Waste Minimisation

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The Regulation of Composting Processes 28 APRIL
2005
Colin Gray SEPA
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Composting Processes

• 3 options for regulation
• Operate under an exemption (Para 12 WMLR 1994)
• Operate under a waste management (Section 35 EPA)
• Operate under a PPC permit (PPC (Scotland) Regs
  2000 Section 5.3 (c) )

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Composting exempt activity

• Subject to compliance with
• Waste types (listed with EWC codes)
• Tonnages treated, stored etc tied to type of
  composting process undertaken
• Processed material may remain a waste subject to
  restrictions under WMLR or may be considered a
  product (PAS 100 and other criteria met)

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Composting WML or PPC
Two main considerations will determine whether
WML or PPC should be applied

• The wording of PPC Section 5.3 (c)
• (c) Disposal of non-hazardous waste in plant with
  a capacity exceeding 50 tonnes per day by-
• (i) biological treatment specified in
  paragraph D8 of Annex IIA to Council Directive
  75/441 or(ii) physico-chemical treatment
  specified in paragraph D9 of Annex IIA to Council
  Directive
• The end use of processed wastes

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Composting WML or PPC

• In simplistic terms product from composting black
  box can take 2 routes

• Disposal (eg disposal at a landfill site)
• Recovery (eg PAS 100 and other criteria met
  used as product)

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Composting WML or PPC

• A PPC permit is acceptable under Waste Framework
  Directive
• A WML is not acceptable under PPC Directive
• As a result starting point is to consider PPC
  requirements tonnage and disposal or recovery
• If over tonnage limit then key factor is disposal
  or recovery of processed waste

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Composting WML or PPC

• What if processed waste goes both for disposal
  and recovery?
• Unless operator can demonstrate adequate
  recovery routes available for all processed waste
  SEPA will assume disposal and PPC as a
  consequence.

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Composting WML or PPC

• Recovery/Disposal and diversion from landfill
• Landfill Allowance Scheme (Scotland) Regulations
  2005 came into force 1/04/05
• Guidance on working procedures including
  clarification on when waste considered diverted
  is imminent
• Remade Biowaste Document currently being
  finalised example given considers use of 30cms
  of biowaste on closed landfills as restoration
  layer site specific consideration needed on max
  depth to be considered diverted/ recovered and
  not disposed of

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Conclusion

• Composting waste is a licensable activity
• Consider tonnages and waste types
• Is processed waste disposed of or recovered?
• Early dialogue with SEPA essential both for
  licensing and diversion considerations