste treatment and disposal facilities will be regulated. The initial implementation of the Regulations included Pollution Prevention and Control (PPC) regulated activities, such as landfill sites, incineration plants, treatment processes, recovery processes, and Waste Management Licensing (WML) regulated activities, such as transfer stations.

Initial implementation of the Regulations during 2008 continued the previous regulatory approach required by PPC and WML regulations, and it is unlikely that it has made a significant change to the level of hazardous waste management capacity across the UK. However, in October 2008, the Environment Agency consulted on changes to the section of the regulations pertaining to exemption activities, including those associated with construction wastes generated during land remediation projects.

The changes that are proposed to take effect from 1st October 2010 will see the need for operators remediating land to apply for an environmental permit rather than an exemption for waste production amounting to more than 300 tonnes. The application and ongoing subsistence charges associated with the new permit procedure will increase costs to operators, and this may lead them to dispose of material to landfill, rather than look at reuse or treatment options on a site.

Other Regulations and Directives

Other legislative and policy drivers that affect hazardous waste management in the UK provide a range of regulatory and fiscal impetus to both encourage the minimisation of hazardous waste generation and to move the management of any hazardous waste that is generated further up the waste hierarchy. The main drivers include the:

Landfill Tax Regulations, that provide a financial impetus to decrease the quantity of all waste (including hazardous waste) from disposal in landfill;

Waste Electrical and Electronic Equipment (WEEE) Directive (2002/96/EC and 2003/108/EC), that aims to minimise the impact of waste from electrical and electronic sources on the environment;

Restrictions on the Use of Certain Hazardous Substances (RoHS) in Electrical and Electronic Equipment, that supplements the WEEE Directive and aims at reducing the impact from such equipment on the environment;

Waste Oil Directive (75/439/EEC, as amended by Directive 87/101/EEC), that aims to provide a harmonised framework for the management of waste oils and thus reduce the impact on the environment;

End of Life Vehicles (ELV) Regulations 2003 and 2005, that are aimed at reducing the amount of waste produced from ELVs and optimising the recycling and recovery rates; Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste Appendix 2 - International and national legislation in relation to this Information Paper Batteries Directive (2006/66/EC), that is aimed at promoting recovery and recycling of waste batteries;

PCB/PCT Directive (96/59/EC), that is aimed at streamlining the legislation in relation to the decontamination or disposal of equipment containing PCBS/disposal of PCBs in order to ensure their complete elimination;

The Control of Asbestos Regulations 2006, that merges three earlier sets of regulations incorporating prohibition of asbestos, supply and control of asbestos at work;

Waste Management Regulations 2006, that extend the regulatory control of waste to agricultural waste including hazardous arisings; and

Registration, Evaluation, Authorisation & Restriction of Chemicals (REACH) Regulations that provide a framework for the evaluation, management & registration of chemicals. Include influencing production & management of hazardous waste.

The implementation of the new regulatory regimes as indicated in the list above is aimed at providing, among other requirements, appropriate waste management approaches for the individual waste streams, many of which are hazardous in nature. The focus from a waste management perspective is again hierarchical, with minimisation preferred before reuse, and recycling and recovery preferred before disposal, whether to landfill or thermal destruction.

The introduction of the new regulatory framework has already seen an increase in certain recycling and recovery facilities (e.g. for WEEE), and, as they become established, it is anticipated that further facilities will come on-stream, thus reducing the need for landfill capacity for these wastes in the longer term.

National Waste Strategy

The Waste Strategy 2007 (WS2007) was issued in May of that year, and now forms the adopted national waste strategy, developed to provide further strategic direction for the minimisation and sustainable management of waste for the period until 2020. The document is based on waste data collated since WS2000, and sets out a number of targets and national goals for improvements in waste management in England and Wales.

Key targets have been set for recycling, recovery and diversion from landfill for the household, commercial, industrial, agricultural, construction and demolition waste sectors, including those defined as hazardous.

Regional Spatial Strategy Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste Appendix 2 - International and national legislation in relation to this Information Paper In the South East, regional planning policy (known as ‘Regional Spatial Strategy’ (RSS)) currently exists in the form of the ‘South East Plan’ (SEP)(13). The RSS sets out the long term spatial planning framework for the region over the period 2006 to 2026, and contains spatial policies including strategies for protecting countryside, biodiversity and the built and historic environment.

Regulations provided by the Localism Act 2011 will revoke Regional Spatial Strategies and it is expected that these will come into force in 2012. Currently though, the SEP is still part of the development for the Plan Area and needs to be considered.

The RSS includes a policy in respect of hazardous waste management (W15) which states:

“The regional planning body and the South East Regional Technical Advisory Body for waste, through the Hazardous Waste Task Group will maintain guidance on regional hazardous waste management requirements. Current priority needs include: i. Hazardous waste landfill capacity, particularly to serve the needs of the south and southeast of the region; ii. Treatment facilities for air pollution control residues (from combustion facilities); iii. Treatment/de-manufacturing plant for waste electronic and electrical equipment, supported by a network of transfer facilities; iv. A sub-regional network of contaminated C&D waste treatment facilities; v. A sub-regional network of landfill cells for stabilised non-reactive hazardous wastes.

Waste development documents will: vi. Identify and safeguard sites for storage, treatment and remediation of contaminated soils and demolition waste. vii. Identify criteria for the determination of large scale specialist hazardous waste facilities. viii. Assess available landfill provision and, where necessary, encourage the creation of a protective cell for stable hazardous waste.

The SE Plan also contains a number of long-term recycling and reuse targets for various wastes streams including commercial and industrial (C&I) and construction, demolition and excavation (C, D & E) wastes.

13 available at http://webarchive.nationalarchives.gov.uk/20100528142817/http://www.gos.gov.uk/gose/planning/regionalPlanning/815640/ Information Paper 7 - Hazardous Waste and Low Level Radioactive Waste Appendix 3 - Further references and information sources Appendix 3 - Further references and information sources

ESCC and BHCC (2000) East Sussex and Brighton & Hove Waste Local Plan Technical Background Paper 4: Special and Difficult Waste Defra (2005) Integrated Pollution Prevention and Control: a Practical guide (www.defra.gov.uk/environment/ppc/envagency/pubs/pdf/ippcguide_ed4.Pdf)

Defra and DTI (2007) Managing Radioactive Waste Safely: A Framework for implementing geological disposal. A public consultation by Defra and DTI Environment Agency guidance about Hazardous Waste (http://www.environment-agency.gov.uk/business/topics/waste/32180.Aspx) SEERA (2005) Overview of Hazardous Waste in South East England, Beyond Waste www.southeast-ra.gov.uk/publications/strategies/waste/research/hazardous_waste.pdf www.hazguide.co.uk Provides advice for all those managing household hazardous type waste including businesses, and disposal authorities and waste management companies. 'Dealing with hazardous waste on your farm': http://www.environment-agency.gov.uk/business/sectors/115666.aspx Waste and Minerals Policy Team Planning Service - Transport & Environment East Sussex County Council WasteCounty and Hall Minerals Policy Team PlanningSt Anne’s Service Crescent – Economy, Transport and Environment EastLewes Sussex County Council CountyEast Sussex Hall StBN7 Anne’s 1UE Crescent Lewes East01273 Sussex 481846 BN7 1UE 01273Planning 481846 Strategy & Projects Brighton & Hove City Council PlanningHove Town Strategy Hall & Projects BrightonNorton Road& Hove City Council HoveHove Town Hall NortonEast Sussex Road HoveBN3 3BQ East Sussex BN301273 3BQ 292505 01273 292505 2561 design by www.graphicdesignteam.org.uk

[email protected] http://consult.eastsussex.gov.uk

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