Do you know how you ensure that soil and stone waste should be recovered or disposed off in accordance with regulatory requirements and to mitigate against potential future liability?
- Recovery and disposal of soil and stone waste must be to a suitably licensed facility (Waste Licence, Waste Facility Permit or Certificate of Registration (COR).
- Transport of soil and stone waste must be undertaken by a suitably licensed contractor
- Accurate classification of soil waste is required.
- Classification of soil waste can have a significant direct and indirect impact upon costs and potential liabilities.
- Soil waste would be classified using the Waste Acceptance Criteria (WAC).
- WAC should be used by the receiving site to determine whether it can accept the soil and stone in accordance with its licence, permit or COR.
The gate fee for accepting a material is largely determined by its classification. The costs associated with soil and stone which is considered to be contaminated and/or hazardous is significant. The cost of remediating a site which has inadvertently (or perhaps deliberately) accepted wastes which were not covered under a licence, permit or COR can prove to be in excess of that covered by any insurance policy or bond.
There are additional options and less cost involved in managing inert soil waste. However
- There is limited capacity nationally for the recovery/disposal of inert soil and stone waste.
- Additional capacity pressures could result from the failure to allow byproduct status to clean/uncontaminated soil and stones.
- Draft guidance on the setting of soil trigger levels suggests that more stringent limits may be imposed for soil recovery facilities.
- The current cost-benefit in operating a soil and stone waste recovery/disposal facility is marginal at best.
- The current waste facility permits are restricted to receiving a maximum of 100,000 tonnes over the lifetime of the facility.
- The cost of obtaining and managing a facility to receive in excess of 100,000 tonnes under a Waste Licence is excessive to the point of being non-viable for most operators.
It is essential therefore:
- To determine whether soil and stone for recovery or reuse is a waste
- If soil and stone is a waste it must be accurately classified to ensure that it is transported and recovered/disposed off to a suitably authorised facility.
- To receive the necessary guidance to correctly classify soil and stone waste.
ECOS has extensive experience in the classification and management of soil and stone waste. Our phased approach to soil waste classification may be summarised as follows:
- Investigation to determine the the nature and extent of potential contamination
- Sampling and analysis to quantify potential contaminants or the absence thereof.
- Assessment to determine the most appropriate List of Waste (LoW) code for the waste
- Determination of the Waste Acceptance Criteria (WAC) based on analytical data.
- Present options for the recovery/disposal of soil and stone in compliance with regulatory requirements.
Please contact us to learn more about the correct classification of soil waste, Waste Acceptance Criteria (WAC) and the recovery/disposal of soil and stone to a licensed facility.
T: +353 (0) 61 633644 E: firstname.lastname@example.org W: www.ecos.ie