Case Studies
In this section...
Material classification and recycling, with regulatory agreement
Paper Sludge Ash (2013 ongoing)
A large UK group requested support for the hazard assessment of a waste from paper manufacture generating ~70,000T pa. The waste was high in alkalinity with trace metals and could have triggered characterisation as a hazardous waste.
HWR were able to analyse 4 years of captured data, assess analysis gaps which could have left ambiguity and regulatory questions about the hazardous nature of the material, (ie the form of alkali present and how this could be evaluated analytically), direct analytical resources to get credible data to fill the data gaps. Culminating in a report which included outline agreement with the Environment Agency technical team led to confirmation of the non hazardous nature of the material/waste.
The outcome allowed the material to be diverted from landfill, recycled as a raw material replacement and saved a six figure sum.
International Agreements with multiple regulatory partners, EPR permits and COMAH
Higher Tier COMAH Waste Storage (2010 – present)
In October 2010 a major UK hazardous waste specialist was asked to offer a solution to a 8000T stockpile of pesticide contaminated soil being excavated in the Ukraine. HWR were asked to identify options for the intermediate storage of the material as it had to leave the site by the end of December 2011. There was at the time no available COMAH storage capacity in the UK for the 5000T of material that could not be shipped directly to the UK incinerator.
We worked with the UN, Defra, the EA, anti-terrorism forces, local planners and a specialist COMAH warehousing company to agree planning and achieve permitting of the warehouse for up to 8000T of pesticide contaminated soil, achieving this in late December 2011.
The consequence was 8,000T of internationally significant waste was imported, stored and treated appropriately and the UK gained a valuable higher tier COMAH waste storage facility for future use.
In 2013 HWR worked with the site team to vary the permit in line with changes in the Environmental Permitting Regulations when the Industrial Emissions Directive was incorporated. The Permit was successfully amended in December 2013. This allows the site operator to develop their business in a wider range of waste types from many business sectors.
Consultancy Support for in house business team in relation to specialist legislation
Assessment of the coding of treatment plant outputs with respect to the Animal Bi Products Regulations (April 2013 ongoing)
HWR are working with a multinational pharmaceutical business in relation to the coding of ABP waste after treatment in a approved technical plant. HWR assessed the historical coding position and found that it had not been revised in light of adoption of new European ABP Directives.
HWR produced a report outlining their interpretation of the new position which should supercede the restrictions place in the original permission, allowing the residue to be recycled rather than disposed.
Jointly rather than simply revise the procedures, HWR, the Client, representatives of Animal Health and Veterinary Laboratory Agency (AHVLA) met sent a proposal forward to DEFRA which demonstrated that revision was necessary in the permission.
The process is ongoing but appears to be nearing conclusion and the treatment plant residue is likely to be able to be recycled.
Practical Solvent Recycling using waste as raw material substitutes
Solvent Recovery as a raw material or fuel (2013 ongoing)
HWR have worked with two Midlands based sites to offer recovery options for liquid organic waste streams. Both have permits that allow wastes to be taken and reused either as a raw material substitute or fuel.
The first is a chemical manufacturing company where we have developed in partnership to take waste solvents for use in the site boilers to generate steam. This offers an alternative recycling route for the issue of recovery (R) codes to suppliers keen to see their materials reused. The site is registered as a lower tier COMAH facility and can take solvents contaminated with pesticides, herbicides, PCBs, halogenated solvents, mercaptans, TBT and other odorous materials.
The second is a reprocessor of solvents for the production of basic thinners. The wastes are analytically assessed and blended on site to meet specifications for use in the thinners blend.
The advantage to all parties is reduced costs and issue of producer returns detailing recovery codes for the waste producer.
Practical Support for in house service relating to planning issues
Planning Application and (DAS) Design and Access Statement (July 2013)
Working with the primary contractor HWR completed and submitted a DAS and Planning Application for a new effluent settlement system at a high capacity hazardous waste treatment facility in Wales. The submission was completed within 2 weeks of the request being made. This was achieved by working closely with the client, the designer and the planning authorities. This process was potentially fraught as the initial planning permission for the site was referred to the Secretary of State as the local authority opposed the development of the site for waste treatment and removed all permitted development rights.
By working with the local Planning department a pre-planning agreement was made, which simplified the scope of the application, thus reducing the application charges and enabled the planning permission to be issued on time without recourse to a planning committee.
Practical Support for in house service relating to legal compliance
Legislation Compliance review (May / June 2013)
A large waste oil processor requested support for assessing their business compliance after an incident. The support took the form of audits of 3 key facilities, resulting in a report and action plan for improved compliance. HWR met with the MD of the company to talk through the key findings and outline how the action plan proposal could be undertaken efficiently.
The report was accepted and the action plan adopted, which improved compliance with relation to collection of large numbers of small collections of waste, where the mechanism for transfer of information was overhauled resulting in simpler systems for the drivers, operators and clients.
The process resulted in a reduced business risk and by applying these changes to the existing system ongoing savings were identified. The business has subsequently been successfully sold to an investor.
Practical Support for the senior management team for HSEQ compliance
Legislation Compliance System Development (Sept 2013 ongoing)
A specialist hazardous waste decontamination and industrial cleaning company was referred to HWR by another client. The senior management team recognised the business needed a HSEQ specialist but had been unable to find a suitable candidate. HWR worked with them to develop an action plan using gap analysis, audit and interview techniques.
This has resulted in a significant increase in the profiling of HSEQ within the business, from revision of the policies and website, to development of medical surveillance, increased clarity of risk assessments their communication within the team and the business has applied for an International Safety Award which is being determined by the British Safety Council.
The business has seen an uplift in employee engagement and involvement in HSEQ business area and several improved assessments by external auditors and clients.