Offsite transfer of waste EPER/E-PRTR module ECENA training workshop Bristol,19 March 2008 Michel Amand Belgian Head of delegation PRTR Chair of the WG UNECE Protocol on PRTRs

Regulation 166/2006 on E-PRTR n An off-site transfer of waste means the movement beyond the boundaries of a facility of waste destined for disposal or recovery. n Operators shall report off-site transfers of - hazardous waste (HW) exceeding 2 tonnes per year - non hazardous waste (non-HW)exceeding 2,000 tonnes per year n for any operations of recovery or disposal with the exception of the disposal operations of land treatment and deep injection, as these have to be reported as releases to land.

Regulation 166/2006 on E-PRTR n Waste’ means any substance or object as defined in Article 1(a) of Council Directive 2006/12 on waste (Waste FD). n "waste" shall mean any substance or object in the categories set out in Annex I (categories of waste) which the holder discards or intends or is required to discard n ! Waste <> by products n ! Industrial complex with different operators

Regulation 166/2006 on E-PRTR n ‘Hazardous waste’ means any substance or object as defined in Article 1(4) of Council Directive 91/689/EEC on hazardous waste. n These wastes must have one or more of the properties listed in Annex III. n The list shall take into account the origin and composition of the waste and, where necessary, limit values of concentration. This list shall be periodically reviewed and if necessary by the same procedure, n any other waste which is considered by a Member State to display any of the properties listed in Annex II n ‘Non hazardous waste’ means any waste which is not ‘Hazardous waste ’

Regulation 166/2006 on E-PRTR n All data have to be expressed in tonnes/year of (normal) wet waste and with three significant digits n With respect to the threshold value the sum of waste transferred off-site is relevant, irrespective of whether it is treated within the country or it is transferred to another country or whether it is disposed of or recovered. n The operator has to indicate whether the waste is destined for recovery (“R”) or for disposal (“D”).

Regulation 166/2006 on E-PRTR n If the waste is destined for waste treatment that includes both recovery and disposal operations (e.g. sorting), the treatment operation (R or D) for which more than 50% of the waste is destined should be reported. n In those rare cases where the facility is not able to trace whether more than 50% of the waste is disposed or recovered, then code “D” should be used. n For transboundary movements of hazardous waste, the name and address of the recoverer or the disposer of the waste and the actual recovery or disposal site have to be reported

Regulation 166/2006 on E-PRTR n Operators should indicate whether the amount of waste was measured (e.g. by the method of weighing), calculated (e.g. by emission or release factors) or estimated. n No measurement available ? n For waste : use factors agreed on international, national or sectoral level which, for example, indicate the waste amount in relation to the material produced or the input of raw material.

Regulation 166/2006 on E-PRTR Release to land n The reporting on “releases to land” applies only to pollutants in waste which is subject to the disposal operations “land treatment” or “deep injection”. n If waste is treated in such a way this shall only be reported by the operator of the facility originating the waste. n Sludge and manure spreading are recovery operations and therefore not reported as releases to land. n Accidental releases of pollutants onto the soil on the site of a facility (for example spillages) do not have to be reported.

Regulation 166/2006 on E-PRTR Release to land n Accidental releases to land are theoretically possible (for example due to the leakage of a pipeline at the location of deep injection) but it is expected that they will only occur in very rare cases. n The relevant disposal operations according to Article 6 are mainly land treatment of oily sludge and deep injection of saline solutions underground. The off-site transfer (e.g. via pipeline) which often precedes the release to land for those cases need not be reported

Other sources of information n Reporting under Regulation 2150/2002 on waste statistics n Reporting under Directive 91/689 on hazardous waste n Reporting & notification under Regulation 1013/2006 on shipment of waste n Basel Convention n Regulation 850/2004 concerning persistent organic pollutants n Stockholm Convention n Complementary and interlinked