TEEP Assessment to Meet the Conditions of the Waste ... Chorley v3.pdfTEEP tests to determine if...

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TEEP Assessment to Meet the Conditions of the Waste (England and Wales) Regulations 2011 and Waste

(England and Wales) (Amendment) Regulations 2012

Report Prepared by: Jo Oliver - Public Protection, Streetscene and Community Directorate

December 2014

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Contents

1. Executive Summary ……………………………………………………………………………………………………………………… 3

2. Introduction and Background to the Regulations ……………………………………………………………………….. 6

3. What Waste is Collected and How ………………………………………………………………………………………………. 7

4. Applying the Waste Hierarchy …………………………………………………………………………………………………… 15

5. Is a Separate Collection for the Four Materials Required? ………………………………………………………….19

5.1 How Does Chorley Compare? ………………………………………………………………………………………………… 19

5.2 The Necessity Test for Paper ……………………………………………………………………………………………………19

5.3 The Necessity Test for Metals …………………………………………………………………………………………………. 20

5.4 The Necessity Test for Plastics …………………………………………………………………………………………………. 20

5.5 The Necessity Test for Glass …………………………………………………………………………………………………… 21

5.6 Conclusion ……………………………………………………………………………………………………………………………… 22

6. The TEEP Test for Collection of Glass from the Kerbside …………………………………………………………. 22

6.1 Technical Appraisal for Glass …………………………………………………………………………………………………. 23

6.2 Environmental Appraisal for Glass …………………………………………………………………………………………. 23

6.3 Economic Appraisal for Glass …………………………………………………………………………………………………. 25

7. Overall Conclusion …………………………………………………………………………………………………………………… 27

8. Sign off and Review …………………………………………………………………………………………………………………. 28

9. Appendix – Supporting Data ……………………………………………………………………………………………………… 29

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1. Executive Summary

The Waste (England and Wales) Regulations 2011 require local authorities to apply the waste

hierarchy (Regulation 12) to the waste they are responsible for and to determine whether they are

required to collect glass, metal, paper and metal separately (Regulation 13).

Regulation 12 requires local authorities to apply the waste hierarchy to each material they collect.

Departure from the hierarchy is permissible when the measures that would be required would not

be “reasonable in the circumstances” or when departure will “achieve the best overall

environmental outcome where this is justified by life cycle thinking on the overall impacts of

generation and management of the waste”.

Regulation 13 states “that from 1st January 2015 all Waste Collection Authorities will be required to

collect paper, metals, plastics and glass (the materials) separately, where doing so is;

Necessary to ensure that waste undergoes recovery operation in accordance with Articles 4

and 13 of the Waste Framework Directive and facilitate or improve recovery; and

Technically, environmentally and economically practicable.”

A route map to help Local Authorities understand the steps they need to undertake to see if their collection method is compliant was produced by the Waste Resource Action Programme (WRAP) in April 2014. This assessment follows their route map.

1.1 Application of the Waste Hierarchy Chorley Council is a Waste Collection Authority (WCA) and along with the other WCAs in Lancashire and the Waste Disposal Authority (WDA), Lancashire County Council is a member of the Lancashire Waste Partnership (LWP). The LWP has put in a place the Lancashire Waste Strategy. This follows the

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principles of the waste hierarchy and 91% of municipal waste in Chorley Council’s area is collected at the kerbside from households. There is a high level of participation in the Council’s kerbside recycling schemes in part due to the simplicity of the collection system provided.

Lancashire County Council as waste disposal authority is responsible for providing disposal and recycling facilities for waste collected by Chorley Council. Nearly all waste and recycling collected by Chorley Council is delivered direct to the Leyland Waste Technology Park (LWTP) at Farington. A significant proportion of the material that cannot be currently recycled at the kerbside is plastic tubs, pots, film and trays. The Council is working with LCC, the Waste Disposal Authority to see if viable end markets for this material can be found.

The appraisal of Chorley Council’s current collection system concludes that the requirements of Regulation 12 have been met.

1.2 The Necessity Test

The purpose of this test is to see if separate collection of “the materials” is necessary to ensure the waste is recycled and to “facilitate or improve recovery”. Improved recovery is where more waste is recycled than subject to other recovery and/or more of the recycling is “high quality”. High quality recycling is generally thought of as closed loop recycling where the material is reprocessed back into a product of similar quality to what it was originally. The collection system operated by Chorley Council ensures a high yield of material is collected through kerbside collections. Paper and card are kept separate from other materials so the quality of the material is good. Plastics and metals can be easily separated at Leyland Waste Technology Park (LWTP) to achieve a good quality material that meets reprocessers’ specifications. The recovery of glass however means that currently 46% of the glass collected at kerbside is recycled into road aggregate rather than closed loop recycled into glass bottles and jars. This is due in part to the majority of glass cullet output from the Materials Recovery Facility (MRF) at LWTP being <25mm. In October 2014 trials commence with the reprocessors of glass to see if a cullet greater than 8mm could go for remelt. If this trial is successful then a greater proportion of cullet will be used for remelt. However as the necessity test is being applied to 2013/14 data the recovery of glass is likely to be improved i.e. a greater proportion of glass being above 25mm if separate collection of glass was introduced. Paper and card are already collected separately from other materials, and the material is of a high quantity and quality and goes for close loop recycling. Separate collections of metals and plastics are unlikely to increase the quantity and quality of recycling. Nearly all of these materials go for closed loop recycling. However, a separate collection of glass is likely to increase the proportion of cullet that could go to remelt i.e. closed loop recycling. 1.3 The TEEP Test for Kerbside Collection of Glass The TEEP test requires local authorities to ascertain if it is Technically, Environmentally, and Economically Practicable to collect recyclables separately but only where collecting separately to facilitate or improve recovery. Glass needs to be subjected to this test. Technical Assessment Kerbside sort where all material is collected in one vehicle pass, but glass is manually sorted by the collection crew to be kept separate from comingled plastic and metals was determined as the

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collection method most likely to improve recovery, and increase the percentage of glass available for closed loop recycling. This method of collection is technically feasible though it is likely to result in lower tonnages of glass as 55l boxes would be provided to residents rather than the current 240l wheeled bins. It would also require changes to our existing vehicle fleet, purchase of new containers for households and raises concerns over how sorting of boxes could be safely carried out by collection crews on busy highways. Environmental Assessment This assessment was based on the carbon dioxide equivalent tonnages avoided. Carbon dioxide is a major contributor to climate change.

The assessment covered three main areas;

Reprocessing of glass either as closed or open loop recycling

Transport emissions through changes to the vehicle fleet required for kerbside sort

Sorting emissions for commingled or kerbside sort

Overall the carbon impact of collection, sorting and reprocessing using a kerbside sort method for glass showed an increase of over 220 tonnes of additional carbon dioxide emissions due to increases in transport emissions. It is not environmentally practicable to collect glass separately at the kerbside because it would result in more carbon dioxide emissions due to increased transport as changes in the vehicle fleet would require more journeys to LWTP as vehicle capacity is reduced. Economic Assessment The introduction of a kerbside sort system for glass would greatly increase collection costs. It is calculated there would be a one off capital cost of £1.35 million which would finance new containers and vehicles, along with additional annual costs of £475,000 for extra crews and vehicle maintenance. If the capital costs were spread over 8 years the annual cost to change to kerbside sort glass collections would be £643,750. This figure does not include borrowing charges or any uplift for inflation. Therefore, it is not economically practicable to introduce a kerbside sort system for Chorley. 1.4 Conclusion Separate collections for paper and card are already in place and achieve a good capture rate of high quality material that is closed loop recycled. A separate collection of plastic or metals is unlikely to improve recovery. These materials are currently collected co-mingled. The current collection method achieves a high participation, generates high quality materials and materials go for closed loop recycling. Glass is currently collected comingled with plastic and metals. A separate kerbside collection is likely to increase in the quality of the glass collected and mean more glass would be recycled through closed loop. This material was then taken through the TEEP test however both environmentally and economically it is not practical to introduce a separate kerbside collection for glass.

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2. Introduction and Background to the Regulations

The EU Waste Framework Directive provides the legislative framework for the collection, transport, recovery and disposal of waste. The Directive requires all Member States to take the necessary measures to ensure waste is recovered or disposed of without endangering human health or causing harm to the environment and includes permitting, registration and inspection requirements. The Directive also requires member states to take appropriate measures to encourage firstly, the prevention or reduction of waste production and its harmfulness and secondly the recovery of waste by means of recycling, reuse or reclamation or any other process with a view to extracting secondary raw materials, or the use of waste as a source of energy. The Directive’s requirements are supplemented by other Directives for specific waste streams. The UK Government transposed the Waste Framework Directive into UK law through the Waste Regulations 2011, which came into force on 1st October 2012. The regulations stated that as from 1st January 2015, Waste Collection Authorities (WCAs) must collect waste paper, metal, plastic and glass separately. It also imposes a duty on WCAs, from that date, when making arrangements for the collection of such waste, to ensure that those arrangements are by way of separate collection. Originally the Regulations (2011) stated that commingled collections of recycling were an acceptable way of meeting that duty. However the Regulations were amended (2012) to remove the statement about commingled collection being acceptable. The amended Regulations state that separate collections of at least paper, metal, plastic and glass are required where they are technically, environmentally and economically practicable (TEEP) and appropriate to meet ‘the necessary quality standards for the relevant recycling sectors’ by January 2015. Therefore if a WCA does not collect dry recycling separately, it must apply the necessity and TEEP tests to determine if this is needed in their circumstances. These duties apply to waste classified as waste from households and waste that is classified as commercial or industrial waste that is collected by the WCA. 2.1 Waste Regulations Route Map In April 2014, the Waste Regulations Route Map was launched in order to help guide WCAs. It was developed by a working group comprising WRAP, LWARB and the Waste Network Chairs (e.g. LARAC, LGA) assisted by environmental consultancy Eunomia. In the absence of any case law and formal government guidance, the Route Map forms the basis for tackling the recent legislative changes, by offering guidance on assessments in the form of step by step guide, with ‘tests’ to determine the likelihood of meeting the regulation requirements. The Route Map has been used to help Chorley Council in meeting the Waste Regulations.

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From the Waste Regulations Route Map published by WRAP, April 2014 3. What Waste is Collected and How Chorley Council is a member of the Lancashire Waste Partnership which was formed in 1997 to address the emerging waste management agenda in relation to the implementation of the then draft Landfill Directive. It was appreciated by all authorities that as a two tier local authority area there were major benefits to be gained from working together to address this issue.

The first step forward in this process was the development of a Joint Municipal Waste Management Strategy for Lancashire. Lancashire County Council (LCC) reporting through the Lancashire Waste Partnership led the development of this policy document. The final document was approved and adopted by all 15 Partners in April 2001.

In developing the strategy, the LWP carried out a lot of research including waste composition analyses and two extensive public consultation exercises which used leaflet drops, newspaper adverts, press releases, public forums, a Citizens’ Jury and an internet website to ask the people of Lancashire for their views on how we should deal with our waste. Extensive sampling and research was carried out in 1999 and 2000 to establish the composition of Lancashire’s waste. This directed what types of material we should target for recycling. This consultation shaped the way in which Lancashire WCAs were asked to collect their waste in order to meet the targets of the strategy as well as providing the material needed for waste treatment and disposal via a network of facilities funded via a Private Finance Initiative (PFI) contract.

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A ten-year Cost Sharing Agreement (CSA) was developed as a binding contract between LCC and its WCAs and was prescriptive as to types of recycling to be collected. Chorley Council entered into this agreement in 2004. The dry recycling that we can collect under the CSA is as follows: card, ferrous and non-ferrous metals, glass, paper, plastics and textiles. Originally the CSA included a financial incentive to source separate dry recycling, with co-mingled recycling incurring a gate fee charge of approximately £10 per tonne. LCC decided to waive this charge so that WCAs could deliver co-mingled recycling to the facilities without penalty. The CSA allows ferrous and non-ferrous metals, glass and plastic together only. In 2007, Chorley Council carried out a consultation exercise with residents on the current recycling collection system, which used a variety of boxes and bags for residents to present their recycling for collection. Residents were asked for their views on the use of a 240l blue bin for co-mingled plastic bottles, cans and glass with a 40l pod for paper sitting in the top of the bin. The vast majority of residents thought the proposed blue bin and pod were an improvement as it provided additional capacity.

Procurement for the new waste and recycling collection contract included provision of the containers described above and the new contract with Veolia Environmental Services plc started in April 2009. The comingled collection system for glass, cans and plastic bottles in blue wheeled bins whilst the collection of paper remained a separate stream in a 40l pod that sits inside the blue bin and card collected separately in a 55l green box was rolled out across the Borough in spring 2009. The CSA was amended and extended for a further 5 years in 2012, although this related to financial matters and the type of material to be collected as the dry recycling fraction was unchanged. 3.1 Evidence of Waste Collected In 2013/14, Chorley Council collected the following types of waste: Table 1: Types of waste collected

Materials Kerbside collections Bring sites Trade waste collections

Residual waste 240l or 140l green wheeled bins or black sacks, once a fortnight by Refuse Collection Vehicles (RCVs) collected by Veolia.

Not applicable All trade waste collections are provided through a direct arrangement between the business and contractor

Co-mingled glass bottles/ jars, cans & plastic bottles

240l or 140l blue wheeled bins once a fortnight by split bodied RCVs collected by Veolia.

660 or 1100l 4 wheeled containers for mixed plastic bottles, glass and cans. A small number of glass only recycling bells are still in use.

All trade waste collections are provided through a direct arrangement between the business and contractor

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Materials Kerbside collections Bring sites Trade waste collections

Card 55l green box (no lid), collected once per fortnight by garden waste split bodied vehicles by Veolia.

1100l bins, variable emptying by RCVs .


Paper 40l black pod which sits inside the blue wheeled bin, collected once per fortnight by Veolia using co-mingled dry recycling split bodied vehicles.

1100l bins, variable emptying by RCVs


Textiles Red sacks, once per fortnight by same vehicle as paper/ card. Sacks are separated at the depot

Cohens, Oxfam and Salvation Army banks

Not applicable

Garden & food waste

240l brown wheeled bins, once per fortnight by Veolia using RCVs

Not applicable Not applicable

WEEE Collected by Recycling Lives on behalf of Veolia on request by customers.

5 recycling banks on main bring sites

Not applicable

Bulky items (non WEEE) e.g. furniture

Collected by Veolia following request from resident


Clinical waste Collected by Veolia, district nurse to supply yellow bags or sharps containers collected once per week.


Street cleansing waste

Collected by street cleansing vehicles (small sweepers and hand sweepers) as well as litterbin and dog bin emptying done by caged tippers.

Some litter bins on bring sites serviced by hand sweepers and caged tippers.

Not applicable

Fly tipped waste Collected by caged vehicles by either Neighbourhood Officers or Streetscene Team.

Dealt with as per kerbside.

Not applicable

Nearly all collections are on the same day of the week, with recycling and garden waste being collected the same week, and residual waste the following (alternate) week.

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3.2 Tonnages of Waste Collected in 2013/14

Table 2: Kerbside Collections

Material Tonnage

Paper 2256.34

Card 1353.50 *

Co-mingled glass/cans/plastic 5949.08 *

Food & Garden waste 10116.76

Fridges/freezers 0

White goods 132.65

Mattresses 0

Textiles 0

Bulky waste reused 0

Trade paper/card 0

Trade commingled glass/cans/plastic

0

*These include tonnages for the recycling bring sites as these are collected by the same vehicle that services households. Table 3: Bring Sites

Material Tonnage

Paper 242.10

Glass (glass only bells) 239.67

Tetra Pak 2.81

Textiles & shoes 29.21

Books 11.87

Table 4: Residual Waste to Leyland Waste Technology Park for Mechanical and Biological Treatment (MBT)

Material Tonnage

Household collections 20088.34

Street cleansing (part landfilled) 2473.63

Trade waste 0

Bulky waste 88.04

Fly tipped materials (landfilled) 126.62

15 tonnes of clinical waste was collected and delivered to Preston Hospital where it was transferred to another site for incineration.

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3.3 Budget Details The total budget for waste collection and recycling in 2013/14 including staffing costs was £3,409,000. Disposal costs for waste are met by the Lancashire County Council (LCC), the waste disposal authority. The following table gives the headline budget figures to provide the current waste collection service and the income from LCC, for 2013/14. Table 5: Headline budget figures

Item Cost

Contract cost £3,263,840

Internal Staff Costs £117,000

Income from LCC £986,000

3.4 Contract Details The Council entered into ten year waste and recycling collection contract with Veolia Environmental Services plc in April 2009. The current contract includes an option for a two year extension. Either party to the contract can propose a variation to the contract but if it cannot be agreed the variation can be withdrawn or the dispute referred following the procedures detailed in the contract. If the contact is terminated by the Council a Compensation Sum is payable by the Council which is the amount of lost profit, any staff redundancy costs, any outstanding lease liabilities and any loss on assets incurred by Veolia. 3.5 Record of Decisions Taken in Relation to Waste Management

1997 – Chorley Council joined the Lancashire Waste Partnership.

2001 – Chorley Council adopted Lancashire’s Municipal Waste Management Strategy, “A Greener Strategy for a Greener Future 2001 -2020”.

2004 – Chorley signs the 10 year Lancashire Cost Share Agreement with LCC.

2009 – Chorley Council introduces blue bins for co-mingled plastic bottles, cans and glass as part of the new waste contract. Paper, card and textiles remain as a separate collection.

2010 – LCC instructs Chorley Council to begin delivering its waste and recycling into the PFI facility at Farington, LWTP. This triggers the Loss of Income payment from LCC as previously income was retained for the sale of recyclate.

2012 – Chorley Council agrees the extension of the Cost Share Agreement up to the end of March 2018, accepting a reduction in the annual payment made by LCC.

3.6 How Collected Materials are Treated and Recycled

Detailed below are the recycling, reprocessing and treatment arrangements for each material collected along with the annual tonnage for each arrangement for 2013/14.

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Table 6: Arrangements for each collected material

Materials

Arrangements Total tonnage

2013/14 Collected by Terms Delivered to Treatment method

Residual waste Veolia April 2014 to March 2019 with option for a 2 year extension

Leyland Waste Technology Park

MBT at Leyland Waste Technology Park

20088.34

Co-mingled glass bottles/ jars, cans & plastic bottles collected at kerbside and at bring sites

Veolia April 2014 to March 2019 with option for a 2 year extension


MRF at Leyland Waste Technology Park

5949.08

Glass from bring site bells

Glass Recycling UK Ltd on behalf of Veolia

Open ended contract

Glass Recycling UK Ltd, Barnsley

Sorted at Barnsley then sent for remelt.

239.67

Paper collected from kerbside



Bailed at LWTP and transported to Saica Manchester for recycling

2256.34

Paper from recycling bring sites


UPM Shotton, Deeside

Closed loop recycling into newsprint

242.10

Cardboard collected at kerbside and at bring sites

Veolia April 2014 to March2019 with an option for a 2 year extension


Bailed at LWTP and transported to Saica Manchester for recycling

1353.50

Books Oxfam & British Heart Foundation

Ad hoc arrangements

Collected by recycling bank operators

Reused or recycled if in poor condition

11.87

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Materials Arrangements Total Tonnages 2013/14 Collected by Terms Delivered to Treatment

method

Textiles / shoes Veolia subcontract to Cohens for kerbside collections. Variety of bring banks

Ad hoc arrangements

Leyland Waste Technology Park.

Collected by recycling bank operators

Recycled/ reused by Wilcox Ltd

29.21

Co-mingled food and garden waste



Composted at Leyland Waste Technology Park

10116.76

WEEE Veolia subcontract service to Recycling Lives

April 2014 to March 2019 with option for a 2 year extension

Recycling Lives depot, Preston

WEEE items recycled

132.65

Bulky household waste e.g. furniture


Leyland Waste Technology Park and Clayton Hall landfill site

Reused and recycled where possible

88.04

Clinical waste Veolia April 2014 to March 2019 with option for a 2 year extension

Preston hospital

Incinerated without energy recovery

36.85

Street cleansing waste

Chorley Council In-house

No fixed term Bengal St Depot

MBT at LWTP and some landfilled at Clayton Hall landfill site

2473.63

None of the above waste is mixed with any other waste after collection other than the same type of waste from other Local Authorities whose material is processed at LWTP. Co-mingled glass, plastic and metals are delivered to the Materials Recycling Facility (MRF) at LWTP for sorting. Details of the mass balance for the LWTP Materials Recovery Facility for 2013/14 are included in the Appendix. The composition of the collected commingled glass, cans and plastics

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varies each quarter based on an audit carried on input material, but the average for 2013/14 was as follows: Table7: Composition of co-mingled materials

Material Tonnage Percentage %

Glass 4193.4 70.5

Plastic 975.5 16.4

Metal 779.2 13.1

Total 5948.1 100

In 2013/14 Chorley Council provided 5948.1t of household commingled glass, metals and plastics to the MRF at LWTP, of which rejects accounted for 4.5% over the year or 267.7 tonnes. Recycling bins are visually checked by collection crews for gross contamination and left if contaminated. Residents are informed why their bin has not been collected via a leaflet posted through their door by a supervisor from Veolia. Loads are delivered to LWTP and visually inspected by staff when tipped off. If loads are heavily contaminated >5% that are rejected, the Council informed and the material processed through the MBT process. Chorley Council only sends clinical waste for incineration which is not relevant under this TEEP assessment.

Chorley Council is bound by the terms of the Cost Sharing Agreement (CSA) and hence no gate fees are charged directly to the Council. It is required to deliver all household waste collected at the kerbside to LWTP for treatment. There are no constraints on material tonnages under the current cost sharing arrangement with LCC. The only minimum is that the Council have to provide 90% of households with a full three-stream recycling service. LCC are constrained by the build specification of the MRF at LWTP which was designed in the mid-2000s but have a variety of other processers available if required.

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4. Applying the Waste Hierarchy

Local Authorities are required to comply with the waste hierarchy. Departure is allowed when the

measures that would be required would not be “reasonable in the circumstances” or when

departure will “achieve the best overall environmental outcome where this is justified by life cycle

thinking on the overall impacts of the generation and management of the waste.”

The various waste streams collected by Chorley Council were assessed to ensure compliance with

Regulation 12 (Waste Hierarchy).

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Table 8: Compliance with waste hierarchy

Material Current Management Method & Actions Can Material be Moved up the Waste Hierarchy?

Newspapers &

magazines

General waste prevention campaigns. Kerbside collection &

at bring sites. Closed loop recycling.

No

Other recyclable

paper including books

General waste prevention campaigns. Kerbside collection &

at bring sites including book banks. Closed loop recycling.

No

Non-recyclable paper General waste prevention campaigns. Kerbside refuse

collection.

No. Material goes through the MBT process at LWTP and is

processed into Organic Growth Medium.

Liquid cartons e.g.

Tetra Pak

General waste prevention campaigns. Five recycling banks

across the Borough Kerbside refuse collection

Liquid cartons collected through bring sites are recycled with the

fibre element being closed loop recycle and the plastic and metal

element open loop recycled.

The MRF cannot sort this material currently. Material goes

through the MBT process at LWTP and is processed into Organic

Growth Medium.

Cardboard packaging General waste prevention campaigns. Kerbside collection & at

bring sites.

No

Plastic bottles General waste prevention campaigns. Kerbside collection & at

bring sites.

No

Plastic packaging and

film e.g. yoghurt pots,

trays

General waste prevention campaigns. Kerbside refuse

collection.

Possible but LWTP cannot currently process this material and

there are limited end markets in the UK. Material goes through

the MBT process at LWTP and is processed into Organic Growth

Medium.

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Material Current Management Method & Actions Can Material be Moved up the Waste Hierarchy?

Ferrous cans General waste prevention campaigns. Kerbside collection &

bring sites.

No

Non-ferrous cans General waste prevention campaigns. Kerbside collection &

bring sites. Closed loop recycling.

No

Other metal General waste prevention campaign. Material pulled out at

LWTP where possible and recycled.

No

Glass bottles & jars General waste prevention campaigns. Kerbside collection &

bring sites. Open and closed loop recycling.

No

Other glass General waste prevention campaigns. Other glass not

collected at the kerbside or at bring sites.

Yes but the measures required would not be reasonable.

Textiles Encourage reuse through donation to charity shops. Limited

kerbside collections provided and textile banks at bring sites.

No

Shoes Encourage reuse through donation to charity shops. Shoe

banks at bring sites.

No

Garden waste Subsidised home compost bins promoted. Kerbside collection

provided. Close loop recycled into PAS100 compost.

No

Food waste Love food, hate waste message promoted. Subsidised home

compost bins promoted. Kerbside collection provided for

those properties that have a garden waste bin. Close loop

recycled into PAS100 compost.

No

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Material Current Management Method & Actions Can Material be moved up the Waste Hierarchy?

WEEE Kerbside collection and bring sites. Yes but the measures required would be unreasonable.

Bulky household

waste e.g. furniture

Encourage reuse by directing to charity shops. Material not

suitable for reuse delivered to LWTP.

Yes but the measures required would be unreasonable. Recycling

of furniture has been financially viable

Clinical waste Clinical waste collections requested by medical practitioner to

minimise amount of collections.

No

Street cleansing waste Waste delivered direct to LWTP goes through MBT process.

Street sweepings landfilled at Clayton Hall.

No. Some recovery of material through MBT process, output

Organic Growth Medium.

Fly tipped waste Landfilled at Clayton Hall or if hazardous material goes for

appropriate treatment.

Yes but the measure required would be unreasonable.

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5. Is Separate Collection of the Four Materials Required?

Chorley Council has collected glass, metal, paper and plastic for recycling from the kerbside since 2005. Paper is interpreted by the Regulations as including cardboard, and paper and card are collected separately from the other materials. The default under the Regulations is for plastics, metals, glass and paper to be collected separately. Each material will be assessed in turn to see if the current collection method meets the necessity and practicability tests as detailed in WRAP’s Route Map, April 2014. 5.1 How Does Chorley Compare? The yield for dry recyclate per household per year is provided by WRAP’s Performance Benchmarking Portal, the latest data is for 2012/13. The following table compares our performance in 2012/13 against the four authorities that are most similar to Chorley based on key population characteristics. Performance is good compared to these authorities. Table 9: WRAP benchmarking tool 2012/13 data

Paper kg/hhd/yr

Card kg/hhd/yr

Total Paper & Card

kg/hhd/yr

Metal (cans)

kg/hhd/yr

Glass kg/hhd/yr

Plastic Bottles

kg/hhd/yr

Chorley BC 53.2 30.6 83.8 18.1 82.9 19.3

Warrington BC 75.9 28.1 104.0 9.2 47.8 12.5

South Ribble BC 59.6 28.0 87.6 18.3 83.5 19.4

Cheshire West & Chester

56.7 29.3 86.0 11.6 69.8 16.3

North Warwickshire BC

43.1 20.5 63.6 9.6 30.5 10.1

5.2 Necessity Test for Paper Paper and card is currently collected separately from other materials. Chorley Council provides a 55l box for cardboard and a 40l pod that sits in a wheeled bin for paper. These materials are collected separately at the kerbside but are combined at the delivery point, Leyland Waste Technology Park (LWTP). 3,629 tonnes were collected from the kerbside in 2013/14. Chorley Council also provide approximately 15 recycling bring sites at various locations across the Borough where paper and cardboard can be brought for recycling. 242 tonnes were collected from recycling bring sites in 2013/14. This material is collected by Veolia and stored at their depot. It is then transported to UPM Shotton, Deeside for closed loop recycling into newsprint. The paper and card collected at the kerbside is a high quality material. The contamination rate for paper is 4.62% based on audits undertaken on material delivered to Leyland Waste Technology Park. The material is baled at LWTP and then taken to Saica, a paper merchant in Manchester. Saica specifies the quality of the material they will accept for reprocessing. Loads are rejected if they contain more than 2% unacceptable papers and materials or more than 5% non paper components. The material is reprocessed and turned into high quality card and paper products. No loads have been rejected by them. This is an example of closed loop recycling.

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A separate collection of paper is required to ensure the waste undergoes recovery operations. The tonnages of paper recovered have dropped over the years but this is in line with national trends. The amount of contaminated paper and card in the residual waste stream is 2.3% (schedule 26 contract waste audit, Farington Facility 2012/13) so capture rates are good. A separate collection of paper is required and provided by all the waste collection authorities across Lancashire. Any proposed change to the collection methodology will be reviewed to ensure it is still complaint with relevant legislation. 5.3 Necessity Test for Metals Metal is currently collected comingled with glass and plastic bottles. Chorley Council provides a 240l wheeled bin to collect this material. 780 tonnes are estimated to be collected from the kerbside in 2013/14. Chorley Council also provide approximately 15 recycling bring sites at various locations across the Borough where cans and tins are co-mingled with plastic bottles for recycling. This material is collected with the household co-mingled recycling stream so it is not possible to provide a separate tonnage figure. The co-mingled material is delivered to LWTP. The co-mingled contamination rate is 12% based on audits undertaken on material delivered to Leyland Waste Technology Park. The co-mingled stream is separated at the materials Recovery facility (MRF) at LWTP. Metals are separated into two streams; ferrous and non-ferrous. The ratio is approximately 6:1. They are separated at LWTP using magnets and eddy currents into their respective fractions. The metal collected and separated into the two fractions is a high quality material. The material is baled at LWTP and then sent to two reprocessers, Recycling Lives at Preston and EMR in Manchester. Both reprocessers specify the quality of the material they will accept for reprocessing. The material is reprocessed and turned into high quality end products. The ferrous metal is fragmented for use in steel production and non ferrous reused to make cans. No loads have been rejected by them. This is an example of closed loop recycling. Based on the evidence available it is not necessary for metal to be collected separately as the separation process at LWTP produces a high quality end product that can be used for closed loop recycling. 5.4 Necessity Test for Plastics Plastic is currently collected comingled with glass and metal. Only HDPE & PET type plastics are specified for collection, these are usually plastic bottles. Chorley Council provides a 240l wheeled bin to collect this material. The contamination rate is 12% based on audits undertaken on material delivered to Leyland Waste Technology Park. 975.5 tonnes are estimated to be collected from the kerbside in 2013/14. The co-mingled material is delivered to LWTP. Co-mingled plastic bottles, glass and cans are collected at the 15 recycling bring sites located across the Borough. This material is collected with the household co-mingled recycling stream so it is not possible to provide a separate tonnage figure.

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The co-mingled stream is separated at the Materials Recovery Facility (MRF) at LWTP. Plastics are separated into three streams;

HPDE, these are then divide into clear and coloured plastics

PET, these are then divide into clear and coloured plastics

Mixed plastics

Plastics are collected co-mingled with glass and metals at the kerbside from households. The co-mingled stream is visually checked for contamination when it is tipped off at LWTP and it then moves by conveyor belt to the hand sort area. Here any hazardous or non recyclable elements are removed. The plastic bottles go through a perforator after being separated from the metal and glass fractions so they can be flattened and pierced to reduce volume. An optical sorter sorts the plastic into the five streams detailed above. The plastics collected and separated into the five fractions is a high quality material. The material is baled at LWTP and then sent to a number of reprocessers, the two main reprocessers used by GRL are Hanbury and Virador. The plastic is flaked and pelletized and sold on to be turned into non-food packaging and drainage products. Both reprocessers specify the quality of the material they will accept for reprocessing. The material is reprocessed and turned into high quality end products. In 2013/14 three loads of HPDE coloured plastic was rejected by a reprocceser due to metal contamination. The 38.5 tonnes rejected represents less than 0.1% of the total MRF inputs for 2013/14. Based on the evidence available it is not necessary for plastic to be collected separately as the separation process at LWTP produces a high quality end product that can be used for closed loop recycling. 5.5 Necessity Test for Glass Glass is currently collected through kerbside household collections co-mingled with plastic bottles and metal. Chorley Council provides a 240l wheeled bin to collect this material. 4193.4 tonnes are estimated to be collected from the kerbside in 2013/14. The co-mingled material is delivered to LWTP. Glass is also collected at the 15 recycling bring sites cross the Borough. The 239.67 tonnes of glass collected from the colour separated glass bells goes to Glass Recycling UK at Barnsley where it is processed and then sent for remelt i.e. closed loop recycling. The separate collection banks for glass are being phased out and glass can now be co-mingled with plastic bottles and cans in the same way it is collected from households. Glass can be broken as soon as it is dropped in the bin, emptied and compacted in the waste collection vehicle, emptied on to the waste transfer station floor and then emptied on to the floor at LWTP. The co-mingled stream is separated at the Materials Recovery facility (MRF) at LWTP. Glass is broken using a bottle breaker as part of separation process, and then separated into size fractions through screening.

<25mm cullet

>25mm cullet

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The proportion of cullet <25mm is 71% and >25mm 29%. LWTP are currently trialling cullet <8mm being send to glass merchants for remelt. The glass cullet is a high quality product and 54% of it is used for remelt by Recresco. This is an example of closed loop recycling. 46% of the cullet is used for road aggregate and which could be considered as a lower quality recycling product. A separate collection for glass would be likely to lead to an increase in quality as the proportion of cullet > 25mm size is likely to increase so this would meet the necessity test. 5.6 Conclusion Table 10: Closed Loop Assessment

Materials Second stage Re-processor

Open (%) Closed (%) Separate Collection Will

Increase Quality or Quantity

Paper/card Saica Manchester & UPM Shotton, Deeside

0 100 Unlikely therefore compliant

Metal EMR & Recycling Lives Ltd

7 93 Unlikely therefore complaint

Plastics Viridor & Hanbury 6 94 Unlikely therefore compliant

Glass Recressco 46 54 Increase in quality likely

Since over 90% of paper, plastic bottles and metals are closed loop recycled and higher yields are unlikely to be achieved by separate collection Chorley Council is likely to fail the Necessity Test for separate collection of these materials. Therefore a Practicability Test is not required. In contrast the recovery of glass may be “improved” if a separate collection increased the amount of available for closed loop recycling. Therefore the collection of glass must be subjected to the Technical, Environmental and Economically Practicable (TEEP) test to see if it is practicable to collect it separately.

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6. The TEEP Test for Kerbside Glass Collection There are a number of options for how glass could be collected separately in Chorley.

Option 1 Comingled system (as current) plastic bottles, metal and glass co-mingled in a 240l

wheeled bin.

Option 2 Kerbside sort where all material collected in one vehicle but glass is manually

sorted by the collection crew to be kept separate from comingled plastic bottles and metal.

Option 3 Separate vehicle pass with residents asked to separate glass.

Option 4 Split bodied vehicle where residents present separate glass and co-mingled plastic

bottles and metals for collection.

Option 2 is more likely to improve recovery and increase the tonnage of glass available for closed loop recycling. Therefore this option is looked at in detail when comparing against our existing collection method. 6.1 Technical Appraisal It would be technically feasible to put in place a separate glass collection but there would be siginificant issues that would need to be addressed. These include;

Replacement of the existing vehicle fleet

Health and safety issues for operatives sorting waste on the highway

Purchase and rollout of new containers for glass

Increased footprint required for storing containers at properties and presenting them at

kerbside for collection

Additional storage space would be required at LWTP for glass.

Data from WasteData Flow for Districts Councils who use a kerbside sort system indicates a lower yield of glass compared to District Councils who use a co-mingled system. It is estimated there would be a 30% reduction on the glass tonnages collected at kerbside if kerbside sort was introduced. This is because residents find it easier to use a 240l bin for comingling their recycling and this provides sufficient capacity to store recycling until the next collection. 6.2 Environmental Appraisal The environmental impact of the collection systems have been modelled using carbon dioxide as the main indicator. The climate change benefits are calculated as carbon dioxide equivalent tonnages avoided.

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Table 11: Assessment of reprocessing emissions

Commingled Kerbside Sort

T CO2 avoided per t recycled

Quantity(t) T CO2 equivalent avoided

Quantity (t) T CO2 equivalent avoided

Glass open loop -0.0211 1928.96 -40.70 293.54 -6.19

Glass closed loop -0.168 2264.44 -380.43 2641.84 -443.83

Total 4193.40 -421.13 2935.38 -450.02

Assumptions Figures for tonnes of carbon dioxide avoided per tonne of glass recycled are from the WRAP 2011 report on Kerbside Collections Options for Wales. The figure for open loop recycling of glass is from RMC aggregates and the figure for closed loop recycling is the British Glass Carbon factor. 2,935.38t of glass collected via a kerbside sort collection with 90% going to closed loop recycling. The co-mingling system would result in 421t of carbon dioxide being avoided compared to 450t for the kerbside sort system, a difference of 29t a year. Transport Emissions The transport emissions have been modelled for a separate collection of glass using stillage vehicles. Data on fuel usage has been provided by Veolia. Co-mingled collections use 82,666 litres of fuel per year. Data from WRAP (2011) shows that kerbside sort takes approximately 30 seconds more per household compared to ten seconds for a bin lift. Rounds would therefore take three times longer compared to existing co-mingled. Additional vehicles would be required to account for this. The capacity (volume) of stillage vehicles determines the amount of material they can collect before tipping off. On average our current twin pack RCVs for dry recycling collect 5.65 tonnes of material. The volume of the plastic and cans stream will determine the frequency of tipping at FWTP. They currently tip off on average 1.5 times per round and it is estimated they would need to tip off at least 4 times per round. Table 12: Assessment of transport emissions

Mileage Fuel (litres) CO2 Equivalent (tonnages)

Current Comingled 58,810 82,666 269.49

Total 269.40

Kerbside Sort 58,810 82,666 269.49

Additional journeys to FWTP

75,900 106,688 347.80

Total 617.30

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Assumptions The average round trip to LWTP is 15 miles. 253 working days per year, assume 8 stillage vehicles in use on any day making 2.5 additional journeys to LWTP. Assume 1.41litres of fuel used per mile for both stillage and existing twin pack RCVs. Data on mileage and fuel consumption provided by Veolia using current commingled recycling vehicles. Diesel emissions kg carbon dioxide per litre 3.26kg/litre (WRAP, 2011) Sorting Emissions If glass was collected separately it would no longer need to be processed through the MRF at FWTP. It would be delivered to a transfer station which would significantly reduce the carbon dioxide emissions. Table 13: Assessment of sorting emissions

Glass collected (tonnes)

Facility Electricity Use (kwh)

CO2

Equivalent (tonnes)

Facility Diesel (litres)

CO2 tonnes Total CO2

tonnes

Comingled 4193.4 146,769.0 86.57 8,386.8 27.18 113.75

Kerbside Sort

2935.4 11,741.6 6.93 2,935.4 9.51 16.44

Assumptions MRF uses 35Kwh electricity per tonne (WRAP, 2011) MRF uses 2 litres per tonne (WRAP, 2011) Transfer station uses 4Kwh electricity per tonne (WRAP, 2011) Transfer station uses 1 litre diesel per tonne (WRAP, 2011) General diesel emission factor kg CO2 per kWh used is 0.58982 General diesel emission factor kg CO2 per litre used is 3.2413 Environmental Conclusion Table14: Emissions assessment

Comingled (t CO2

equivalent) Kerbside Sort (t CO2

equivalent) Impact of changing

collection (t CO2

equivalent)

Reprocessing -421.13 -450.02 -28.90

Transport 269.49 617.30 347.80

Sorting 113.75 16.44 -97.31

221.60

The use of a kerbside sort would reduce the climate change impact during reprocessing and sorting but increase it during transport. The increase in the number of vehicles required to carry out kerbside sort collections outweighs the reduction in carbon dioxide emissions from more closed loop reprocessing and that sorting through a MRF would no longer be required.

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6.3 Economic The Council is currently in year six of a ten year collection contract with Veolia Environmental Services plc with an option to extend for another two years which would take the contract to March 2021. The contract was let on the basis of a co-mingled kerbside collection with only paper and card being required to be collected separately. Although during the procurement process the LWTP was not operational the design was known, what materials it could accept and in what configuration was provided by Lancashire County Council, the waste disposal authority. The collection of waste and recycling across Chorley is therefore based on this information and expected to remain for the contract duration. The LWTP was part of 25 year PFI project between LCC and Global Renewables Lancashire Ltd. The PFI contract was terminated in July 2014 and LCC are now owners of the PFI facilities across Lancashire. In the short term it unlikely there will be any changes in how they are willing to accept waste for reprocessing at their facilities. There is scope in the existing waste collection contract to change how we collect materials and in what configuration but any increase in the number of vehicles required or changes to where material would be delivered will all result in increased contract costs. The table below outlines some of the likely costs that would be incurred by the Council if it switched to a kerbside collection of glass using stillage vehicles during the lifetime of the existing contract. Table 15: Costs resulting from changing to a kerbside sort collection for glass

Category Operational Costs Capital Costs Assumptions

Lease or purchase of 10 stillage vehicles with compaction for plastics to collect dry recyclate stream. 8 in operation at any one time with 2 spare vehicles

£850,000 one off Currently 5 dry recycling vehicles. Loading of stillage vehicles takes longer and capacity is lower. Assume stillage vehicle costs £85k each.

Return of existing 5 split bodied recycling vehicles which are on 7 year lease

£250,000 one off Lease costs of £25k per vehicle per year. Each vehicle has a further 2 years until the lease finishes.

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Category Operational Costs Capital Costs Assumptions

Additional crew of driver plus 3 loaders per vehicle.

£300k per annum Currently driver plus 2 but additional loader needed per vehicle to achieve productivity. Assume average salary inc. on costs £20k.

Annual running costs per stillage vehicle including maintenance and fuel

£125k per annum £25k per annum, costs for existing dry recycling vehicles deducted.

Increase size of depot

£50k per annum Additional space required to store vehicles.

Provide each household with a 55l box for glass

£250k one off cost

£4.90 per unit including delivery and a sum for communications

One Off Costs £1.35m

Total Annual Costs

£475,000

If the Council were to move towards a source separated kerbside collection for glass the additional costs for the first year would be in the region of £1.8m with ongoing costs of £475k for future years. These figures do not include interest charges for financing capital costs or inflation increases. In conclusion it is not economically practicable to introduce a kerbside sort. 7. Overall Conclusion Regulation 12 requires local authorities to meet the waste hierarchy for all wastes it is responsible for. This assessment concludes that this regulation has been met. Regulation 13 states “that from 1st January 2015 all Waste Collection Authorities will be required to

collect paper, metals, plastics and glass (the materials) separately, where doing so is;

Necessary to ensure that waste undergoes recovery operation in accordance with Articles 4

and 13 of the Waste Framework Directive and facilitate or improve recovery; and

Technically, environmentally and economically practicable.”

The introduction of a kerbside sorting system for these materials has been subjected to these tests

with the following conclusions;

The collection system operated by Chorley Council ensures a high yield of material is

collected through kerbside collections.

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Paper and card are kept separate from other materials so the quality of the material is good

and it goes for closed loop recycling. Therefore the current collection method is permitted

under these Regulations.

Plastics and metals can be easily separated at Leyland Waste Technology Park (LWTP) to

achieve a good quality material that meets closed loop reprocessers’ specifications.

Therefore the current collection method is permitted under these Regulations.

The separate collection of glass via kerbside sort is unlikely to facility recovery but it would

improve the amount of glass that could be closed loop recycled. The TEEP test shows it is

technically practicable to introduce a kerbside sort system. However it is not

environmentally practicable as it would increase carbon dioxide emissions by 221 tonnes per

year. It is also not economically practicable as there would be a one off cost of £1.35m and

annual costs of £435,000.

Separate collection of glass at the kerbside is not environmentally or economically practicable. Therefore the current kerbside collection method is permitted under these Regulations. 8. Sign Off and Review An Executive member Decision report will be drafted recommending the Council’s compliance with these Regulations is noted and approval of the assessment. The Executive member Decision report is expected to be approved in January 2015. This assessment will be reviewed in the event of key triggers including;

Waste collection contract procurement

Substantial variations to existing waste collection contracts

Significant changes to the MRF at Leyland Waste Technology Park

New data becomes available which is likely to affect the overall conclusion of this

assessment.

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9. Appendix – Supporting Data Figure 1 Mass Balance for 2013/14 for the MRF facility at LWTP. Tonnages shown are for all Lancashire Authorities whose recycling in processed there.

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Figure 2 Inputs and Outputs for the MRF facility at LWTP 2013/14. Tonnages shown are for all Lancashire Authorities whose recycling is processed there.

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Figure 3 The MRF process at LWTP

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