DEFRA THE ENVIRONMENTAL IMPACTS OF THE ACTIVITY OF ...sciencesearch.defra.gov.uk/Document.aspx?Document=... · Table 5.4 Waste spread to land under Paragraph 7 by LoW chapter 54 Table

DEFRA

THE ENVIRONMENTAL IMPACTS OF THE ACTIVITY OF SPREADING WASTE TO LAND

WRc Ref: UC7899.02

SEPTEMBER 2009

ON THE ENVIRONMENTAL IMPACTS OF THE ACTIVITY OF SPREADING WASTE TO LAND

Report No.: UC7899.02

Date: September 2009

Authors: James Peacock; Jane Turrell

Data Collection Team: James Peacock; Victoria Colden; Frank Moy; Holly Smith; Line Pionel; James Williams; Paul Sweenie; Louise Roberts; Jennifer Horn; Craig Gordon

Contract Manager: James Peacock

Contract No.: 15070-0

Any enquiries relating to this report should be referred to the authors at the following address:

WRc Swindon, Frankland Road, Blagrove, Swindon, Wiltshire, SN5 8YF. Telephone: + 44 (0) 1793 865000 Fax: + 44 (0) 1793 865001 Website: www.wrcplc.co.uk

The contents of this document are subject to copyright and all rights are reserved. No part of this document may be reproduced, stored in a retrieval system or transmitted, in any form or by any means electronic, mechanical, photocopying, recording or otherwise, without the prior written consent of the copyright owner.

This document has been produced by WRc plc.

CONTENTS

SUMMARY 1

1. INTRODUCTION 3

2. CURRENT SYSTEM 5

2.1 Regulatory Framework 5 2.2 Regulator organisation 9 2.3 Requirements for application 12

3. DATA COLLATION 15

3.1 Sources of information 15 3.2 The Agricultural Waste Database System 15 3.3 Paragraph 7 exemption notifications 16 3.4 Biobed Material 20

4. RESULTS 21

4.1 Tier 1 Risk Assessment 21 4.2 Tier 1 Risk Assessment – Ranking 22 4.3 Location of sites 35 4.4 Spreading on non-agricultural and agricultural land 37 4.5 Number of Wastes spread on site 38 4.6 Agricultural Benefit vs. Ecological Improvement 39 4.7 Waste currently spread under permit 40 4.8 Waste Spread under modern regulatory position statement 41 4.9 Survey Results 42

5. TIER 2 ASSESSMENT OF WASTE STREAM ARISINGS AND CHARACTERISTICS 51

5.1 Waste Protocols 52 5.2 Discussion on Application Forms 53 5.3 Data Specifics by waste type 56

6. SAFE LOADING LIMITS 121

7. CONCLUSIONS AND RECOMMENDATIONS 139

7.1 General 139 7.2 Follow-up inspections 140 7.3 Pollution Incidents 140 7.4 Recommendations 140

REFERENCES 143

APPENDICES

APPENDIX A DATA GATHERING: EXEMPTION NOTIFICATIONS 145

APPENDIX B DATA GATHERING: CONTACTING OPERATORS AND REGULATORS 163

APPENDIX C METHODOLOGY FOR ASSESSING IMPACTS AND PRIORITISING HIGH RISK WASTES 167

LIST OF TABLES

Table 3.1 Summary of Paragraph 7 notifications for the period 30th April 2007 to 1st May 2008 16

Table 4.1 Tier 1 risk assessment 23

Table 4.2 Suggested LoW codes for wastes consigned as 02 02 99 38

Table 4.3 Wastes used for ecological improvement 39

Table 4.4 Summary of waste applied to land under Environmental Permits 41

Table 4.5 Summary of waste applied to land under Environmental Permits 42

Table 4.6 Exemption Operators 43

Table 4.7 Responses to questionnaires by operators 45

Table 4.8 Responses to questionnaires by Application Assessment Officers 47

Table 4.9 Responses to questionnaires by Environment Officers 49

Table 5.1 Total spread for wastes being considered under the Waste Protocol Project 52

Table 5.2 Suggested LoW codes for wastes consigned as 02 02 99 53

Table 5.3 Codes used in Paragraph 7 notifications for animal blood 54

Table 5.4 Waste spread to land under Paragraph 7 by LoW chapter 54

Table 5.5 Summary of waste analysis for 17 05 06 59






Table 5.11 Characteristics of Abattoir Wash waters 77









Table 5.20 Summary of waste analysis for Mixed sludge 101








Table 6.1 Code of Practice and Legislative Limits for PTEs and Nutrients 121

Table 6.2 Limiting application rates based on average values 122

Table 6.3 Limiting application rates based on 90th Percentile Values 124

Table 6.4 Limiting application rates based on levels for Chromium 128

Table 6.5 Limiting application rates based on average values for Lead 129

Table 6.6 Limiting application rates based on average values for Zinc 130








Table 6.14 Limiting application rates based on average values for flouride 138

LIST OF FIGURES

Figure 2.1 Basis of a LoW code 9

Figure 4.1 Map showing location of registered Paragraph 7 exemptions in England and Wales 35

Figure 4.2 Map showing location of registered Paragraph 7 exemptions in Cornwall and Devon 36

Figure 4.3 Map showing location of registered Paragraph 7 exemptions in North West 37

Figure 5.1 Map showing location of registered Paragraph 7 exemptions for LoW code 17 05 06 58














Figure 5.15 Map showing location of registered Paragraph 7 exemptions for LoW code Mixed sludge 100





Figure 6.1 Histogram showing zinc concentrations (wet weight mg/kg) in LoW code 02 02 04 126

DEFRA

WRc Ref: UC7899.1/15070-0 September 2009

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SUMMARY

I BENEFITS

This work completed for Defra will produce a reliable dataset on waste currently being spread to land under Paragraph 7 exemptions, including information on impact and agricultural benefit. The collated data will allow accurate ranking of waste types in terms of risk of environmental impact.

II OBJECTIVES

To investigate the impact of waste spread for agronomic benefit or ecological improvement on agricultural land for all the wastes listed in column 2 of the table in Paragraph 7 of schedule 3 to the Environmental Permitting (England and Wales) Regulations 2007 and those listed in the Environment Agency‟s modern regulatory position statement on land spreading.

III REASONS

Historically exemptions from environmental permitting (previously waste management licensing) have been used as the main mechanism for regulating land-spreading activities. The Government and the Welsh Assembly Government intend to continue to make

use of exemptions from permitting, and develop a transparent and consistent way of doing so.

This project is part of the current review of the exemption system, the aim of which is to move to a more risk-based and proportionate approach to the regulation of waste recovery and disposal operations, to complement the proposed new environmental permitting and compliance regime. The work was commissioned to determine which activities might best be covered by exemptions and which would be better covered by permits, in order to achieve a more risk based approach to regulating waste spread to land.

IV CONCLUSIONS

Many of the 75 waste types currently spread to land confer real agricultural benefit to land, and constitutes sensible re-use of waste. Variability of reported waste composition between sites was very large. The standard to which exemption notification forms were completed varied considerably.

From the analysis provided by operators, heavy metal concentrations applied to land were within the levels set in the Code of Practice in the vast majority of cases.

Only 1.3% of the exemptions registered in the 12 months evaluated were for ecological improvement, the majority were for agricultural improvement.

Subsequent to the application stage of spreading waste, follow-up inspection frequency is extremely variable across areas (10% - 100%). Due to the fact that there is no requirement for operators to pre-notify the Environment Agency of when the spreading of waste is to take place, follow-up inspections are not always effective.

Spreading of waste to land under Paragraph 7 has resulted in a substantial number of reports of environmental incidents since 2005, the majority of which were odour complaints. A total of

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44 successful prosecutions (including formal cautions) relating to Paragraph 7 exemptions have been taken by the Environment Agency since 2005.

V RECOMMENDATIONS

Following the review of the available data, WRc would make the following recommendations:

Standardisation of notifications (preferably in electronic format), and more rigorous assessment of how the form is completed (e.g. LoW codes and units) should be considered. This will enable clear and unambiguous comparison between waste types. The collecting of notifications of waste spread under the Environment Agency modern regulatory position statement should be centralised nationally and stored electronically, so that it can be interrogated to monitor risk.

A tiered degree of regulation should be introduced to take in to account the variation of risk by waste type, rather than the current single tier approach.

Waste returns should be required of sites to show how much waste has been spread in comparison with how much was originally applied for.

Minimum requirements for agricultural benefit should be set.

The number of wastes spread on a single site should be restricted (currently there is no limit).

Better data is required on the variability of waste streams, with more than one sample per year required for the high risk waste streams, where the operator cannot show that the waste stream is inherently homogenous and consistent.

Up to date data should be required for renewal notifications (we were unable to assess any renewal notifications for this study due to this reason).

Notification to the Environment Agency of when spreading is to be carried out should be required. Follow-up inspections of the exempt sites should be tied in with when the waste is spread.

More detailed information on pollution incidents relating to Paragraph 7 exempt sites should be kept, to allow the incident reporting system to be interrogated more easily.

Details should be kept on agricultural waste spread under the Environmental permitting Regulations (England and Wales) Regulations 2007.

VI RESUMÉ OF CONTENTS

The current system of regulation for waste to land activities is outlined in Section 2. The methods of data collection are briefly outlined in Section 3. Results of the study are then given in Section 4, followed by a waste by waste assessment of high risk wastes in Section 5, and conclusions of the study given in Section 6.

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1. INTRODUCTION

Background

Historically exemptions from environmental permitting (previously waste management licensing) have proven to be a successful mechanism for helping to regulate waste management activities in a proportionate way. The Government and the Welsh Assembly Government intend to continue to make use of exemptions from permitting, and develop a transparent and consistent way of doing so.

This project is part of the current review of the exemption system in England and Wales, the aim of which is to move to a more risk-based and proportionate approach to the regulation of waste recovery and disposal operations, to complement the proposed new environmental permitting and compliance regime. The review is focussed on establishing which activities might be covered by exemptions and which would be better covered by permits. It examines how this boundary could change to reflect the goal of a more risk based approach to exemptions.

The first phase of the review developed the environmental principles and criteria on which future exemptions will be based, the requirements associated with exemptions and the way exemptions will look in the future.

A consultation was held between July and October 2008 on the revised exemptions, in the form of draft regulations and it is intended that the revised exemptions will be implemented in April 2010.

To help inform the review process, Defra commissioned WRc to undertake a short study to establish the environmental impacts of the activity of spreading waste on land, the extent of these activities and any agronomic benefits conferred. The project commenced in July 2008 and was reported in February 2009. This report provides a summary of WRc‟s findings.

Overall Aim

The overall aim of the work undertaken by WRc is to provide Defra with evidence on the extent, benefits and impacts of the activity of spreading waste on land to inform the policy options on the appropriate level of regulation and controls to mitigate environmental risk.

Specific objectives

a) To investigate the impact of waste spread for agronomic benefit or ecological improvement on agricultural land for all the wastes listed in column 2 of the table in Paragraph 7 of schedule 3 to the Environmental Permitting (England and Wales) Regulations 2007 and those listed in the Environment Agency‟s regulatory position statement on landspreading.

b) In particular examining:

waste from the preparation and processing of meat, fish and other foods of animal origin; wastes from processing of fruit, vegetables, cereals, oils, cocoa, coffee (other than coffee grounds) tea, tobacco, conserve production, yeast and yeast extract production, molasses preparation and fermentation;

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wastes from sugar processing, other than soil from cleaning and washing beet;

wastes from the dairy products industry;

wastes from the baking and confectionery industry;

wastes from the production of alcoholic and non-alcoholic beverages;

wastes from pulp, paper and cardboard production and processing;

wastes from the textile industry;

wastes from calcification and hydration of lime;

gypsum from power stations or from the manufacture of cement, lime and plaster;

soil from excavating contaminated sites;

dredging spoil other than that produced from farm ditches or non-controlled waters for habitat creation or maintenance;

compost, liquor and digestate from anaerobic or aerobic treatment of source-segregated biodegradable waste;

biobed material;

any other categories identified during investigation. c) To investigate the extent of the spreading of waste on non-agricultural land in order to

beneficially condition it. To determine what wastes are used in this way and for what purposes and including all the wastes listed in column 2 of the table in Paragraph 7 of schedule 3 to the Environmental Permitting (England and Wales) Regulations 2007 but in particular examining:

plant tissue waste from forestry, aquaculture, horticulture and fishing - waste bark and cork from wood processing; the production of panels and furniture or from pulp, paper and cardboard production and processing;

de-inked paper sludge and de-inked paper pulp from pulp, paper and cardboard production and processing;

sludges from treatment of urban waste water;

sludges from water clarification; sludges from soil remediation.

d) In particular to examine for each of the waste streams:

the nature of the waste;

how uniform or variable the waste stream is;

the cumulative impact of contaminants and therefore safe loading rates;

what nature of the benefit to agriculture and/or ecological improvement each waste stream confers by spreading;

the extent and the impact of the spreading of waste;

to explore any evidence that permitting this activity would reduce its impact on the environment or the local amenity.

To achieve the objectives of the project, WRc used three main sources of information:

Electronic copies of application forms for Paragraph 7 exemptions;

The Environment Agency‟s Pollution Database;

A survey of waste exemption operators; Application Assessment Officers and Environment Officers.

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2. CURRENT SYSTEM

2.1 Regulatory Framework

2.1.1 Introduction

The Environment Protection Act 1990 requires all sites that accepting waste to be either permitted or be exempt from permitting. The Environmental Permitting Regulations define the way sites which accept waste are regulated. In general, if a site accepts waste it must be covered by an Environmental Permit, which gives a list of conditions specific to that site. Such sites must pay an annual fee; must submit annual waste returns; require a person to be present on site with a Certificate of Technical Competence (CoTC) for a specific amount of time and have regular inspections by the Environment Agency. These sites also require planning permission. However, there are a number of exemptions from Environmental Permitting given in Schedule 3 of the Regulations. If the conditions of any of these exemptions are met, there is no need to notify for an environmental permit, and the above requirements do not apply.

The current regulations have been largely unchanged since the Waste Management Licensing Regulations (Amendment) (England and Wales) 2005 came in to force in April that year. The 2005 amendment introduced more stringent requirements of agricultural benefit statements, limited the number of wastes that could be spread under Paragraph 7, and introduced a charge for an exemption for the first time.

Spreading of waste to land is currently regulated under Paragraph 7 of Schedule 3 of the Environmental Permitting Regulations 2007. The Environmental Permitting Regulations replaced the Waste Management Licensing Regulations for spreading of waste to land in April 2008, implementing only minor changes to the previous legislation (such as restricting the number of hectares any Paragraph 7 registration can be applied over).

2.1.2 Waste Framework Directive

Article 24 allows for exemptions from permit requirements where:

“establishments or undertakings for the following operations:

(a) disposal of their own non-hazardous waste at the place of production; or

(b) recovery of waste.”

Article 3.14 of the Waste Framework Directive (2008/…/EC) defines recovery as:

“any operation the principal result of which is waste serving a useful purpose by replacing other

materials which would otherwise have been used to fulfil a particular function, or waste being prepared

to fulfil that function, in the plant or in the wider economy. Annex II sets out a non-exhaustive list of

recovery operations”

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2.1.3 Other relevant legislation

Sludge (Use in Agriculture) Regulations 1989

The use of sewage sludge (biosolids) is controlled by the Sludge (Use in Agriculture) Regulations 1989 (Sludge Regulation) (derived from Directive 86/278/EEC on landspreading of sewage sludge), and therefore not included in the list of wastes spread under Paragraph 7 exemptions (NB spreading of sewage sludge on non-agricultural land is covered by Schedule 3 Paragraph 6 exemptions. Sludge is defined by the regulations as:

„residual sludge from sewage plants treating domestic or urban waste waters and from other sewage plants treating waste waters of a composition similar to domestic and urban waste waters‟

The Sludge Regulations do however have relevance for wastes spread under Paragraph 7; levels set in the regulations for heavy metals are used to assess Paragraph 7 exemption notifications. The basic requirements for Paragraph 7 notifications are very similar to the requirements of the Sludge Regulations.

The Sludge Regulations set various requirements. Which include:

minimum sampling and testing frequency of every 6 months;

set basic requirements for record keeping;

requires the farmer to work in sewage sludge into soil soon after spreading.

Animal By-products Regulations 2005

The Animal By-products Regulations divide all animal derived materials in to the following three categories:

Category 1: Very high risk (e.g. suspected BSE carcases)

Category 2: High risk (condemned meat; blood and gut contents)

Category 3: Low risk (Catering waste from households, restaurants, Former food, Much slaughter house waste e.g. waste blood & feathers)

Category 1 wastes cannot be spread on land under any circumstances.

Category 2 material may be spread to non-pasture land following processing to the method 1 standard set out in Annex V of Regulation (EC) 1774/2002. Optionally, this processing may be followed by composting or biogas treatment in a suitably approved plant prior to spreading. Certain category 2 materials (manure, digestive tract content, milk and colostrum) may be applied direct to land without treatment. They may only be applied to non-pasture land, except for manure1.

1 (i) blood can only be applied to land if it has been treated in accordance with 1774/2002 (i.e. in an approved

rendering composting or biogas plant) and is spread to non-pasture land

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Category 3 wastes material may be spread to non-pasture land following treatment in a suitably approved processing, composting or biogas plant.

The proposed update to these regulations is currently out to consultation2.

Nitrate Pollution Prevention Regulations 2008

The above regulations came in to force on 1st January 2009 and updated the implementation of The Nitrates Directive (91/676/EEC). Over 60% of nitrate in waters in England and Wales comes from agricultural sources. At high levels nitrates can be toxic to aquatic species, and can also cause algal blooms and eutrophication. Control of nitrate in surface waters is also important to protect the quality of drinking water.

Following the implementation of these regulations Nitrate Vulnerable Zones currently cover almost 70% of England and Wales (although only 3% of Wales is designated as nitrate vulnerable zones). In these zones restrictions are placed on farmers on the use of nitrogen fertilisers, such as when fertilisers can be spread and quantities.

As many wastes spread under Paragraph 7 exemptions contain high levels of nitrogen, limits imposed by The Nitrate Pollution Prevention Regulations 2008 are often the limiting factor in terms of loading rates when applying the waste to land. A limit of 250 kg/ha of nitrogen for grassland is set in the regulations.

Nitrogen and other major nutrient requirements of crops are taken from Defra‟s Fertiliser Handbook3. This handbook also provides nutrient content of a wide range of organic manures, but there is no information on industrial wastes, such as those spread under Paragraph 7 exemptions. The Fertiliser Handbook is due to be updated in January 2009. The update is understood to contain nutrient content of the major industrial wastes, but was not available at the time of this report.4

Agricultural Waste Regulations 2005 (superseded by the Environmental Permitting Regulations 2007)

When the regulations came in to force in May 2006, the Waste Management (England & Wales) Regulations 2006 made many agricultural wastes controlled (i.e. regulated under standard controls) wastes for the first time. This had the effect that farmers had to notify for exemptions for the first time.

(ii) manure, digestive tract content separated from the digestive tract, milk and colostrums can be applied to land provided no restrictions relating to animal health have been imposed in relation to those ABPs e.g. FMD controls

(iii) Digestive tract content may be applied to non-pasture land; and

(vi) The land application of untreated feathers is not an approved disposal route and mixing feathers with poultry litter for disposal to land is also prohibited

2 http://www.defra.gov.uk/corporate/consult/animalbyproducts/index.htm

3 Fertiliser Recommendations for Agricultural and Horticultural Crops (RB209), Defra 2000 http://www.defra.gov.uk/FARM/environment/land-manage/nutrient/fert/rb209/

4 Review of Defra‟s „Fertiliser Recommendations (RB209)‟ publication, 2006, ADAS

http://www.defra.gov.uk/farm/environment/land-manage/nutrient/pdf/RB209revFinalRepF.pdf

http://www.defra.gov.uk/FARM/environment/land-manage/nutrient/fert/rb209/

http://www.defra.gov.uk/farm/environment/land-manage/nutrient/pdf/RB209revFinalRepF.pdf

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To ease the regulatory burden on farmers, a simplified system of registering exemptions was introduced. For Paragraph 7 exemptions, this meant operators did not have to provide data or notifications as with standard Paragraph 7s, they are only required to fill in a „tick box‟ application that did not require any details on composition of the waste. This type of Paragraph 7 exemption can only be used for the following wastes from agriculture:

Soil

Compost

Plant tissue

Dredgings

This type of exemption under the Agricultural Waste Regulations must be renewed every year, as with standard Paragraph 7 notifications. A key constraint of this type of Paragraph 7 exemption is a restriction of 50 tonnes per hectare per year maximum, and a maximum of 50 hectares per application, a capacity for spreading of 2500 tonnes per site (compared to 250 tonnes on standard Paragraph 7 application or 5000 t/ha for dredging spoil).

In the period April 2007 – April 2008 (the period for which Paragraph 7 notifications were assessed in this study), 13 363 notifications were received by the Environment Agency via the simplified form. A further 1410 exemptions were registered through Defra‟s Whole Farm Approach (WFA) website5. Exemptions registered under the WFA do not have to be renewed.

The utilisation of exemptions after registration is unknown, and many exemptions may be registered „just in case‟. It is possible that many farmers register a Paragraph 7 application for the spreading of manure, which will be produced at most farms housing livestock. A recent European Court of Justice ruling6 found that livestock manure was not a waste, and would therefore not require an exemption in order to be spread to land, so these exemptions are registered in error.

European Waste Catalogue 2002 (EWC 2002) and List of Waste Regulations 2005

The European Waste Catalogue 2002 (EWC) is a non-exhaustive, hierarchical list of waste types established by the European Commission (2000/532/EC), under which all wastes should be classified. It is bought in to force by List of Wastes (England) and List of Wastes (Wales) Regulations 2005. Under the Environment Protection Act (Duty of Care) Regulations 1990 (as amended) in England and Wales, all waste producers (including waste spread to land) must classify their waste using one of the six-digit codes set out in the EWC. European Waste Catalogue (EWC) codes are the same as List of Waste (LoW) Codes.

The List of Waste codes are split in to twenty chapters based on the source from which the waste was generated (making up the first two digits of the code). This is further split in to subchapters (giving the third and forth digits of the code), in which the waste descriptions are given (see Figure 2.1).

The Regulations do not define the wastes allowed to be spread to land by LoW code, although the descriptions given under Schedule 3 Paragraph 7 are taken from the EWC. Applications

5 http://www.defra.gov.uk/farm/wholefarm/index.htm

6 Commission of the European Communities v Kingdon of Spain, C-416/02, 2005

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for Paragraph 7 exemptions require all wastes to be defined by a LoW code, and this is the categorisation system used throughout this report.

Figure 2.1 Basis of a LoW code

Code of Good Agricultural Practice

The Code of Good Agricultural Practice for the protection of water soil and air7 was released by Defra in 2009 and updates and consolidates the previous separate guidance documents for Water, Soil and Air. It provides non-statutory guidance for farmers on how to comply with relevant legislation and minimise agriculture‟s impact on the environment. The code of practice provides practical advice on spreading of organic materials to land, including advise on how to minimise losses to surface and groundwater.

2.2 Regulator organisation

2.2.1 Assessment

Exemptions from Environmental Permitting Regulations are divided into notifiable (complex) and non-notifiable (simple) exemptions. Applications are assessed and enforced by the Environment Agency in England and Wales.

Since April 2008, all notifications for notifiable exemptions (including Paragraph 7 exemptions) have been assessed at one of five National Permitting Centres, by dedicated permitting officers. Prior to April 2008, notifications were assessed at local area level by a more dispersed team of assessment officers.

The role of the National Permitting Centres is to assess notifications for their agricultural benefit/ecological improvement, and the wastes potential dis-benefits.

Agricultural benefit/ ecological improvement

As discussed above, spreading of waste to land is exempt from permitting requirements due to Article 14 of the Waste Framework Directive (2006/12/EC). Operators for Paragraph 7

7 http://www.defra.gov.uk/farm/environment/cogap/pdf/cogap090202.pdf

** ** **

From Waste Chapter

From Sub-chapter

Waste description

http://www.defra.gov.uk/farm/environment/cogap/pdf/cogap090202.pdf

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exemptions from permit requirements must show agricultural benefit or ecological improvement to show they are „serving a useful purpose by replacing other materials‟ e.g. nitrogen fertilisers or liming agents.

To claim agricultural benefit it must be proved that the waste will improve the soil for growing crops or grazing. The definition used by the Environment Agency for agricultural benefit/ecological improvement is that given by Davis and Rudd8.

Agricultural benefit may be considered in terms of:-

i) Crop yield and quality.

ii) Soil chemical properties (e.g. addition of plant nutrients and soil pH control).

iii) Soil physical properties (e.g. water holding capacity, porosity and stability).

iv) Soil biological properties (e.g. root growth conditions, soil invertebrate and microbial populations).

v) Soil water content (e.g. direct moisture addition from liquid wastes).

Each of the aforementioned benefits would require different analyses and assessment of the waste, soil and crop to provide the necessary evidence. The guidance for notification of an exemption does not specify what assessment is required for each case. The guidance does provide some indication of minimum analysis requirements of waste and soil, and that advice from an accredited agronomist should be sought. These minimum requirements, with some additional determinands as advised by an agronomist (or similar expert) are likely to be used in most notifications. In general, a waste material is considered to provide agricultural benefit „if it contains measurable quantities of nutrients identified by DEFRA‟S RB209 Fertiliser Handbook as being required by the receiving soil‟.

For waste the minimum analysis requirements are:

pH

Nitrogen (available and total)

Phosphorous (P)

Potassium (K)

Percentage dry matter. Additional minimum requirements (unless operator can justify it is not necessary) are for:

Metals – Zinc (Zn), Copper (Cu), Nickel (Ni), Lead (Pb), Cadmium (Cd), Mercury (Hg)

Magnesium (Mg)

Sodium (Na)

Sulphur (S)

8 Davis, RD, and Rudd C, (April 1998) Investigation of the criteria for, and guidance on, the landspreading of

industrial wastes. WRc report No. UC3757

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The soil analysis requirements are less defined but the minimum include:

Soil type

pH

Phosphorous

Potassium

Magnesium If the number of determinands are minimised then this means that most claims of agricultural benefit are likely to be based on soil chemical properties (addition of plant nutrients and soil pH control). As most soils are rarely deficient in P, K, and Mg the assessment should include an estimation of the removal of these elements from the soil by the crop to be replaced by the addition from waste.

2.2.2 Enforcement

Once an exemption is accepted and registered, Environment Officers at local area offices are responsible for follow-up inspections and enforcement of Paragraph 7 exemptions. Environment Agency Service Level Agreements (SLA) state that notifiable exemptions should be inspected on average once per year. The SLA allows a degree of flexibility, such that some sites will be visited more often, and some sites not at all.

All exempt sites must meet the relevant objectives set out in Article 4 of the Waste Framework Directive:

“Member States shall take the necessary measures to ensure that waste is recovered or disposed of without endangering human health and without using processes or methods which could harm the environment, and in particular: — without risk to water, air, soil and plants and animals, — without causing a nuisance through noise or odours, — without adversely affecting the countryside or places of special

interest.‖ In addition to this requirements specific to Paragraph 7 exemptions are set out in Schedule 3 of The Environmental Permitting Regulations 2007.

Where exemption operators are found not to meet the requirements specific to the exemption or the relevant objectives, the Environment Agency can de-register that exemption, and therefore no further waste is allowed to be spread under that exemption. The Environment Agency will deregister an exemption where they:

―fail to comply with a condition of an exemption; or carry out the operation in a way that threatens to harm the environment or in

particular– (i) poses a risk to water, air, soil, plants or animals; or

(ii) causes nuisance through noise or odours; or

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(iii) adversely affects the countryside or places of special interest.‖9

If it is considered that the operation is outside the scope of the exemption, the operator is liable to prosecution under Section 33 of The Environment Protection Act 1990. In addition, in the event that the exempt operation leads to pollution of controlled waters, the operator is liable to prosecution under Section 85 of The Water Resources Act 1991; regardless of whether the requirements of the exemption are met.

2.3 Requirements for application

2.3.1 Sampling

Guidance for completing Paragraph 7 application forms indicates the operator should follow guidance given in DEFRA‟S RB209 Fertiliser Handbook document for how to sample soils. This analysis should be no more than 4 years old. For waste sampling, no reference is given other than the „sampling analysis‟ should be appropriate to the waste which is being tested.

Defra‟s RB209 Fertiliser handbook gives the following specific recommendations for sampling soils10:

Samples of 3 depths should be taken and analysed separately (0-30 cm, 30 cm - 60 cm and 60 cm - 90 cm). Except for shallow rooted crops.

If sampling for soil nitrogen, samples should not be taken for 2-3 months after applying nitrogen fertilisers.

In most cases samples should be taken in autumn or spring for soil nitrogen.

Areas known to have different soil characteristics should be sampled and analysed separately.

10 sub-samples should be taken for each field (more if practicably feasible), and 25 samples in the case of P, K and Mg.

After sampling samples should be refrigerated and analysed as soon as possible.

Leave as long as possible between the last fertiliser or manure application. If possible, sample after the last fertiliser or manure application has been cultivated into the soil.

Do not sample within 6 months of a lime or fertiliser application (except nitrogen).

Sample at the same point in the rotation and well before growing a sensitive crop (e.g. sugar beet).

Avoid sampling when the soil is very dry. Farm manures can also contain heavy metals which on certain soils, for example copper deficient soils, can correct a trace element deficiency. However, in the majority of situations, the accumulation of heavy metals in the soil is the more important issue. Pig and poultry manures can contain elevated levels of zinc and copper, which in the long-term (over 100 years), may lead to undesirably high soil levels. Where pig or poultry manures have been

9 http://www.environment-

agency.gov.uk/static/documents/PS_008_Duty_to_remove_exemp_registrations_to_LP_final.pdf

10 This does not apply to sampling wastes, which RB209 makes no note of. However, many of the principles of soil sampling from RB209 can be applied to wastes.

http://www.environment-agency.gov.uk/static/documents/PS_008_Duty_to_remove_exemp_registrations_to_LP_final.pdf

http://www.environment-agency.gov.uk/static/documents/PS_008_Duty_to_remove_exemp_registrations_to_LP_final.pdf

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applied to land for a number of years and will continue to be applied, it is advisable to sample the soil periodically and carry out analysis for heavy metals.

Although undesirable in excessive amounts, zinc deficiency has very occasionally been found to reduce growth and cropping of apple trees on sandy soils. This deficiency can be corrected by foliar application of zinc. Excessive amounts during blossom or cell division may have a fruitlet thinning effect.

Such detailed guidance does not exist for waste sampling. The current standard for waste sampling for waste destined for landfill is given by the Environment Agency document11 on waste sampling and testing would appear to be the most relevant document, in the absence of any sampling guidance specific to waste to land.

The Paragraph 7 application guidance states that analytical methods should be in accordance with those given in Specification for Topsoil12, for soils. This gives guidance on sampling similar to that given in the Defra‟s RB209 Fertiliser handbook.

2.3.2 Record keeping

Schedule 2 Regulation 12(3) of the Environmental Permitting Regulations give the following record keeping requirement for all waste recovered under exemptions:

―(3) An establishment or undertaking which carries out an exempt waste operation to which this Paragraph applies must—

(a) keep records of the quantity, nature, origin and, where relevant, the destination and treatment method of all waste disposed of or recovered in the course of that activity;

(b) keep those records for a period of 2 years; and

(c) during that period make those records available to the exemption registration authority on request.‖

Requirements exist under other legislation such as Nitrogen Vulnerable Zones Regulations to keep records of what fertilisers have been spread.

11 Guidance on sampling and testing of wastes to meet landfill waste acceptance procedures, Version 1, April 2005

http://www.environment-agency.gov.uk/static/documents/Business/sampling_and_testing_1069398.pdf

12 Specification for Topsoil, BS 3882:2007

http://www.environment-agency.gov.uk/static/documents/Business/sampling_and_testing_1069398.pdf

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3. DATA COLLATION

3.1 Sources of information

The following sources of information were used in gathering data for the project:

REGIS (REGulation Information System for waste) database: This system stores the name, reference number and address of all registered exempt sites. This system was used to generate the sample of Paragraph 7 exemptions for the study.

Electronic Data Records Management (eDRM) system: eDRM stores scanned copies of all notifications for Paragraph 7 exemptions, as well as other correspondence between the Environment Agency and the operator. These scanned application forms formed the basis of the material characterisation.

National Incident Reporting System (NIRS): Stores details of all reported pollution incidents, including environmental impact and compliance assessment response.

A telephone survey of permitting officers at National Permitting Centres (NPC) at the Environment Agency, who are responsible for assessing notifications for Paragraph 7 exemptions.

A telephone survey of Area Process Liaison Officers (APLCs) in local Environment Agency offices, responsible for co-ordinating regulation and enforcement of registered Paragraph 7 exempt sites, once their application has been accepted.

A telephone survey of exemption operators. These are generally broker companies who do not own the land on which the waste material is spread, nor are they the waste producers.

3.2 The Agricultural Waste Database System

When the regulations came in to force in May 2006, the Waste Management (England & Wales) Regulations 2006 made many agricultural wastes controlled wastes for the first time. This had the effect that farmers had to notify for exemptions, albeit with a much reduced level of detail (see Section 1.1.3).

Information on exemptions applied for under the Agricultural Waste Regulations are kept on the Environment Agency‟s Agricultural Waste Database System. No information is kept on the waste types, composition or amounts spread, or on whether the waste is spread for agricultural improvement or ecological benefit. Exemptions made under these regulations were therefore not included in this study.

In the period April 2007 – April 2008 (the period for which Paragraph 7 notifications were assessed in this study), 13 363 notifications were received by the Environment Agency via the simplified form. A further 1410 exemptions were registered through Defra‟s Whole Farm

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Approach (WFA) website13. Exemptions registered through the Whole Farm Approach web-site do not have to be renewed.

The uptake of exemptions after registration is unknown. It is possible that many farmers register a Paragraph 7 application for the spreading of manure, which will be produced at most farms housing livestock. A recent European Court of Justice ruling14 found that livestock manure was not a waste, and would therefore not require an exemption in order to be spread to land, so these exemptions are registered in error. In addition many farmers may register these exemptions just in case, and consequently the full capacity is not used.

3.3 Paragraph 7 exemption notifications

At the project inception meeting (24th July 2008) with the Defra Project Officer, WRc proposed that the review would be based on one years‟ worth of Paragraph 7 notifications to collect information on waste types currently being spread to land. As Paragraph 7 exemptions have to be renewed every year, this approach would give a good indication of annual loadings.

3.3.1 Number of notifications

The Environment Agency‟s electronic data records management system (eDRM) was set up to hold all correspondence sent and received relating to the sites it regulates, including Paragraph 7 exemptions. Problems in extracting this data led to extensive delays in project reporting.

Table 3.1 shows a summary of notifications for this period.

Table 3.1 Summary of Paragraph 7 notifications for the period 30th April 2007 to 1st May 2008

Number of Applications Percentage of total (%)

Rejected* 101 5.1

Cancelled** 62 3.2

Registered (New notifications) 1255 64

Registered (Renewal notifications) 534 27

TOTAL 1952 -

*Cancelled notifications are notifications that were withdrawn prior to full assessment being made **Rejected notifications were rejected following assessment of the application, due to the application being incomplete or the waste/site being unsuitable.

13 http://www.defra.gov.uk/farm/wholefarm/index.htm

14 Commission of the European Communities v Kingdom of Spain, C-416/02, 2005

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Applications for a renewal of a Paragraph 7 are only possible where no information has changed regarding the site or the waste for the exemption. These notifications require only limited information, and to gather all information on these notifications, the original form would therefore have to be obtained. As it was not possible to extract pre-April 2007 application forms without manual intervention, this could not feasibly be achieved, given Environment Agency resource availability and the project timescale, The assessment has therefore only been made on new notifications, making up 64% of all notifications in the Paragraph.

3.3.2 Inputting data

The requirements for Paragraph 7 notifications are discussed in Section 2.2.1. A system for collating this information was devised, and template Excel spreadsheet documents created. A variety of protection and automatic copying facilities were employed to ensure standardisation of the data entry process. Full details of the system are described in Appendix A.

A data entry team was assembled for the task. Full training was given to each team member, and they were given detailed instructions on how data should be entered (reproduced in Appendix A).

Fields were created to enter data supplied from the application forms. The following fields were used for general details about the site where the waste is to be spread:

Renewal/New application

Original Application Ref. (if renewal)

Details changed since last application? If new; leave blank

No. of waste types

No. of fields

Is storage facility less than 10 m from w/c, 50 m from spring, 250 m from borehole

Capacity of storage

Intended storage

Is land currently used for agriculture (Y/N)

Is site within an NVZ

Is site within 1 km of SSSI or SAC

Has land been treated with waste in last 12 months

Waste spread in last 12 months (tonnes / ha)

Total land to be treated (hectares)

Improvement Claimed (Agricultural benefit/ecological improvement)

Any other sources of nutrients

Other source

How often will waste be spread (once/ several times)

Start Date of spreading

End Date

Method of application

Rate of application (amount per area e.g. tonnes/ha or m3/ha)

rate of application (unit)

Grid ref.

Slurries/manures spread on land in last 12 months - type

Total amount of slurry/manure spread in last year

Has hazard assessment been carried out?

Number of hazards identified.

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In a separate section of the application, information supplied on soils was collected. Information could be entered for up to three sets of soil/crop analysis. The following fields were used:

Site Address

Current crop

Proposed next crop

Soil type

pH

% Dry Matter

% Moisture content

Total N

Total extractable (available) NH3 (ammonium)

Total extractable (available) Nitrate (NO3)

Total P

Extractable (available) P or Phosphate

Total K

Extractable (available) K

Total S

Extractable (available) S

Total Mg

Extractable (available) Mg

Organic matter (or LOI or VS)

organic carbon

C:N ratio

COD

Other nutrient info

Water holding capacity

Nitrogen mineralisation rate

Soil respiration rate

Lime requirement

SNS index

Method of analysis for PTEs

Zn

Cu

Ni

Pb

Cd

Cr

Hg

Other PTE info

Yield

Nutrient off-take -P

Nutrient off-take - K

Nutrient off-take - N

Other crop analysis. Finally, a section for collation of waste analysis was devised. Space for up to 10 different waste stream analysis was allowed. Where more than 10 waste streams were spread (in

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approximately 53 cases), details on the 10 highest volume wastes were taken. Fields were also created to allow entry of duplicate analysis. The following fields were set up for waste analysis:

Process from which the waste arises

General process category

Kind of waste

Producer of the waste

Physical form

Total amount to be used

LoW code

Amount spread per hectare

Is waste treated prior to spreading?

Date sampled

Lab name

pH

% Dry Matter

% Moisture content

Total N

Extractable (available) N

Total NH3 (ammonium)

Total Nitrate (NO3)

Total P

Extractable (available) P or Phosphate

Total K

Extractable (available) K

Total S

Extractable (available) S

Total Mg

Extractable (available) Mg

Organic matter (or LOI or VS)

Organic carbon

C:N ratio

COD

Neutralising capacity

Other nutrient info

Method of analysis for PTEs

Zn

Cu

Ni

Pb

Cd

Cr

Hg

Other PTE information

Organics pollution data

Alkalinity

Biodegradation data.

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3.4 Biobed Material

The spreading of biobed material is regulated under Schedule 3, Paragraph 16 of the Environmental Permitting Regulations 2007. Exemptions for this type of spreading will therefore not appear in the list of wastes spread under Paragraph 7.

There are 116 exemptions registered for Paragraph 16 exemptions currently registered in England and Wales. As Paragraph 16 exemptions are considered a non-notifiable (simple) exemptions (as opposed to notifiable (complex) exemptions such as Paragraph 7), the same level of detail is not required for the application, and we therefore were unable to assess information for this waste type. This exemption can only be registered through the Agricultural Waste System, and therefore no details other than the operators name and address are available.

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4. RESULTS

4.1 Tier 1 Risk Assessment

4.1.1 Methodology

The full methodology for the risk assessment is discussed in full in Appendix A. All wastes were considered in terms of:

Total amount spread in England and Wales

Average loading rate per site

Heavy metal loading (Zn, Cu, Ni, Pb, Cd, Cr, Hg)

Nutrient loading per site per hectare (P and N)

Biodegradability

Pathogen risk

Organic Pollutants.

The total amount of waste spread, loading rates, heavy metal content and nutrient content is all information that could be extracted from Paragraph 7 application forms. However, WRc found that the application forms contained almost no information on biodegradability, pathogen risk or organic pollutants, although these are potentially key in an evaluation of risk. These parameters are not part of the minimum required information by operators, and it therefore appears on only a handful of notifications (in the case of biodegradability, none at all). This part of the risk assessment was therefore largely qualitative.

4.1.2 Biodegradability

Biodegradability was considered in terms of potential for the wastes to biodegrade, and thus produce greenhouse gases (NO2, CH4, CO2). Guidance for notifications of Paragraph 7 exemptions does not currently require details of biodegradability, and this information is therefore not provided by operators.

4.1.3 Nutrients

Plants need phosphorus and nitrogen to grow. Both of these nutrients are naturally found in water. Higher levels of phosphorus in water can lead to increased algal growth in freshwater. Higher levels of nitrate are of concern in relation to drinking water abstractions and can lead to increased algal growth in the sea.

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Rivers with the highest concentrations of phosphate and nitrate are mainly in central and eastern England, reflecting the geology, agricultural inputs and higher population, although there has been little change over time.

Nitrogen (N) chemistry is extremely complex, and is relevant to soil chemistry only in relation to organic matter. However, for simplicity total nitrogen has been used in the risk assessment, as Carbon:Nitrogen ratios and total organic carbon analysis was not always supplied with the notifications.

Nitrate Vulnerable Zones (NVZs) were designated in England and Wales (and expanded by the Nitrate Pollution Prevention Regulations 2008) as areas with high nitrates in surface waters, with agriculture being a major contributor. In these zones specific restrictions are placed on farmers regarding spreading of nitrogen fertilisers, including waste to land operations.

The regulations state that in an NVZ, organic manure loadings (including waste materials spread under Paragraph 7) should not be spread at a rate exceeding 250 kg/ha total nitrogen for areas of the farm in grass (170 kg/ha for areas not in grass). Although not all Paragraph 7 sites are located in NVZs (for example, only 3% of Wales is currently covered by NVZs) and nitrogen loadings should be assessed on a site-by-site basis, we have utilised this limit for the sake of simplicity in comparing such a large number of waste streams.

As most operators conducted their agricultural assessment so as to meet this limit, WRc found only a small number of sites spread nitrogen a rate greater than 250 kg/ha. We therefore used 200 kg/ha as a limit representing a high nitrogen loading.

4.1.4 Heavy Metals

As a minimum (unless the operator can justify this is not necessary), all notifications for Paragraph 7 exemptions require total concentrations of Zn, Cu, Ni, Pb, Cd and Hg. These are then assessed against the levels set in the sludge regulations (reproduced in Appendix C).

Where it can be reasonably considered that other potentially toxic elements may be present in the waste, concentrations of these must also supplied by the operator. This has not been supplied by the majority operators, and this data has therefore not been collated.

4.2 Tier 1 Risk Assessment – Ranking

Once each waste type was considered in terms of the parameters outlined above and in Appendix C, a score out of a theoretical maximum of 17.2 was assigned based on the total amount of waste spread, and the characteristics of the waste. A summary of these results is presented in Table 4.1 (blank cells indicate no information was available for that parameter).

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Table 4.1 Tier 1 risk assessment

Rank LoW Code Waste Description

Total score

Total Spread

(t)

Average loading

(t/ha)

Zn (kg/ha)

90th percentile

Cu (kg/ha)

90th percentile

Ni (kg/ha) 90th

percentile

Pb (kg/ha)

90th percentile

Cd (kg/ha) 90th

percentile

Cr (kg/ha) 90th

percentile

Hg (kg/ha) 90th

percentile

N (kg/ha) 90th

percentile

P (kg/ha) 90th

percentile

1 17 05

06

Construction and Demolition Wastes (including Excavated Soil from

Contaminated Sites); soil (including excavated soil from contaminated sites), stones and dredging spoil; dredging spoil other than those mentioned in 17 05 05

7.0 238710 662 70 10.3 9.34 48.8 0.389 10.5 0.233 281 329

2 19 09

02

Wastes from Waste Management Facilities, Off-Site Waste Water

Treatment Plants and the Preparation of Water for Human Consumption and

Water for Industrial Use; wastes from the preparation of water intended for human consumption or water for industrial use;

sludges from water clarification

5.9 708630 104 8.77 3.21 4.19 1.92 0.0306 0.739 0.00625 244 119

3 02 02

04

Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and

Fishing, Food Preparation and Processing; wastes from the preparation and processing of meat. Fish and other foods of animal origin; sludges from on-

site effluent treatment

5.9 428452 155 4.22 3.06 2.23 0.125 0.1 0.763 0.01 251 118

4 02 07

05


Fishing, Food Preparation and Processing; wastes from the production

of alcoholic and non-alcoholic beverages (except coffee, tea and cocoa); sludges

from on-site effluent treatment

4.7 108452 164 12.6 0.384 0.072 0.15 0.00625 0.938 0.01 250 101

5 02 06

03


Fishing, Food Preparation and Processing; wastes from the baking and confectionery industry; sludges from on-

site effluent treatment

4.7 120074 131 1.08 1.83 1.06 0.1 0.1 0.105 0.01 251 87.3

6 02 02

99


Fishing, Food Preparation and Processing; wastes from the preparation

4.7 249525 146 1.25 2 2 0.12 0.0128 0.625 0.00402 250 48.7

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Total score

Total Spread

(t)

Average loading

(t/ha)

Zn (kg/ha)

90th percentile

Cu (kg/ha)

90th percentile

Ni (kg/ha) 90th

percentile

Pb (kg/ha)

90th percentile

Cd (kg/ha) 90th

percentile

Cr (kg/ha) 90th

percentile

Hg (kg/ha) 90th

percentile

N (kg/ha) 90th

percentile

P (kg/ha) 90th

percentile

and processing of meat. Fish and other foods of animal origin; wastes not

otherwise specified

7 02 02

01


Fishing, Food Preparation and Processing; wastes from the preparation and processing of meat. Fish and other

foods of animal origin; sludges from washing and cleaning

4.7 371252 179 2.04 1.58 1.52 0.125 0.1 1.25 0.01 249 60.7

8 17 05

04


Contaminated Sites); soil (including excavated soil from contaminated sites),

stones and dredging spoil; soil and stones other than those mentioned in 17

05 03

4.5 96135 1208 0.446 0.182 2.85 0.135 1.2 0.162 0.257

9 02 02

03



foods of animal origin; materials unsuitable for consumption or processing

3.9 84411 115 6.5 3.5 5.5 0.113 0.0125 0.625 0.0024 250 123

10 02 07

01



of alcoholic and non-alcoholic beverages (except coffee, tea and cocoa); wastes from washing, cleaning and mechanical

reduction of raw materials

3.8 130822 156 0.224 0.132 0.0774 0.0848 0.00315 0.0508 0.0012 183 14.3

11 02 03

99


Fishing, Food Preparation and Processing; wastes from fruit, vegetables,

cereals, edible oils, cocoa, coffee, teas and tobacco preparation and processing,

conserve production, yeast and yeast extraction production, molasses

preparation and fermentation; wastes not

3.8 248911 156 1.18 1.7 0.77 0.125 0.125 0.161 0.0125 236 40.3

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Total score

Total Spread

(t)

Average loading

(t/ha)

Zn (kg/ha)

90th percentile

Cu (kg/ha)

90th percentile

Ni (kg/ha) 90th

percentile

Pb (kg/ha)

90th percentile

Cd (kg/ha) 90th

percentile

Cr (kg/ha) 90th

percentile

Hg (kg/ha) 90th

percentile

N (kg/ha) 90th

percentile

P (kg/ha) 90th

percentile

otherwise specified

12 02 03

05





preparation and fermentation; sludges from on-site effluent treatment

3.8 481295 172 1.47 2.08 1.26 0.125 0.125 0.5 0.0125 115 23.9

13 02 03

01





preparation and fermentation; sludges from washing, cleaning, peeling,

centrifuging and separation

3.8 440565 161 1.62 0.8 0.675 0.125 0.0425 0.625 0.01 214 26.4

14 02 03

04





preparation and fermentation; materials unsuitable for consumption or processing

3.1 56316 109 1.58 1.61 0.678 0.125 0.125 0.125 0.0125 50 75.2

15 Mixed Sludge

- 3.0 161079 124 1.87 0.338 0.0678 0.802 0.00409 0.338 0.00599 293 28.5

16 02 07

99



of alcoholic and non-alcoholic beverages (except coffee, tea and cocoa); wastes

3.0 497233 191 0.508 0.575 0.27 0.125 0.125 0.125 0.0125 220 18.1

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Total score

Total Spread

(t)

Average loading

(t/ha)

Zn (kg/ha)

90th percentile

Cu (kg/ha)

90th percentile

Ni (kg/ha) 90th

percentile

Pb (kg/ha)

90th percentile

Cd (kg/ha) 90th

percentile

Cr (kg/ha) 90th

percentile

Hg (kg/ha) 90th

percentile

N (kg/ha) 90th

percentile

P (kg/ha) 90th

percentile

not otherwise specified

17 02 05

02


Fishing, Food Preparation and Processing; wastes from the dairy

products industry; sludges from on-site effluent treatment

3.0 521597 146 0.602 0.75 1 0.125 0.0125 0.125 0.0125 242 53.3

18 02 04

03


Fishing, Food Preparation and Processing; wastes from sugar

processing; sludges from on-site effluent treatment

3.0 172260 160

19 19 05

99



Water for Industrial Use; wastes from aerobic treatment of solid wastes; wastes

not otherwise specified

2.9 553499 42 5.36 2.35 0.715 4.34 0.016 0.781 0.00544 253 48.6

20 20 02

01

Municipal Wastes (Household Waste and Similar Commercial, Industrial and

Institutional Wastes) Including Separately Collected Fractions; garden and park wastes (including cemetery waste);

biodegradable waste

2.3 215887 52 6.61 1.76 0.728 5.02 0.0245 1.39 0.0103 346 55.1

21 19 06

06



Water for Industrial Use; wastes from anaerobic treatment of waste; digestate from anaerobic treatment of animal and

vegetable waste

2.3 95702 35 248 9.29

22 03 03

05

Wastes from Wood Processing and the Production of Panels and Furniture, Pulp, Paper and Cardboard; wastes from pulp,

paper and cardboard production and processing; de-inking sludges from paper

recycling

2.3 1148230 100 3.84 8.22 1.18 0.721 0.0169 1.21 0.0033 217 30.2

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Total score

Total Spread

(t)

Average loading

(t/ha)

Zn (kg/ha)

90th percentile

Cu (kg/ha)

90th percentile

Ni (kg/ha) 90th

percentile

Pb (kg/ha)

90th percentile

Cd (kg/ha) 90th

percentile

Cr (kg/ha) 90th

percentile

Hg (kg/ha) 90th

percentile

N (kg/ha) 90th

percentile

P (kg/ha) 90th

percentile

23 Other - 2.0 26135 193 6.39 0.405 0.0791 0.676 0.00579 1.19 0.00965 249 2.12

24 02 06

01


Fishing, Food Preparation and Processing; wastes from the baking and

confectionery industry; materials unsuitable for consumption or processing

2.0 76061 161 0.388 0.804 0.56 0.1 0.1 0.1 0.01 251 12.4

25 02 05

99



products industry; wastes not otherwise specified

2.0 41548 127 3.16 0.756 0.482 0.0384 0.00118 0.394 0.005 155 19.9

26 02 04

02


Fishing, Food Preparation and Processing; wastes from sugar

processing; off-specification calcium carbonate

2.0 21364 160

27 02 02

02



foods of animal origin; animal tissue waste

2.0 41990 105 0.451 0.742 0.0313 0.0116 27.8 12.1

28 19 06

99



Water for Industrial Use; wastes from anaerobic treatment of waste; wastes not

otherwise specified

2.0 72774 73 1.93 0.921 0.179 0.149 0.000832 0.0933 0.000611 381 26.1

29 19 05

03



Water for Industrial Use; wastes from aerobic treatment of solid wastes; off-

2.0 24652 35 4.22 4.9 1.78 1.25 0.0294 0.632 0.00566 240 84.7

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Total score

Total Spread

(t)

Average loading

(t/ha)

Zn (kg/ha)

90th percentile

Cu (kg/ha)

90th percentile

Ni (kg/ha) 90th

percentile

Pb (kg/ha)

90th percentile

Cd (kg/ha) 90th

percentile

Cr (kg/ha) 90th

percentile

Hg (kg/ha) 90th

percentile

N (kg/ha) 90th

percentile

P (kg/ha) 90th

percentile

specification compost

30 02 07

04



of alcoholic and non-alcoholic beverages (except coffee, tea and cocoa); materials unsuitable for consumption or processing

1.6 72837 92 0.31 0.065 0.164 0.0163 0.003 0.0208 0.00588 173 28.8

31 02 05

01



products industry; materials unsuitable for consumption or processing

1.5 151345 72 0.28 0.0326 0.0175 0.00931 0.00237 0.0163 0.0125 77.4 51.6

32 02 02

44



foods of animal origin;

1.5 0 250

33 04 02

20

Wastes from the Leather, Fur and Textile Industries; wastes from the textile

industry; sludges from on-site effluent treatment other than those mentioned in

04 02 19

1.3 32087 33 2.49 0.867 0.147 0.28 0.00447 0.0974 0.00257 213 34.1

34 02 07

03




from chemical treatment

1.3 11136 160

35 19 06

04



Water for Industrial Use; wastes from anaerobic treatment of waste; digestate from anaerobic treatment of municipal

waste

1.0 26100 50 0.22 0.113 0.00975 0.0024 0.00015 0.0064 0.0001 304 8

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Total score

Total Spread

(t)

Average loading

(t/ha)

Zn (kg/ha)

90th percentile

Cu (kg/ha)

90th percentile

Ni (kg/ha) 90th

percentile

Pb (kg/ha)

90th percentile

Cd (kg/ha) 90th

percentile

Cr (kg/ha) 90th

percentile

Hg (kg/ha) 90th

percentile

N (kg/ha) 90th

percentile

P (kg/ha) 90th

percentile

36 19 06

03



Water for Industrial Use; wastes from anaerobic treatment of waste; liquor from anaerobic treatment of municipal waste

1.0 17400 200

37 10 13

04

Waste From Thermal Processes; wastes from manufacture of cement, lime and plaster and articles and products made from them; wastes from calcination and

hydration of lime

1.0 52397 15 0.235 0.0765 0.0975 0.0452 0.00842 0.113 8.69E-05 4.34 0.469

38 03 03

11


paper and cardboard production and processing; sludges from on-site effluent treatment other than those mentioned in

03 03 10

1.0 2214 140

39 03 03

01


paper and cardboard production and processing; waste bark and wood

1.0 33845 83 0.446 0.256 0.189 0.137 0.00123 0.077 0.00425 194 23.5

40 03 01

05

Wastes from Wood Processing and the Production of Panels and Furniture, Pulp, Paper and Cardboard; wastes from wood processing and the production of panels

and furniture; sawdust, shavings, cuttings, wood, particle board and veneer other than those mentioned in 03 01 04

1.0 19217 41 4.79 0.89 0.508 6.38 0.0132 1.95 0.009 270 10.9

41 02 06

99


Fishing, Food Preparation and Processing; wastes from the baking and

confectionery industry; wastes not otherwise specified

1.0 36932 14 0.284 0.0952 0.114 0.0535 0.00984 0.132 0.000145 9.5 3.43

42 02 04

99


Fishing, Food Preparation and

1.0 9445 168 0.25 0.25 0.25 0.125 0.163 0.25 0.0125 199 57.9

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Total score

Total Spread

(t)

Average loading

(t/ha)

Zn (kg/ha)

90th percentile

Cu (kg/ha)

90th percentile

Ni (kg/ha) 90th

percentile

Pb (kg/ha)

90th percentile

Cd (kg/ha) 90th

percentile

Cr (kg/ha) 90th

percentile

Hg (kg/ha) 90th

percentile

N (kg/ha) 90th

percentile

P (kg/ha) 90th

percentile

Processing; wastes from sugar processing; wastes not otherwise

specified

43 02 02

05



foods of animal origin;

1.0 23838 49 250 76.9

44 02 01

03


Fishing, Food Preparation and Processing; wastes from agriculture,

horticulture, aquaculture, forestry, hunting and fishing; plant tissue waste

1.0 39601 38 3.15 0.547 0.268 1.3 0.0111 0.297 0.00581 254 54

45 02 01

06


Fishing, Food Preparation and Processing; wastes from agriculture,

horticulture, aquaculture, forestry, hunting and fishing; animal faeces, urine and

manure (including spoiled straw), effluent, collected separately and treated off-site

0.8 10791 82 3.22 0.311 0.073 0.0467 0.00132 0.119 0.000306 132 64.3

46 02 03

03





preparation and fermentation; wastes from solvent extraction

0.6 1218 60 7.21 3.41 0.828 2.1 0.0108 1.13 0.00119 217 47.7

47 02 03

02





0.6 2429 54 0.76 1.55 0.257 0.102 0.102 0.102 0.0102 16.3 11.6

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Total score

Total Spread

(t)

Average loading

(t/ha)

Zn (kg/ha)

90th percentile

Cu (kg/ha)

90th percentile

Ni (kg/ha) 90th

percentile

Pb (kg/ha)

90th percentile

Cd (kg/ha) 90th

percentile

Cr (kg/ha) 90th

percentile

Hg (kg/ha) 90th

percentile

N (kg/ha) 90th

percentile

P (kg/ha) 90th

percentile

preparation and fermentation; wastes from preserving agents

48 Mixed - 0.5 6099 92 225 42.2

49 27 07

05 - 0.5 0

50 26 07

05 - 0.5 0

51 22 07

05 - 0.5 0

52 22 06

07 - 0.5 1618 23 1.67 0.427 246 31.3

53 19 09

05



Water for Industrial Use; wastes from the preparation of water intended for human consumption or water for industrial use; saturated or spent ion exchange resins

0.5 5254 40 1.94 0.618 0.72 0.616 0.0184 0.747 0.00699 61.4 49.5

54 19 09

01



Water for Industrial Use; wastes from the preparation of water intended for human consumption or water for industrial use; solid wastes from primary filtration and

screenings

0.5 3882 50 4.65 0.498 0.775 0.737 0.000093 0.167 0.0013 136 24.1

55 19 05

19



Water for Industrial Use; wastes from aerobic treatment of solid wastes;

0.5 3393 20 1.97 1.04 0.143 0.21 0.00367 0.106 0.002 250 55.5

56 19 05 Wastes from Waste Management Facilities, Off-Site Waste Water

0.5 4376 21 4.26 1.27 0.17 10.3 0.0111 0.26 0.00656 310 60

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Total score

Total Spread

(t)

Average loading

(t/ha)

Zn (kg/ha)

90th percentile

Cu (kg/ha)

90th percentile

Ni (kg/ha) 90th

percentile

Pb (kg/ha)

90th percentile

Cd (kg/ha) 90th

percentile

Cr (kg/ha) 90th

percentile

Hg (kg/ha) 90th

percentile

N (kg/ha) 90th

percentile

P (kg/ha) 90th

percentile

09 Treatment Plants and the Preparation of Water for Human Consumption and

Water for Industrial Use; wastes from aerobic treatment of solid wastes;

57 17 08

02


Contaminated Sites); gypsum-based construction material; gypsum-based

construction materials other than those mentioned in 17 08 01

0.5 205

58 17 02

01


Contaminated Sites); wood, glass and plastic; wood

0.5 3435

59 17 01

07


Contaminated Sites); concrete, bricks, tiles and ceramics; mixtures of concrete,

bricks, tiles and ceramics other than those mentioned in 17 01 06

0.5 3480

60 15 03

05

Waste Packaging, Absorbents, Wiping Cloths, Filter Materials and Protective Clothing Not Otherwise Specified; ;

0.5 0

61 12 08

05

Wastes from Shaping and Physical and Mechanical Surface Treatment of Metals

and Plastics; ; 0.5 0

62 12 03

99

Wastes from Shaping and Physical and Mechanical Surface Treatment of Metals

and Plastics; wastes from water and steam degreasing processes (except 11);

0.5 1982 27 0.396 0.0998 0.0675 0.0853 0.00427 0.0874 0.000171 220 50.3

63 10 13

99

Waste From Thermal Processes; wastes from manufacture of cement, lime and plaster and articles and products made

from them; wastes not otherwise specified

0.5 1044 12 0.086 0.0446 0.107 0.0205 0.000172 0.218 0.000505 0.000667 0.621

64 10 10

13

Waste From Thermal Processes; wastes from casting of non-ferrous pieces; waste binders containing dangerous substances

0.5 807 36.7 1.53 0.899 0.688 0.517 0.0639 0.878 0.00045 45 2.88

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Total score

Total Spread

(t)

Average loading

(t/ha)

Zn (kg/ha)

90th percentile

Cu (kg/ha)

90th percentile

Ni (kg/ha) 90th

percentile

Pb (kg/ha)

90th percentile

Cd (kg/ha) 90th

percentile

Cr (kg/ha) 90th

percentile

Hg (kg/ha) 90th

percentile

N (kg/ha) 90th

percentile

P (kg/ha) 90th

percentile

65 08 08

05

Wastes from the MFSU of Coatings (Paints, Varnishes and Vitreous

Enamels), Adhesives, Sealants and Printing Inks; ;

0.5 0

66 07 05

12

Wastes from Organic Chemical Processes; wastes from the MFSU of pharmaceuticals; sludges from on-site

effluent treatment other than those mentioned in 07 05 11

0.5 1060 19.4 0.0505 0.00467 0.00253 0.00251 9.72E-05 0.0069 0.000486 28.6 2.94

67 04 02

10

Wastes from the Leather, Fur and Textile Industries; wastes from the textile

industry; organic matter from natural products (e.g. grease, wax)

0.5 4221 14.2 4.12 0.369 0.0108 0.0651 0.00217 0.13 0.00325 174

68 03 05

05

Wastes from Wood Processing and the Production of Panels and Furniture, Pulp,

Paper and Cardboard; ; 0.5 0

69 03 03

99


paper and cardboard production and processing; wastes not otherwise

specified

0.5 5217 60.0 0.588 0.211 0.132 0.0396 0.00198 0.0927 0.000158 82.4 4.47

70 02 07

02




from spirits distillation

0.5 4755 33.2 0.0275 0.435 3.67 5.43

71 02 05

09



products industry;

0.5 207 2.5 0.125 0.025 0.0125 0.00125 0.000025 0.0125 0.138 0.215

72 01 09

02

Wastes resulting from exploration, Mining, Quarrying, Physical and Chemical

treatment of Minerals; ; 0.5 1590 40 6.11 0.248 0.852 0.719 0.0174 0.0811 0.000618 171 62.5

73 01 05 Wastes resulting from exploration, 0.5 0

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Total score

Total Spread

(t)

Average loading

(t/ha)

Zn (kg/ha)

90th percentile

Cu (kg/ha)

90th percentile

Ni (kg/ha) 90th

percentile

Pb (kg/ha)

90th percentile

Cd (kg/ha) 90th

percentile

Cr (kg/ha) 90th

percentile

Hg (kg/ha) 90th

percentile

N (kg/ha) 90th

percentile

P (kg/ha) 90th

percentile

04 Mining, Quarrying, Physical and Chemical treatment of Minerals; drilling muds and other drilling wastes; freshwater drilling

muds and wastes

Blank cells in the table indicate that no information was available for that particular determinand.

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4.3 Location of sites

Figure 4.1, shows the distribution of the exemptions assessed for the year May 07 – May 08. The map is complete for 93% of the sites for which data was acquired. The remaining 7% of sites that do not appear on the map are made up of sites where the notification grid reference was not reported (105 sites), or was incorrect or in a non-recognisable format (39 sites).

Figure 4.1 Map showing location of registered Paragraph 7 exemptions in England and Wales

The map shows a fairly even spread of Paragraph 7 sites across England and Wales. Clusters of sites can be seen in a number of areas, particularly in the North West. The Environment Agency estimate around 80% of the North West land use is classified as agricultural and are the second largest producer of agricultural waste in England and Wales.

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Maps for each waste type are reproduced in Section 5.

The map below shows a close up of the area of South-West Cornwall. The cluster that can be seen is for 28 notifications for Paragraph 7 exemptions by a single operating company.

Figure 4.2 Map showing location of registered Paragraph 7 exemptions in Cornwall and Devon

This clustering can be seen in other areas of the country. This map of the North West and North Wales shows a group of 7 notifications by a single operator.

In terms of potential risk it is important where there are such clusters of activity that individual notifications should not be considered in isolation, as many may drain to the same watercourse, and may have a substantial cumulative impact.

28 notifications

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Figure 4.3 Map showing location of registered Paragraph 7 exemptions in North West

4.4 Spreading on non-agricultural and agricultural land

Of the 1255 notifications assessed where an answer was provided as to whether the land to be used was agricultural land, 1209 (99%) were used on agricultural land. Only 12 sites were registered for non-agricultural land, of which 6 were registered for benefit to agriculture, and 6 for ecological improvement.

As one of the requirements of the exemption is to show benefit to agriculture, we would expect to see a low number of exemptions being registered for non-agricultural land.

Sewage Sludge can be spread on non-agricultural land by virtue of Schedule 3 Paragraph 6 exemptions. As this is a separate exemption to Paragraph 7, these exemptions would not appear in our assessment of notifications.

The Sludge (Use in Agriculture) Regulations gives the definition of agriculture as:

“the growing of all types of commercial food crops, including for stock-rearing purposes”

Land where non-food crops such as oilseeds (where not used as a food) and fibre crops (jux, flax, hemp and cotton) are grown would not be considered agricultural land. However, in the case of oilseeds, these are almost always (in 92% of cases assessed) grown in rotation with cereals, and this land would therefore be classed as agricultural.

7 notifications

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4.5 Number of Wastes spread on site

Table 4.2 shows the number of Paragraph 7 notifications where notifications cover more than one waste type.

Table 4.2 Suggested LoW codes for wastes consigned as 02 02 99

Number of wastes applied for Number of notifications

Percentage (%) notifications

1 931 74

2 87 6.9

3 90 7.1

4 28 2.2

5 11 0.87

6-10 56 4.4

11-20 46 3.7

20+ 29 2.3

Although the majority of sites spread only one type of waste, a significant number of sites (26%) spread more than one and 6% greater than 10 wastes.

The current application process is the same regardless of the number of types of waste being applied to land. All waste types must be shown to confer agricultural benefit/ ecological improvement on an individual basis rather than as a mixed waste stream.

From interviews with Permit Assessment Officers responsible for assessing notifications for Paragraph 7 exemptions, we have determined that notifications for large numbers of waste types require a substantial amount more work to assess than notifications for a single waste, as each waste stream must be considered individually.

Where a large number of wastes are spread (10+), it would be extremely difficult to assess all the synergistic and antagonistic chemical and physical interactions that could change the impact on the soil and crop. For example, wastes of very different pH could be spread together on one site, affecting the solubility of heavy metals in either of the wastes, which would render the analysis of the single waste stream irrelevant.

From interviews with operators, it is understood that where notifications are registered for a large number of waste streams at a single site this commonly does not reflect the actual wastes. The larger operators will have a number of waste streams from different processes, and have a „land bank‟ of a sites on which they will spread the waste. The site for application will be chosen on the basis of weather conditions, the amount of waste received (which cannot always be predicted), type of crop planted, time of year etc.

This would suggest that waste being applied at sites is commonly not tailored to the crop or soil conditions at the site in some cases. Follow-up inspection frequency is variable across different regions in the Environment Agency. The problem of effective follow-up inspections of

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exempt sites is exacerbated by the fact that there is no statutory requirement for operators to inform the Environment Agency of when the spreading of waste will take place. Although this is requested on the exemption notification form, in many cases the operator gave long time frames for spreading as exact time was dictated by weather and other factors.

Operators are required to keep records on:

Quantity

Nature

Origin

Destination

Method of recovery of the waste Due to time pressures on Environment Agency inspectors, this appears to only have been checked in a very limited number of cases. The actual waste spread will have a bearing on environmental impact of the waste, and the claimed agricultural benefit.

4.6 Agricultural Benefit vs. Ecological Improvement

The review of notifications for Paragraph 7 exemptions found that a large majority of exemptions were registered for agricultural benefit (98.7%) with just 1.3% were registered for ecological improvement. Two registrations were registered for both agricultural benefit and ecological improvement.

Of exemptions registered for ecological improvement, the following wastes were used:

Table 4.3 Wastes used for ecological improvement

LoW Code LoW description Description used on form

17 05 04 Construction and Demolition Wastes (including Excavated Soil from Contaminated Sites); soil (including excavated soil from contaminated sites), stones and dredging spoil; soil and stones other than those mentioned in 17 05 03

Topsoil; Top soil and sub soil; topsoil and subsoil; Topsoil

19 09 02 Wastes from Waste Management Facilities, Off-Site Waste Water Treatment Plants and the Preparation of Water for Human Consumption and Water for Industrial Use; wastes from the preparation of water intended for human consumption or water for industrial use; sludges from water clarification

Filter material; Sludge cake from water clarification

17 05 06 Construction and Demolition Wastes (including Excavated Soil from Contaminated Sites); soil (including excavated soil from contaminated sites), stones and dredging spoil; dredging spoil other than those mentioned in 17 05 05

Canal sediment

03 01 05 Wastes from Wood Processing and the Production of Panels and Furniture, Pulp, Paper and Cardboard; wastes from wood processing and the production of

Woodchip

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LoW Code LoW description Description used on form

panels and furniture; sawdust, shavings, cuttings, wood, particle board and veneer other than those mentioned in 03 01 04

02 06 03 Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from the baking and confectionery industry; sludges from on-site effluent treatment

Daff plant sludge

02 06 01 Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from the baking and confectionery industry; materials unsuitable for consumption or processing

Daff plant sludge

19 05 99 Wastes from Waste Management Facilities, Off-Site Waste Water Treatment Plants and the Preparation of Water for Human Consumption and Water for Industrial Use; wastes from aerobic treatment of solid wastes; wastes not otherwise specified

Compost; grass cuttings

02 02 04 Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from the preparation and processing of meat. Fish and other foods of animal origin; sludges from on-site effluent treatment

Settled Sludge

4.7 Waste currently spread under permit

As of August 2008, there were 7 sites registered in England and Wales for “Deposit of waste to land as a recovery operation”, with a cumulative licensed capacity of 3 500 000 tonnes (compared to 6 000 000 tonnes for all Paragraph 7 exemptions). This situation is used where a waste is to be spread on land, but does not meet the requirements of either the Paragraph 7 exemption or the modern regulatory position statement15.

Table 4.4 shows a summary of the seven sites which are licensed for deposit of waste to land as a recovery operation.

15 This is only for waste for recovery, as disposal of waste to land would fall under the Landfill Regulations

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Table 4.4 Summary of waste applied to land under Environmental Permits

Operator Region Licensed Annual Capacity (t)

Total waste accepted to date (t)

U G S Recovery North West - South 4999 No waste returns

Wordsworth Excavations Ltd

North East - Ridings 176000 2225 up to June 2008

Conygre Farm Midlands - Lower Trent

74999 None as new site

Associated Waste Management Limited

North East - Ridings 240000 79500 tonnes up to June 2008

Simpsons Quarries Ltd

North East - Ridings 74999 No response

Olympic Delivery Authority (North)

Thames - North East 1600000 No waste returns

Olympic Delivery Authority (South)

Thames - North East 1600000 No waste returns

All the above licenses have been issued since September 2006. As can be seen from Table 4.4 no data was available from Environment Agency systems on the amount of waste taken at 5 of the 7 sites, either because the data has not been uploaded on to the system or the waste returns have not been submitted. It should be noted that “deposit on land as a recovery operation” can cover operations other than those that would otherwise be covered by a Paragraph 7 exemption (e.g. use of waste materials for construction, covered by Paragraph 19 exemptions).

4.8 Waste Spread under modern regulatory position statement

The Environment Agency currently operates an modern regulatory position statement16 for wastes which are not in the statutory list of wastes authorised under Paragraph 7 exemptions, but which the Environment Agency considers to be of sufficiently low risk to operate under exemption style regulation. The list of wastes currently authorised for spreading to land under the modern regulatory position statement are as follows:

activated sludge from oil refinery biological effluent treatment plants;

biological effluent treatment plant sludge arising on chemical manufacturing sites;

cotton fibre waste arising from paper manufacture;

16 http://www.environment-agency.gov.uk/static/documents/Business/MWRP_001_v4_Oct_2008.pdf

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off-specification beer and lemonade;

lairage waste;

Ahlstrom liquor;

rendering plant sludge and wash waters;

effluent and wash-down water resulting from secondary food processing or the cook-chill sector;

seaweed collected by a local authority.

In order to spread these wastes, the operator must meet all the same requirements as anyone operating under the Paragraph 7 exemption, including submitting the form in the usual way.

Unfortunately, forms submitted under the modern regulatory position statement are not held centrally as with standard Paragraph 7 exemptions. The notifications are held at the local office where the application was submitted, and not in electronic format. Consequently, figures obtained on the amount of waste spread are not reliable. Table 4.5 shows the results of the survey.

Table 4.5 Summary of waste applied to land under Environmental Permits

Waste Type Number of notifications for period 01/05/07 – 30/4/08

Ahlstrom liquor 34

Biological effluent treatment plant sludge arising on chemical manufacturing sites

2

Activated sludge from oil refinery biological effluent treatment plants

-

Cotton fibre waste arising from paper manufacture -

Off-specification beer and lemonade -

Lairage waste -

Rendering plant sludge and wash waters -

Effluent and wash-down water resulting from secondary food processing or the cook-chill sector

-

Seaweed collected by a local authority -

The survey (arranged through the Environment Agency) is likely to be incomplete, and these figures should therefore be seen as minima.

4.9 Survey Results

Following analysis of the data extracted from the application forms, a survey was conducted of:

Exemption operators;

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Application Assessment Officers;

Local Area Environment Officers.

The results of this survey are details in the sections below.

4.9.1 Exemption Operators

A survey was conducted of the top 20 exemption operators (by number of sites), as shown in Table 4.6. Together these 20 operators are responsible for approximately 55% of all Paragraph 7 exempt sites.

Table 4.6 Exemption Operators

Operator Company Number of Applications in Period 1/5/07 – 30/4/08 (including renewals)

Envar Ltd 210

Darlington Group PLC 89

Summerleaze Ltd 86

Site Serv 75

Whites 65

Austin Contact Services 57

Bioganix 46

J W S Recycling 42

Coast to Coast Recycling 35

N-Virocycle 34

Envirowaste 33

4 Recycling 31

Neales Waste Management 30

Bluestar 28

Phillip Trim 26

Tillertech 23

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Operator Company Number of Applications in Period 1/5/07 – 30/4/08 (including renewals)

Shanks Waste 18

Trade Effluent Services 18

J H Willis and Son 17

D J Huxley Farms Ltd 16

A 2-page questionnaire with six questions was e-mailed to contacts from each operator (reproduced in Appendix C). This was followed up by at least one telephone call, inviting the contact to go through their response to the questionnaire over the phone.

The questionnaire was intended to produce information that would supplement that collected from the application forms. The questions asked of the operators are outlined below, together with rationale for that question where appropriate.

Question 1: Approximately what percentage of total waste applied for do you actually spread?

Operators submit notifications for the maximum amount of waste they will spread in a year. Any assessment of the impacts of the wastes spread to land would therefore be worst-case. Many operators also notify for the statutory maximum of waste allowed to be spread (250t/ha and 12500 t per site), to allow themselves flexibility should they need. This question was intended to get an understanding of how accurate this worst case of maximum total tonnages would be.

Question 2: How often do you test waste streams? Is this a regular time frequency, or based on volume of waste handled?

Guidance for Paragraph 7 notifications state that waste should be tested every 12 months or more frequently if waste streams are variable. From the review of notifications we found that waste stream analysis was rarely submitted for more than one analysis per year. For inherently variable waste streams (e.g. compost) this could have implications for supposed agricultural benefit and impact of soil and surface waters,

Question 3: How is waste sampled? Do you undertake the sampling or does the waste producer? How many samples are taken for analysis?

Guidance for Paragraph 7 exemptions states that details of sampling methodology should be provided, but gives only limited guidance on how this should be done. Consequently, the majority of notifications received did not give details of their sampling methodology. Good sampling is vital for proper characterisation of the waste stream (for example, a 1 kg sample for the top of a weathered field pile will have very different characteristics to waste in the middle).

Question 4: Do you undertake analysis beyond the minimum required for Paragraph 7 exemption notifications, and if so what? (e.g. organic pollutants).

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Very limited data was provided in notifications of organic pollutants, biodegradability and microbes. This question was intended to determine whether operators are carrying out this analysis, but not submitting the results as part of their notifications.

Question 5: Do you think the current exemption process would be improved by permitting? If so/if not, why?

Question 6: How often do you sample receiving soils where the waste is to be spread?

Guidance on Paragraph 7 notifications states that receiving soils should be sampled every 4 years, in accordance with guidance given in Defra‟s RB209 Fertiliser handbook. This frequency of testing may not be appropriate for some wastes with high PTE content, especially where good data is not available for impacts of that waste stream (e.g. wastes only recently applied to land)

Question 7: Is there any other information you think pertinent to a risk assessment for application of waste to land that is not covered above? Are there any improvements you would like to see to the current system?

Responses

From the 20 questionnaires sent out, we received 4 responses (4 operators did not want to take part in the survey, and 12 operators did not respond to e-mails and telephone calls). A summary of the responses is given below.

Table 4.7 Responses to questionnaires by operators

Question Summary of Responses

Question 1: Approximately what percentage of total waste applied for do you actually spread?

Range from 70% to 100%

Question 2: How often do you test waste streams? Is this a regular time frequency, or based on volume of waste handled?

Once a month to once per year, some dependant on size of waste stream

Question 3: How is waste sampled? Do you undertake the sampling or does the waste producer? How many samples are taken for analysis?

We found operators had good understanding of best practice sampling methodology.

Question 4: Do you undertake analysis beyond the minimum required for Paragraph 7 exemption notifications, and if so what? (e.g. organic pollutants).

Operators interviewed did not undertake any extra analysis for biodegradability or organic parameters (except some analysis for pesticides which was crop specific)

Question 5: Do you think the current exemption process would be improved by permitting? If so/if not, why?

Most thought there was enough regulation already, but would like to see greater flexibility. Some operators would welcome permitting if it ended perceived lack of

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Question Summary of Responses

consistency from Environment Agency

Question 6: How often do you sample receiving soils where the waste is to be spread?

All operators interviewed who responded to this question tested soils every 4 years.

Question 7: Is there any other information you think pertinent to a risk assessment for application of waste to land that is not covered above? Are there any improvements you would like to see to the current system?

All respondents highlighted the need for greater flexibility, in terms of pricing structure and how and where waste can be spread (i.e. once an application has been submitted cannot change the waste types/amounts without re-notifying). Some respondents would like to see a return of application assessment by local officers.

4.9.2 Application Assessment Officers

Three application assessment officers were contacted for the survey. There is very good communication between assessment officers, and therefore responses to questions were very similar. The questions asked are outlined below.

Question 1: Do you think the current system is adequate for assessing risk of waste being spread to land? If not, what other information do you think should be required? Do you think any information is requested from operators that is not relevant/ not necessary?

This question was asked

Question 2: Do you think the current system is adequate for assessing agricultural benefit/ecological improvement of waste being spread to land? If not, what other information do you think should be required?

Question 3: How often do operators provide proof of agricultural benefit conferred from previous years?

The current guidance does not ask for proof of agricultural benefit, but this is vital as part of the justification of spreading waste to land.

Question 4: Are there any specific wastes that cause particular problems? Are there any specific wastes you think confer particular agricultural benefit/ ecological improvement?

This was to get an understanding of what are the high risk/ low risk wastes from the perspective of those assessing notifications, to determine whether this correlated with those found to be high risk from the assessment of the notifications.

Question 5: Are there any improvements you would like to see to the current system?

Question 6: What is the general quality of notifications? How often do you have to go back to the operator for more information?

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WRc‟s review of notifications found that the form of notifications was confusing as there are no standards for how information should be reported. We wanted to get those who assess the notifications opinions on this.

Question 7: Do you think the current system of an application once a year is adequate/ too much/ too little?

Question 8: Is there any other information you think pertinent to a risk assessment for application of waste to land not covered above?

Responses

The responses to the questionnaire are summarised in Table 4.8.

Table 4.8 Responses to questionnaires by Application Assessment Officers

Question Summary of responses

Question 1: Do you think the current system is adequate for assessing risk of waste being spread to land? If not, what other information do you think should be required? Do you think any information is requested from operators that is not relevant/ not necessary?

General consensus that the basic suite is adequate, if supplemented by more crop/waste specific parameters. Analysis from previous years would be useful for nutrients (e.g. where phosphorus was spread previous year with only 50% availability


Heavy reliance on Defra‟s RB209 Fertiliser handbook (current version dates from 2000), which was developed for organic manures and not really waste streams. One respondent thought the current system was adequate.

Question 3: How often do operators provide proof of agricultural benefit conferred from previous years?

This is never provided by operators. Again as long as calculations from Defra‟s RB209 Fertiliser handbook show there is benefit, this is not considered relevant.


No specific issues, training highlights certain parameters to look out for on certain waste streams e.g. high TOC in compost, fats and oils content of food wastes.

Question 5: Are there any improvements you would like to see to the current system?

Currently there is no limit on the number of waste streams that can be spread on a single field, and this should be limited (or at least reflect this in the charging scheme). Also fact that renewal notifications are cheaper and do and only require basic information, but do not require less work in terms of assessment. Finding information

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on current Agency system on previous notifications is not easy.

Question 6: What is the general quality of notifications? How often do you have to go back to the operator for more information?

This was variable by operator, although in most cases more information was required of the operator after submission of the application.

Question 7: Do you think the current system of an application once a year is adequate/ too much/ too little?

Yearly notifications are based on crop cycle so for most wastes it is appropriate. A tiered approach would be welcomed here based on amount of wastes, number of types of wastes and risk.

4.9.3 Local Area local Environment Officers

Enforcement of exemption sites after the application has been made is arguably the most important part of the exemptions process. This is the responsibility of local Environment Agency area officers. Each of the 20 Environment Agency Areas has a representative for overseeing exemptions in their Area, although how this works in practice is not nationally consistent. These representatives were contacted to arrange responses. It was important to get a high response rate from the questionnaires from local officers, due to the variability between areas in terms of wastes spread, geology, rationality of operators and enforcement response.

The questionnaire was sent to 30 local contacts – however the list of contacts provided was not current and therefore a number of respondents were no longer in this role. Where possible their questionnaires were passed on to the most relevant person.

20 responses were received to the survey. The questions asked are outlined below.


Question 2: What do you look for when carrying out follow-up inspections in terms of risk/agricultural benefit of spreading?

This was to determine whether agricultural benefit is assessed in follow-up inspections, and what if any auditing of environmental impact is carried out


Information gathered from the application forms will not necessarily show what impact the waste will have in practice. Also, the assessment using basic parameters may miss wastes that pose a threat e.g. due to high salt content or extreme pH. Another factor that can only be

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considered by practical experience is smell nuisance, which we know from analysis of pollution data to be the most commonly reported incident type by the public.

Question 4: Do you think the current system of inspection once a year is adequate/ too much/ too little?

Question 5: Do you have any specific examples of spreading under Paragraph 7 causing pollution/nuisance?

Question 6: Could you estimate the percentage of Paragraph 7 sites where a follow up inspection is carried out?

Local officers are resourced to inspect each exempt site once per year. This question was intended to determine how close this reflects reality.

Question 6: Is there any other information you think pertinent to a risk assessment for application of waste to land not covered above? Are there any improvements you would like to see to the current system?

Responses

Responses to these questions are given in Table 4.9.

Table 4.9 Responses to questionnaires by Environment Officers



83% of those that responded to this question felt that the current system could be improved. Whilst many of the respondents thought the majority of waste spread under Paragraph 7 was done responsibly and with genuine agricultural benefit, there are a significant minority of sites where waste causes nuisance or pollution, and that these sites were difficult to regulate.

Question 2: What do you look for when carrying out follow-up inspections in terms of risk/agricultural benefit of spreading?

Assessment of agricultural benefit conferred by the waste during follow-up visits was carried out in a small number of cases. Many respondents reported it was hard to carry out follow-up assessments as it depended at what time in the crop cycle the inspection was carried out. Spot samples to confirm analysis reported by operators was only reported to be used in two cases.


Abattoir wastes, composts and composts mixed with plaster board (thus producing sulphide gas) were highlighted as causing problems in terms of odour, and coloured paper sludge ash was a problem in one area. Some respondents made the point that it is the cumulative impact on soils and controlled waters that may be having a long term effect. One respondent raised concerns over heavy metal content/low nutrient

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value of anaerobic digestates.

Question 4: Do you think the current system of inspection once a year is adequate/ too much/ too little?

There was a broad range in response to this question; ranging from it was more than is necessary to not nearly enough. Many felt that greater flexibility was needed to target high risk wastes.

Question 5: Do you have any specific examples of spreading under Paragraph 7 causing pollution/nuisance?

Most examples related to nuisance – either smell, noise (the exemptions do not place restrictions on times of operation).

Question 6: Could you estimate the percentage of Paragraph 7 sites where a follow up inspection is carried out?

There was large variation between areas, ranging from <5% of all sites inspected to 100% or greater (more than one inspection per site) in 5 cases. Many respondents made the point that unless they knew when the spreading was due to take place, there was little point in a follow-up inspection

Question 6: Is there any other information you think pertinent to a risk assessment for application of waste to land not covered above? Are there any improvements you would like to see to the current system?

Some respondents felt that farmers were not in control of how /when waste is spread, as it is usually spread by waste management companies.

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5. TIER 2 ASSESSMENT OF WASTE STREAM ARISINGS AND CHARACTERISTICS

Twenty waste streams were selected from the initial investigation, representing the top quartile when ranked by overall risk score. A further two wastes (from the second quartile) were also investigated further, due to relatively high waste properties scores17. The methodology for this initial risk assessment where all 76 wastes were considered can be seen in Appendix C. Each waste was considered in terms of:

Total amount spread in England and Wales

Loading rates (tonnes per hectare)

Nutrients (Phosphorus and Nitrogen)

Biodegradability

Organics content

Pathogen risk.

Each waste was given an overall score from this assessment. The wastes identified from the initial investigation are considered in more detail below in the order of risk identified from the assessment.

Although the first tier assessment was a useful exercise to highlight any wastes with potentially deleterious characteristics, the actual ordering within the top twenty wastes is open to debate, due to the fairly simplistic nature of this initial risk assessment. Indeed, the exact order of wastes has changed slightly since the initial assessment after further data cleansing.

As previously discussed, data was not available for all sites, so total tonnages are estimates. Of the 1789 Paragraph 7 exemptions registered between 01/05/07 and 30/04/08, data was collected on waste types on 1028 notifications (57.5%). Of the remaining 760 notifications, 534 were renewal notifications where this information was not available, and the remaining 224 were either because the form was missing or illegible.

For total amount of waste spread, we have estimated the total for the entire population by multiplying the number found from the sample of 1028 notifications up by a factor of 1.74 (1788/1028). This is based on the untested assumption that renewal notifications are made up of a similar selection of waste types as those for which we have data. Further work would be necessary to test this assumption, but it would appear from discussions with the Environment Agency and Operators that this is potentially valid.

17 Waste properties score was derived by a quantitative assessment of both the reported nutrient and heavy metal content of the waste, and a qualitative assessment of biodegradability, micriobial activity and organic pollutants

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5.1 Waste Protocols

A number of waste protocols are currently being developed by the Environment Agency in association with WRAP (Waste and Resource Action Programme), which will define when materials cease to be a waste. This will have an impact on waste spread under Paragraph 7 exemptions, as many of the wastes can be used in agriculture, currently spread in accordance with the Environment Agency‟s Position Statement18. The following wastes and are listed as being considered under the protocols project for agricultural use:

Anaerobic digestate.

Gypsum from waste plaster board.

Paper sludge ash (NB not Paper Sludge).

Table 5.1 gives the totals used for these wastes found in the assessment of application forms.

Table 5.1 Total spread for wastes being considered under the Waste Protocol Project

LoW Codes used Total (tonnes)

Anaerobic digestate 03 03 05, 19 06 06, 19 06 04, 19 06 99

109 545

Gypsum from waste plaster board 17 08 02, 10 13 99 1677

Paper sludge ash (NB not Paper Sludge) - 0

Paper sludge ash does not appear in the notifications assessed. This would suggest either the use of these waste streams is non-existent; they are being spread illegally without the use of an exemption (possibly due to confusion over the modern regulation position statement); or all notifications for spreading of these wastes were renewal notifications, which were not available for the assessment. It is thought likely that a combination of these factors resulted in low number of exemptions for the above wastes being picked up by the survey.

The Quality Protocol for Anerobic Digestate was recently published by the Environment Agency and WRAP19. It is not known what percentage of the total quantity currently spread to land would meet the new quality protocol.

18 The regulation of materials being considered under the Waste Protocols Project, Version 2, Environment

Agency, July 2008 http://www.environment-agency.gov.uk/static/documents/mwrp_017_2077226.pdf

19 Anerobic digestate Quality Protocol, WRAP and Environment Agency, January 2009, http://www.environment-agency.gov.uk/static/documents/Business/W524AnaerobicDigestatev4(1).pdf

http://www.environment-agency.gov.uk/static/documents/mwrp_017_2077226.pdf

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5.2 Discussion on Application Forms

5.2.1 Waste Descriptions

The LoW classification system is discussed in Section 2.1.3. Some LoW codes are used for many disparate wastes, which have little in common in terms of properties or the process in which they produced.

This is particularly apparent for „99‟ codes (in the form ** ** 99), the „wastes not otherwise specified‟ descriptions. According to the European Waste Catalogue List of Wastes 2002, these codes should be used only where no other suitable six-digit code is appropriate. In many cases it would appear that these descriptions are used as the default.

For example, under LoW code 02 02 99 (Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from the preparation and processing of meat. Fish and other foods of animal origin; wastes not otherwise specified), among the codes used are the following:

Pelt washing area liquid;

Poultry blood;

Gut contents;

Yard washings;

Washing chicken sheds.

These wastes have little in common in terms of their properties, and would require very different risk assessments. For example, washings from chicken sheds would have very high ammonia content, whereas yard washings may be only a very dilute source of nutrients.

Suggested LoW codes for these wastes are given in Table 5.2, using the Waste Thesaurus20 where relevant.

Table 5.2 Suggested LoW codes for wastes consigned as 02 02 99

LoW Code Description

Pelt washing area liquid 04 01 01 Wastes from the leather and fur industry, fleshings and lime split wastes

Poultry blood 02 02 02 or 02 01 02 Animal tissue waste

Gut contents 02 02 03 Materials unsuitable for consumption or processing

Yard washings 02 02 01 Sludges from washing and cleaning

Washing chicken sheds 02 01 01 Sludges from washing and cleaning

20 Using the List of Wastes Codes, Environment Agency, April 2006 http://www.opdems.ac.uk/_files/LOW_Guide_v1%202%20(sustainability).pdf

http://www.opdems.ac.uk/_files/LOW_Guide_v1%202%20(sustainability).pdf

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54

In the case of animal blood, 4 different codes were used in the application forms assessed.

Table 5.3 Codes used in Paragraph 7 notifications for animal blood

LoW Code LoW Description

02 02 04 Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from the preparation and processing of meat. Fish and other foods of animal origin; sludges from on-site effluent treatment

02 02 02 Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from the preparation and processing of meat. Fish and other foods of animal origin; animal tissue waste

02 02 99 Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from the preparation and processing of meat. Fish and other foods of animal origin; wastes not otherwise specified

02 02 03 Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from the preparation and processing of meat. Fish and other foods of animal origin; materials unsuitable for consumption or processing

There is clearly confusion amongst operators as to the correct waste classification code to use for their waste.

Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing (LoW Chapter 2 wastes) are by far the largest category of wastes spread to land (56%). This category of wastes is made up by a huge variety of wastes.

Table 5.4 Waste spread to land under Paragraph 7 by LoW chapter

General Process Category

Description (from List of Wastes) Total Spread (T)

% of total

2 Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing

2523092 56.4

19

Wastes from Waste Management Facilities, Off-Site Waste Water Treatment Plants and the Preparation of Water for Human Consumption and Water for Industrial Use

876920 19.6

3 Wastes from Wood Processing and the 697928 15.6

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55

General Process Category

Description (from List of Wastes) Total Spread (T)

% of total

Production of Panels and Furniture, Pulp, Paper and Cardboard

17 Construction and Demolition Wastes (including Excavated Soil from Contaminated Sites)

196532 4.4

20

Municipal Wastes (Household Waste and Similar Commercial, Industrial and Institutional Wastes) Including Separately Collected Fractions

124073 2.8

10 Waste From Thermal Processes 31423 0.70

4 Wastes from the Leather, Fur and Textile Industries

20867 0.47

12 Wastes from Shaping and Physical and Mechanical Surface Treatment of Metals and Plastics

1139 0.03

1 Wastes resulting from exploration, Mining, Quarrying, Physical and Chemical treatment of Minerals

914 0.02

7 Wastes from Organic Chemical Processes 609 0.01

5.2.2 Units

A huge variety of units were used in notifications. For example, for total P, 25 different units were used:

µg P/l; ppm P2O5; P2O5 mg/kg; P2O5 kg/m3; P2O5 % w/w wet weight; P2O5 % w/w DM; mg PO4-P/l; mg PO4/l; mg PO4/kg wet weight; mg P2O5/l; mg P2O5/kg wet weight; mg P2O5/kg DM; mg P/l; mg P/kg wet weight; mg P/kg DM; kg/tonne wet; kg/tonne dry mass; kg/tonne; kg/m3; kg/ha; kg P2O5/m

3; g/kg; % w/w wet weight; % w/w DM.

This made comparing and compiling data very difficult, and leads to unnecessary confusion for the evaluation of data. This large array of units was repeated for most parameters and makes compiling such data a difficult and time consuming task.

5.2.3 Dry matter vs. Wet weight

There is no standard governing whether waste analysis is reported as wet weight values („as received‟ analysis) or the dry matter content (after moisture has been subtracted). This information is crucial in order to combine data from different sources but is not always

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56

supplied. Liquid wastes typically have less than 12% Dry Matter content. For example, a waste has 2% DM, and a total zinc concentration stated as 1000 mg/kg. If this assumed to be wet weight, the „as received‟ concentration is 1000 mg/kg Zn. If it is as dry matter, this would make the as received concentration 20 mg/kg (1000 mg/kg * 2%), a difference of a factor of 50.

When compiling data, where it is not clear whether Dry Matter or wet weight has been used, this data has not been used in the risk assessment. This only occurred on a small number of occasions, as generally even where Dry Matter/ wet weight had been left out of the analysis, we were able to deduce this information from subsequent calculations of loading rates.

5.2.4 Outliers

Data quality checking was carried out throughout the process of extracting the data from application forms. This took the form of checks on randomly chosen notifications, and checking notifications where results were very different from the mean result for that LoW code. However, as discussed in Section 5.1, variability would be expected within an LoW code due to the large number of waste types that may be included under that code.

For certain LoW codes and parameters, higher than expected results were seen (e.g. N at greater than 250 kg/ha, heavy metals at concentrations greater than levels given in the Sludge Regulations). Where these unexpected results have occurred, they have been checked for accuracy.

5.2.5 Calculating Loading Rates

Loading rates (kg/ha) have been calculated according to the following calculation:

Application Rate (t/ha) x Concentration of Determinand (kg/t) = Loading Rate (kg/ha)

This was calculated for each individual waste spread at a given site, and then complied with other wastes in the same LoW category.

Occasionally more than one application rate was given. Where this occurs, the higher application rate was used to calculate loading rates.

5.3 Data Specifics by waste type

The following section provides data for the top twenty wastes identified from the initial risk assessment. Two additional wastes have been included due to their high waste properties score (see Appendix C). Basic information is given in each table, with a map of the U.K. showing where the waste type is spread (as discussed above, these maps are incomplete). Discussion on each waste type is also given.

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57

5.3.1 17 05 06

Risk Rank 1

LoW Code 17 05 06

No. of sites 37

LoW Description Construction and Demolition Wastes (including Excavated Soil from Contaminated Sites); soil (including excavated soil from contaminated sites), stones and dredging spoil; dredging spoil other than those mentioned in 17 05 05

Descriptions used on forms Sediment; Silt; Dredged pond sediment; Lake dredgings; Waterway dredgings/sludge; Silt stones; Chalk; Dredging soil; Canal sediment; Dredged silt

Average Loading Rate (t/ha) 602

Total Amount Spread (estimated tonnes) 238710

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58

Figure 5.1 Map showing location of registered Paragraph 7 exemptions for LoW code 17 05 06

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59

Table 5.5 Summary of waste analysis for 17 05 06

n min mean median 90th

percentile 95th

percentile max RSD

pH 21 5.86 7.52 7.75 8.2 8.2 8.2 8.53

% Dry Matter 18 4.65 36.4 38.3 51.3 55.8 57.2 36.6

Total N kg/ha 4 160 220 213 281 288 294 -28.7

Total NH3 kg/ha 8 9.04 82.2 65.2 165 171 177 79.1

Total P kg/ha 8 0.0558 121 43.7 329 420 510 147

Total K kg/ha 8 1.69 211 104 512 607 702 116

Total S kg/ha 4 147 344 268 573 633 693 69.9

Total Mg kg/ha 8 0.575 374 108 925 927 929 114

Organic C kg/ha 8 13900 58000 33200 121000 122000 124000 80.8

C:N ratio 2 26 28.5 28.5 30.5 30.8 31 12.4

Zn kg/ha 15 6.97 35.6 28.7 70 73.1 73.3 68.5

Cu kg/ha 13 1.19 5.95 5.17 10.3 12.7 15.6 70.1

Ni kg/ha 9 1.94 5.34 4.68 9.34 10.9 12.5 66.7

Pb kg/ha 15 1.33 18 13.7 48.8 52.9 61.2 112

Cd kg/ha 16 0.0116 0.209 0.0671 0.389 0.691 1.45 171

Cr kg/ha 14 0.204 4.79 2.67 10.5 11.4 12.8 89

Hg kg/ha 16 0.00745 0.1 0.0377 0.233 0.391 0.657 168

Waste spread under Paragraph 7 exemptions can be spread at a maximum rate of 250 t/ha, except in the case of sugar beet (5000 t/ha) and dredging spoil (1500 t/ha). This accounts for the much higher average application rate seen for this waste compared to other waste streams.

The higher than expected results for many parameters, given in Table 5.4, is due mainly to the very high application rates.

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5.3.2 19 09 02

Risk Rank 2

LoW Code 19 09 02

No. of sites 171

LoW Description Wastes from Waste Management Facilities, Off-Site Waste Water Treatment Plants and the Preparation of Water for Human Consumption and Water for Industrial Use; wastes from the preparation of water intended for human consumption or water for industrial use; sludges from water clarification

Descriptions used on forms Cake sludge from water clarification; Clarification sludge; De-watered sludge; Filter Cake; Filter cake from water clarification; Potable water residual silt; Potable water silt after treatment; Residual silt; Silt; Sludge cake from water clarification; Sludge from water clarification; Water treatment silt.


Total 708630

DEFRA


61


DEFRA


62


n min mean median 90th percentile

95th percentile

max RSD

pH 114 3.7 6.62 6.5 7.8 7.88 10.7 15.1

% Dry Matter 115 1 21.3 19 37.2 44.3 92.6 69.7

Total N kg/ha 100 0.00653 130 112 244 253 500 -73.3

Total NH3 kg/ha

67 0.000375 4.59 2 12.7 14.7 24.7 121

Total P kg/ha 106 0.95 50 35.9 119 120 331 108

Total K kg/ha 102 8.05E-05 21.6 12.7 50.1 56.8 126 103

Total S kg/ha 90 0.502 251 63.7 287 622 6500 338

Total Mg kg/ha 92 0.648 30.7 13.3 79.4 90 153 103

Organic C kg/ha

32 720 20500 3880 72600 98700 249000 240

C:N ratio 31 5.8 11.7 11.9 12 21.4 22 31.6

Zn kg/ha 100 0.000849 3.87 2.62 8.77 9.36 23.8 107

Cu kg/ha 100 3.05E-05 1.2 0.67 3.21 4.83 8.05 128

Ni kg/ha 100 0.000425 2.08 1.38 4.19 6.67 11.8 114

Pb kg/ha 100 2.72E-05 0.722 0.333 1.92 1.96 6.79 130

Cd kg/ha 100 7.62E-06 0.0158 0.00786 0.0306 0.0532 0.198 193

Cr kg/ha 100 0.000348 0.359 0.262 0.739 1.12 1.8 99.7

Hg kg/ha 98 6.8E-07 0.00387 0.00195 0.00625 0.0103 0.0594 193

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63

5.3.3 02 02 04

Risk Rank 3

LoW Code 02 02 04

No. of sites 225

LoW Description Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from the preparation and processing of meat. Fish and other foods of animal origin; sludges from on-site effluent treatment

Descriptions used on forms Blood washing sludge; DAF sludge; Effluent from treatment plant; Effluent Plant Sludge; Fat & water; Fish waste; Food effluent; Gut washing from abattoir/gut content; Plant Waste; Poultry processing; Preparation and processing of foods of animal origin; Site effluent sludge/blood washing/gut washing wash water; Sludge from effluent treatment plant; Sludge from on-site effluent treatment; Treatment plant waste; Wash water; Waste from foods of animal origin.



DEFRA


64


DEFRA


65



percentile 95th

percentile max RSD

pH 199 3.8 6.04 5.93 6.72 7.3 8.44 12.1

% Dry Matter 192 0.131 2.85 1.49 6.27 6.84 43.2 173

Total N kg/ha 168 0.0915 133 125 249 250 486 69

Total NH3 kg/ha 149 0.00774 58.7 61.5 111 135 216 72.9

Total P kg/ha 167 0.00336 40.4 34 118 123 166 97.3

Total K kg/ha 168 0.000025 39 23 97.6 122 185 114

Total S kg/ha 151 0.0105 19.2 15.8 43.5 49.1 72.5 85.3

Total Mg kg/ha 168 0.00025 8.14 5.24 23.3 23.5 61.1 109

Organic C kg/ha

C:N ratio 52 20.2 24.4 24.6 27.5 27.5 27.5 8.07

Zn kg/ha 163 0.000268 1.54 0.8 4.22 9.18 9.25 149

Cu kg/ha 163 5.27E-05 1.35 0.612 3.06 3.5 7.71 109

Ni kg/ha 143 0.00142 1.3 0.82 2.23 6 6 129

Pb kg/ha 127 0.000105 0.0759 0.0625 0.125 0.125 0.863 151

Cd kg/ha 122 0.000013 0.0348 0.0125 0.1 0.1 0.2 131

Cr kg/ha 126 0.000105 0.345 0.1 0.763 1 4.96 196

Hg kg/ha 96 4.04E-06 0.00447 0.000563 0.01 0.0144 0.025 141

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66

5.3.4 02 07 05

Risk Rank 4

LoW Code 02 07 05

No. of sites 50

LoW Description Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from the production of alcoholic and non-alcoholic beverages (except coffee, tea and cocoa); sludges from on-site effluent treatment

Descriptions used on forms Apple plant sludge; Effluent Plant Sludge; Filter sand and spent hops effluent; Settled sludge from the process; Sludge from on-site treatment of wastes from brewing process; Spent hops effluent;



DEFRA


67


DEFRA


68



percentile 95th

percentile max RSD

pH 42 3.94 6.55 6.8 7.8 7.8 12.3 29.3

% Dry Matter 42 0.29 3.93 3.38 7.15 7.63 18 81.4

Total N kg/ha 35 0.45 125 77 250 279 345 -97

Total NH3 kg/ha 28 1.44 28.2 11.6 60 63.9 66 92.7

Total P kg/ha 33 0.03 47.9 20.7 101 133 140 106

Total K kg/ha 33 0.12 15.5 14 27.5 34 62.5 80.1

Total S kg/ha 31 0.00157 16.9 18.7 34.3 40 50 82.1

Total Mg kg/ha 35 0.00025 32.7 5.18 95.4 106 132 140

Organic C kg/ha

C:N ratio

Zn kg/ha 32 0.0005 4.04 0.59 12.6 14 15.3 133

Cu kg/ha 29 0.00105 0.366 0.155 0.384 2.11 3.25 221

Ni kg/ha 19 0.00009 0.0358 0.017 0.072 0.2 0.2 165

Pb kg/ha 16 0.00006 0.0558 0.007 0.15 0.229 0.467 216

Cd kg/ha 11 0.000003 0.00377 0.001 0.00625 0.0151 0.024 188

Cr kg/ha 11 0.00033 0.178 0.002 0.938 0.938 0.938 212

Hg kg/ha 5 0.000975 0.0062 0.005 0.01 0.01 0.01 62

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69

5.3.5 02 06 03

Risk Rank 5

LoW Code 02 06 03

No. of sites 93

LoW Description Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from the baking and confectionery industry; sludges from on-site effluent treatment

Descriptions used on forms Bakery waste from DAF effluent plant; Batter waste; Daff plant sludge; Effluent Plant Sludge; Effluent wash down water and waste food; Sludge from on site effluent treatment of waste from baking; Sludge from onsite effluent treatment of bakery waste; Sludge from on-site treatment; Waste batter/food.



DEFRA


70


DEFRA


71



percentile 95th

percentile max RSD

pH 71 4.5 5.61 5.6 6.25 6.4 7.63 10.5

% Dry Matter 71 0.12 4.42 1.46 8.67 12.9 22.9 119

Total N kg/ha 61 0.353 74.5 42 251 278 375 139

Total NH3 kg/ha 51 0.0225 12.1 2.8 58.7 69.1 79.4 181

Total P kg/ha 58 0.0269 26.7 8.4 87.3 112 200 165

Total K kg/ha 59 0.000025 6.74 4.15 19 19 28 110

Total S kg/ha 48 0.0437 10.7 9.6 22.6 25.4 69.6 111

Total Mg kg/ha 58 0.00025 5.33 3.57 11.7 20.5 31.9 131

Organic C kg/ha

C:N ratio 25 27.3 30 27.3 32.8 34.1 36.1 10.7

Zn kg/ha 58 0.00295 0.805 0.702 1.08 5.2 5.2 166

Cu kg/ha 58 0.00383 0.504 0.251 1.83 1.83 1.83 128

Ni kg/ha 50 0.000873 0.317 0.0514 1.06 1.06 1.06 132

Pb kg/ha 39 0.000176 0.044 0.0375 0.1 0.1 0.106 101

Cd kg/ha 38 2.25E-05 0.0388 0.005 0.1 0.1 0.1 120

Cr kg/ha 39 0.00042 0.0582 0.017 0.105 0.145 0.4 132

Hg kg/ha 36 0.000084 0.00412 0.0005 0.01 0.01 0.01 112

DEFRA


72

5.3.6 02 02 99

Risk Rank 6

LoW Code 02 02 99

No. of sites 83

LoW Description Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from the preparation and processing of meat. Fish and other foods of animal origin; wastes not otherwise specified

Descriptions used on forms Abattoir washings; Foods of animal origin; Gut contents; Gut contents and lairage waste; Pelt washing area liquid; Poultry blood; Preparation and processing of food of animal origin; Wash water; Washing chicken sheds; Washings from Poultry shed; Yard washings.



DEFRA


73


DEFRA


74



percentile 95th

percentile max RSD

pH 64 4 6.72 6.8 7.77 7.8 11.2 18.8

% Dry Matter 57 0.15 6.28 0.7 18 23.2 100 227

Total N kg/ha 53 0.281 117 114 250 251 251 -74

Total NH3 kg/ha

38 0.192 56.1 46.3 161 161 162 104

Total P kg/ha 51 0.00815 27.8 10.8 48.7 68.4 253 140

Total K kg/ha 50 0.167 41.3 29 72.4 84 376 135

Total S kg/ha 39 0.03 15.2 9.75 34.4 46.3 47.5 97.4

Total Mg kg/ha 44 0.0243 6.13 2.9 14.5 34.5 37.7 155

Organic C kg/ha

C:N ratio 7 4.2 13.2 17.3 17.9 17.9 18 59

Zn kg/ha 45 0.000713 0.683 0.191 1.25 1.65 7.75 179

Cu kg/ha 45 0.000613 0.811 0.183 2 2 2.91 112

Ni kg/ha 42 0.000138 0.6 0.124 2 2 2 140

Pb kg/ha 31 0.00043 0.0603 0.0625 0.12 0.125 0.45 134

Cd kg/ha 30 0.00025 0.0144 0.0125 0.0128 0.0306 0.125 156

Cr kg/ha 32 0.00241 0.287 0.123 0.625 0.625 0.625 94.9

Hg kg/ha 24 0.000025 0.00236 0.00065 0.00402 0.0113 0.025 233

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75

5.3.7 02 02 01

Risk Rank 7

LoW Code 02 02 01

No. of sites 118

LoW Description Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from the preparation and processing of meat. Fish and other foods of animal origin; sludges from washing and cleaning

Descriptions used on forms Abattoir washdown; Animal food; Dolaf washings; Egg processing; Egg processing washings; Egg produce; Egg production; Food & drinks; Food processing; Food processor; Food production (Scotch Eggs); Food waste; Meat and egg processing; Meat processing; Poultry meat processing; Poultry processing; Preparation and processing of foods from animal processing; Preparation and processing of meat; Savoury food production; Slaughter house; Slaughtering, preparation and processing of meat; The slaughtering, preparation and processing of meat; The slaughtering, preparation and processing of poultry; Vegetarian sausage production - shower cooling of vegetarian sausages and wash water; Wash water and effluent from foods of animal origin; Wash water from preparation and processing of meat and dairy; Washing down of floor and machinery - egg production; Washing down of floor and machinery of egg waste - egg produce; Waste from preparation of meat


DEFRA


76



DEFRA


77

This waste scored highly in terms of the application of the waste, and properties. Wastes from animal origin are subject to the Animal By-products Regulations, and as such may require treatment before being spread to land.

Abattoir Wash Waters

As part of the proposed update to The Defra Fertiliser Handbook (RB209) S.R. Smith and H. Rigby, Imperial College London (2008) tested a number of wastes produced in industrial processes. Table 2.1 compares results from this trail for abattoir wash waters with the results reported on Paragraph 7 notifications.

Table 5.11 Characteristics of Abattoir Wash waters

n range average 90th percentile

RSD (%)

Imperial Average

% DM 10 0.3 – 10.6 3.5 7.5 90 0.13

pH 12 5.5 – 8.4 7.0 8.2 13 7.7

N (g/m3 wet weight)

10 0.19 – 2.9 1.3 2.9 75 1.23

P (g/m3 wet weight)

10 0.12-0.44 0.089 0.192 151 <0.01

The results show reasonable correlation with the results from the Smith and Rigby Imperial study. The main difference between the two sets of results is the dry matter content, which was found to be higher in the reported values from the Paragraph 7 application forms, which would account for the slightly higher total N and P values found as the liquid is more concentrated.. This may be due to loss of moisture during storage, or the operator wishing to concentrate the liquid to reduce transportation costs.



percentile 95th

percentile max RSD

pH 92 3.17 6.32 6.54 7.19 7.74 10.1 21.2

% Dry Matter 82 0.09 6.35 0.5 27.1 27.5 72.4 225

Total N kg/ha 73 0.037 108 79 249 250 374 -83.3

Total NH3 kg/ha

63 0.0908 45.9 20.8 98.1 210 288 133

Total P kg/ha 74 0.000506 29.8 17 60.7 136 287 172

DEFRA


78


percentile 95th

percentile max RSD

Total K kg/ha 74 0.021 28.7 21 44.9 108 376 165

Total S kg/ha 65 0.0135 17 16 25.2 50.7 52.6 78.1

Total Mg kg/ha 66 0.0029 6.6 4.75 17.7 20.3 20.5 95.2

Organic C kg/ha

C:N ratio 11 28.9 29.3 28.9 30.2 30.8 31.4 3.48

Zn kg/ha 66 0.00143 1.24 0.701 2.04 7.07 8.09 156

Cu kg/ha 66 0.000625 1.05 0.703 1.58 5.19 5.75 134

Ni kg/ha 59 0.00186 0.635 0.34 1.52 3.83 3.83 153

Pb kg/ha 56 0.0001 0.0791 0.0595 0.125 0.125 1.29 214

Cd kg/ha 58 0.00003 0.0289 0.0125 0.1 0.1 0.125 131

Cr kg/ha 58 0.0001 0.317 0.1 1.25 1.28 1.28 133

Hg kg/ha 39 0.00001 0.00252 0.000025 0.01 0.01 0.0125 153

5.3.8 17 05 04

Risk Rank 8

LoW Code 17 05 04

No. of sites 23

LoW Description Construction and Demolition Wastes (including Excavated Soil from Contaminated Sites); soil (including excavated soil from contaminated sites), stones and dredging spoil; soil and stones other than those mentioned in 17 05 03

Descriptions used on forms Excavated Soil; Soil & organic material; Top soil; Top soil and sub soil



DEFRA


79


DEFRA


80



percentile 95th

percentile max RSD

pH 5 6.9 7.87 7.4 9.08 9.39 9.7 14.3

% Dry Matter 2 4.5 46.2 46.2 79.5 83.6 87.8 128

Total N kg/ha

Total NH3 kg/ha

Total P kg/ha

Total K kg/ha

Total S kg/ha 1 571 571 571 571 571 571

Total Mg kg/ha 1 169 169 169 169 169 169

Organic C kg/ha

C:N ratio

Zn kg/ha 1 0.446 0.446 0.446 0.446 0.446 0.446

Cu kg/ha 1 0.182 0.182 0.182 0.182 0.182 0.182

Ni kg/ha 1 2.85 2.85 2.85 2.85 2.85 2.85

Pb kg/ha 1 0.135 0.135 0.135 0.135 0.135 0.135

Cd kg/ha 2 0.00135 0.667 0.667 1.2 1.27 1.33 141

Cr kg/ha 1 0.162 0.162 0.162 0.162 0.162 0.162

Hg kg/ha 2 0.000169 0.143 0.143 0.257 0.271 0.286 141

Treated excavated soil from contaminated sites and uncontaminated topsoil are two materials being considered under the Environment Agency‟s and WRAP‟s Protocol project21. This may have the effect of taking much of the waste currently spread under Paragraph 7 out of the waste legislation regime. These protocols are in early stages so it is not yet clear how much of this waste would meet the quality protocol.

21 http://www.wrap.org.uk/manufacturing/projects/waste_protocols_projects/

DEFRA


81

5.3.9 02 02 03

Risk Rank 9

LoW Code 02 02 03

No. of sites 56

LoW Description Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from the preparation and processing of meat. Fish and other foods of animal origin; materials unsuitable for consumption or processing

Descriptions used on forms Animal gut content; Belly Grass; Composted stomach contents; Gut content; Gut leftovers and washdown; Materials unsuitable for consumption or processing; Plant tissue waste (gut content); Poultry blood; Preparation and processing of foods of animal origin; Stomach contents; Treatment plant; Waste from foods of animal origin



DEFRA


82


DEFRA


83



percentile 95th

percentile max RSD

pH 34 3.6 6.12 5.32 8.16 8.51 9.72 25.7

% Dry Matter 34 0.43 11.9 7.62 22.9 31.8 74 120

Total N kg/ha 32 0.3 143 126 250 289 395 66.5

Total NH3 kg/ha

20 0.15 45.9 23.5 85 88.8 161 95.2

Total P kg/ha 33 2.75 58.3 43.3 123 164 232 90.1

Total K kg/ha 32 3.78 51 49.5 90.6 110 120 64

Total S kg/ha 25 0.937 32.2 17 44.2 54.1 331 199

Total Mg kg/ha

28 0.724 19.2 15.8 20.8 68.7 134 148

Organic C kg/ha

2 3210 4270 4270 5120 5220 5330 35

C:N ratio 3 12 15.2 16.3 17.1 17.2 17.3 18.5

Zn kg/ha 24 0.0582 2.28 1.03 6.5 6.5 6.5 106

Cu kg/ha 23 0.0121 1.16 1.36 3.5 3.5 3.5 110

Ni kg/ha 22 0.00355 2.14 1.81 5.5 5.5 5.5 105

Pb kg/ha 23 0.00128 0.0536 0.0625 0.113 0.125 0.225 97.3

Cd kg/ha 23 0.000105 0.00798 0.0125 0.0125 0.0125 0.0128 73.4

Cr kg/ha 22 0.00147 0.34 0.397 0.625 0.625 0.625 86.9

Hg kg/ha 20 2.5E-06 0.000717 0.000025 0.0024 0.00375 0.00375 167

DEFRA


84

5.3.10 02 07 01

Risk Rank 10

LoW Code 02 07 01

No. of sites 44

LoW Description Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from the production of alcoholic and non-alcoholic beverages (except coffee, tea and cocoa); wastes from washing, cleaning and mechanical reduction of raw materials

Descriptions used on forms Barrel washings; Brewing waste; Filter sludge; Filter sludge (Kieselghur); Lauterton drainings; Processing waste; Sludges derived from the production of alcoholic beverages and the washing and cleaning of plant; Washing & reduction raw materials; Washings; Washwaters; Yeast tailing



DEFRA


85


DEFRA


86



percentile 95th

percentile max RSD

pH 40 2.98 4.29 4.02 6.19 7.02 7.99 30.2

% Dry Matter 39 0.03 3.59 1.33 7 9.82 41.9 198

Total N kg/ha 38 0.0065 68.7 57.5 183 250 250 -108

Total NH3 kg/ha

20 0.0025 1.97 0.289 3.5 8.65 17.2 207

Total P kg/ha 38 0.06 6.39 5.91 14.3 15.6 32.5 108

Total K kg/ha 38 0.9 15.6 13.5 35.8 37.7 55.8 91.8

Total S kg/ha 33 0.06 6.03 4.81 10.4 15.5 25 96.2

Total Mg kg/ha 32 0.00874 5.23 3.4 8.22 17.8 29.7 135

Organic C kg/ha

1 18 18 18 18 18 18

C:N ratio 3 36.2 36.2 36.2 36.2 36.2 36.2

Zn kg/ha 27 1.77E-05 0.105 0.09 0.224 0.264 0.277 89.7

Cu kg/ha 27 0.00125 0.0557 0.0308 0.132 0.22 0.25 123

Ni kg/ha 15 0.00009 0.0245 0.0114 0.0774 0.0922 0.0972 136

Pb kg/ha 12 0.00006 0.0259 0.0027 0.0848 0.11 0.134 168

Cd kg/ha 10 2.25E-06 0.00165 0.000585 0.00315 0.00607 0.009 168

Cr kg/ha 14 6.75E-05 0.0151 0.00306 0.0508 0.0777 0.0972 194

Hg kg/ha 6 0.000006 0.000498 0.000289 0.0012 0.00135 0.0015 124

DEFRA


87

5.3.11 02 03 99

Risk Rank 11

LoW Code 02 03 99

No. of sites 57

LoW Description Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from fruit, vegetables, cereals, edible oils, cocoa, coffee, teas and tobacco preparation and processing, conserve production, yeast and yeast extraction production, molasses preparation and fermentation; wastes not otherwise specified

Descriptions used on forms Beetroot juice; Cheese Washing; Coffee grounds, De-watered cake; Fat Interceptor; Food waste; Processing waste; Shale skins and roots; Waste from fruit, veg or cereal preparation; Waste from pulping and washing; Yeasty wash water



DEFRA


88


DEFRA


89



percentile 95th

percentile max RSD

pH 50 3.48 5.47 5.18 7.38 8.42 11.2 33.4

% Dry Matter 50 0.5 14.4 4.6 63.3 63.3 71.9 142

Total N kg/ha 44 1.68 70.9 38.8 236 250 278 -117

Total NH3 kg/ha

35 0.13 34.6 20.7 68 139 246 160

Total P kg/ha 44 0.081 46.1 13 40.3 91.2 653 285

Total K kg/ha 42 1.41 30.4 30.9 35.5 71.7 152 79.4

Total S kg/ha 43 0.886 31.5 19.3 40.8 64.7 285 181

Total Mg kg/ha 44 0.073 45.1 11.3 171 286 356 206

Organic C kg/ha

2 4250 4470 4470 4640 4660 4680 6.73

C:N ratio 12 30.2 30.2 30.2 30.2 30.2 30.2

1.24E-14

Zn kg/ha 43 0.000161 0.958 0.408 1.18 4.7 8.77 170

Cu kg/ha 44 0.000122 0.788 0.503 1.7 1.7 2.04 82.8

Ni kg/ha 42 0.00156 0.326 0.246 0.77 0.77 1.15 98.2

Pb kg/ha 36 0.000262 0.0913 0.119 0.125 0.183 0.288 71.5

Cd kg/ha 35 9.72E-06 0.068 0.05 0.125 0.125 0.235 92.2

Cr kg/ha 36 0.00127 0.105 0.121 0.161 0.239 0.25 60.6

Hg kg/ha 36 0.000025 0.00723 0.00619 0.0125 0.0153 0.025 95.8

DEFRA


90

5.3.12 02 03 05

Risk Rank 12

LoW Code 02 03 05

No. of sites 248

LoW Description Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from fruit, vegetables, cereals, edible oils, cocoa, coffee, teas and tobacco preparation and processing, conserve production, yeast and yeast extraction production, molasses preparation and fermentation; sludges from on-site effluent treatment

Descriptions used on forms Centrifuge slurry; Daff plant sludge; Digested sludge; Effluent Plant Sludge; Food effluent; Fruit, vegetable or cereal production waste; Jam effluent; On site treatment sludge; Press cake from DAF treatment of cereal processing; Reactor sludge; Sludge from on-site effluent treatment; Treatment plant waste; Wash water; Waste from fruit, veg or cereal production; Waste from fruit, vegetables or cereals; Waste site effluent plant; Waste soya; Yeast effluent



DEFRA


91


DEFRA


92



percentile 95th

percentile max RSD

pH 195 3.06 5.97 6.21 7.05 7.53 9.8 20.2

% Dry Matter 191 0.05 2.1 0.62 3.33 12 48 228

Total N kg/ha 174 0.103 56.8 41.3 115 154 252 93.8

Total NH3 kg/ha 138 0.00107 14.2 7.3 41.3 49 72.2 109

Total P kg/ha 169 0.0072 12.9 6.25 23.9 51.8 103 142

Total K kg/ha 170 0.0264 23.2 19 44 64 205 104

Total S kg/ha 147 0.0101 10.2 7.5 18.6 32.1 65.4 102

Total Mg kg/ha 163 0.0073 8.52 6 14.4 29.1 88.4 126

Organic C kg/ha

3 620 2260 2320 3550 3700 3850 71.5

C:N ratio 42 4.6 24 25.4 27.9 27.9 27.9 23.5

Zn kg/ha 162 0.00127 0.605 0.5 1.47 1.56 2.55 89.4

Cu kg/ha 163 0.000777 0.845 0.392 2.08 2.22 7.6 142

Ni kg/ha 150 0.000172 0.477 0.219 1.26 1.42 1.88 109

Pb kg/ha 137 2.68E-05 0.0774 0.0625 0.125 0.147 0.55 86.4

Cd kg/ha 130 1.34E-05 0.0501 0.018 0.125 0.125 0.25 114

Cr kg/ha 141 0.000113 0.159 0.123 0.5 0.625 1.25 137

Hg kg/ha 111 0.000012 0.00551 0.0016 0.0125 0.0125 0.025 111

DEFRA


93

5.3.13 02 03 01

Risk Rank 13

LoW Code 02 03 01

No. of sites 225

LoW Description Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from fruit, vegetables, cereals, edible oils, cocoa, coffee, teas and tobacco preparation and processing, conserve production, yeast and yeast extraction production, molasses preparation and fermentation; sludges from washing, cleaning, peeling, centrifuging and separation

Descriptions used on forms Aqueous vegetable sludge; Effluent liquid; Food effluent; Food waste; Fruit washings; Grain sludge; Pea water; Peelings; Plant washings; Potato washings; Sludge from washing; Sludge from washing, cleaning, peeling, centrifuging and separation of raw materials; Vegetable sludge; Vegetable/water/oil; Wash water; Wash waters and peelings; Waste from edible oil; Waste from fruit, veg or cereal production



DEFRA


94


DEFRA


95



percentile 95th

percentile max RSD

pH 141 0.5 5.53 5.72 6.81 7.2 8.94 22.4

% Dry Matter 136 0.07 7.07 1 17 40.3 88.5 249

Total N kg/ha 113 0.0039 61.6 39.5 214 252 529 136

Total NH3 kg/ha

86 1.48E-05 10.1 2.94 17 39 123 217

Total P kg/ha 104 0.000949 12.4 4 26.4 27.9 349 284

Total K kg/ha 112 0.00882 32.3 14.1 64.4 98.6 956 288

Total S kg/ha 88 0.0253 11.1 4.5 27.5 45.5 91 153

Total Mg kg/ha 109 0.00176 10.9 5 12.3 17.8 529 464

Organic C kg/ha

C:N ratio 13 22.4 33.8 36.2 36.2 36.2 36.2 13

Zn kg/ha 105 0.00127 0.87 0.19 1.62 5.3 7.75 205

Cu kg/ha 107 0.000123 0.399 0.125 0.8 1.9 2.36 131

Ni kg/ha 106 4.61E-05 0.572 0.102 0.675 2.53 7 248

Pb kg/ha 95 3.89E-05 0.0669 0.0438 0.125 0.125 1.73 272

Cd kg/ha 92 3.6E-07 0.0149 0.0125 0.0425 0.0529 0.125 149

Cr kg/ha 93 8.03E-05 0.299 0.09 0.625 0.625 4.2 171

Hg kg/ha 76 0.000009 0.00335

8.53E-05 0.01 0.0106 0.0563 228

DEFRA


96

5.3.14 02 03 04

Risk Rank 14

LoW Code 02 03 04

No. of sites 72

LoW Description Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from fruit, vegetables, cereals, edible oils, cocoa, coffee, teas and tobacco preparation and processing, conserve production, yeast and yeast extraction production, molasses preparation and fermentation; materials unsuitable for consumption or processing

Descriptions used on forms Activated sludge; Caramel washings; Materials unsuitable for consumption; Sludge/ liquid 0-5% dry solids; Sludge/liquid 3% dry solids; Straw / Grass etc; Waste batter / food; Waste from fruit/veg/cereal preparation; Yeast



DEFRA


97


DEFRA


98



percentile 95th

percentile max RSD

pH 199 3.8 6.04 5.93 6.72 7.3 8.44 12.1

% Dry Matter 192 0.131 2.85 1.49 6.27 6.84 43.2 173

Total N kg/ha 168 0.0915 133 125 249 250 486 69

Total NH3 kg/ha 149 0.00774 58.7 61.5 111 135 216 72.9

Total P kg/ha 167 0.00336 40.4 34 118 123 166 97.3

Total K kg/ha 168 0.000025 39 23 97.6 122 185 114

Total S kg/ha 151 0.0105 19.2 15.8 43.5 49.1 72.5 85.3

Total Mg kg/ha 168 0.00025 8.14 5.24 23.3 23.5 61.1 109

Organic C kg/ha

C:N ratio 52 20.2 24.4 24.6 27.5 27.5 27.5 8.07

Zn kg/ha 163 0.000268 1.54 0.8 4.22 9.18 9.25 149

Cu kg/ha 163 5.27E-05 1.35 0.612 3.06 3.5 7.71 109

Ni kg/ha 143 0.00142 1.3 0.82 2.23 6 6 129

Pb kg/ha 127 0.000105 0.0759 0.0625 0.125 0.125 0.863 151

Cd kg/ha 122 0.000013 0.0348 0.0125 0.1 0.1 0.2 131

Cr kg/ha 126 0.000105 0.345 0.1 0.763 1 4.96 196

Hg kg/ha 96 4.04E-06 0.00447 0.000563 0.01 0.0144 0.025 141

DEFRA


99

5.3.15 Mixed sludge

Risk Rank 15

LoW Code Mixed sludge

No. of sites 25

LoW Description N/A

Descriptions used on forms Sludge from lagoon



DEFRA


100

Figure 5.15 Map showing location of registered Paragraph 7 exemptions for LoW code Mixed sludge

DEFRA


101

Table 5.20 Summary of waste analysis for Mixed sludge


percentile 95th

percentile max RSD

pH 15 5.94 6.05 6.01 6.22 6.28 6.41 2.29

% Dry Matter 15 2.26 3.66 3.98 5.13 5.23 5.23 30.6

Total N kg/ha 15 110 208 229 293 335 365 39

Total NH3 kg/ha 15 52.2 96.7 115 124 132 153 35.3

Total P kg/ha 15 11.2 22.8 25.5 28.5 36.9 55 50.3

Total K kg/ha 15 28.2 38.2 34.3 52.9 68.8 81.3 37.9

Total S kg/ha 15 23 40.9 32.5 49.7 63.9 97 44.8

Total Mg kg/ha 15 16.3 21.1 19.1 26.1 33.7 42.8 31.7

Organic C kg/ha

C:N ratio

Zn kg/ha 15 1.1 1.9 1.51 1.87 3.84 8.26 93.3

Cu kg/ha 15 0.0874 0.225 0.264 0.338 0.402 0.52 56.8

Ni kg/ha 14 0.0246 0.0527 0.0624 0.0678 0.0792 0.1 44.7

Pb kg/ha 15 0.0314 0.37 0.458 0.802 0.846 0.875 83

Cd kg/ha 15 0.00056 0.00259 0.00312 0.00409 0.00523 0.0075 75.2

Cr kg/ha 15 0.132 0.273 0.242 0.338 0.363 0.423 29.9

Hg kg/ha 15 0.0028 0.00486 0.0052 0.00599 0.00812 0.0125 50.4

DEFRA


102

5.3.16 02 07 99

Risk Rank 16

LoW Code 02 07 99

No. of sites 50

LoW Description Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from the production of alcoholic and non-alcoholic beverages (except coffee, tea and cocoa); wastes not otherwise specified

Descriptions used on forms Dursley liquid; Effluent waste from alcoholic and non-alcoholic beverages; Effluent waste from production of alcoholic beverages; Effluent waste from the production of alcoholic beverages; Effluent wastes not otherwise specified; Processing waste.



DEFRA


103


DEFRA


104



percentile 95th

percentile max RSD

pH 39 3.8 4.1 3.93 4.79 5.74 6.1 15.2

% Dry Matter 39 0.04 1.52 0.05 4.4 5.07 8.9 160

Total N kg/ha 35 0.000024 67.8 6 220 228 244 135

Total NH3 kg/ha 27 0.375 4.41 1.4 12.4 22.3 22.3 151

Total P kg/ha 34 0.000036 10.3 9 18.1 26.5 26.5 67.6

Total K kg/ha 32 0.000045 14.3 11.3 31.4 34 35.9 64

Total S kg/ha 35 0.000016 9.39 4 25.2 26.3 29 96.1

Total Mg kg/ha 35 2.04E-05 6.84 5.1 13.4 14.4 14.4 62.3

Organic C kg/ha

C:N ratio 21 26.3 29.1 29.3 29.3 29.3 29.3 2.58

Zn kg/ha 34 1.63E-06 0.341 0.397 0.508 0.723 0.723 53.8

Cu kg/ha 34 2.3E-06 0.322 0.309 0.575 0.575 0.575 75.8

Ni kg/ha 34 0.0027 0.148 0.125 0.27 0.27 0.27 77.4

Pb kg/ha 28 5E-07 0.0771 0.125 0.125 0.125 0.25 86.5

Cd kg/ha 26 5E-07 0.0818 0.125 0.125 0.125 0.25 81.7

Cr kg/ha 28 5E-07 0.0802 0.125 0.125 0.125 0.25 79.6

Hg kg/ha 26 5E-08 0.00994 0.0125 0.0125 0.0125 0.025 52.3

DEFRA


105

5.3.17 02 05 02

Risk Rank 17

LoW Code 02 05 02

No. of sites 230

LoW Description Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from the dairy products industry; sludges from on-site effluent treatment

Descriptions used on forms Biological sludge; Dairy industry waste; Effluent Plant Sludge; Effluent sludge; Final effluent 1; Milk effluent; Milk Washings; Plant washings; Settled sludges; Sludge from on-site effluent treatment; Sludge from on-site treatment of wastes from processing of dairy products; Sludge from on-site treatment of wastes from processing of dairy products; Treatment plant; Treatment plant effluent; Wastes from dairy products



DEFRA


106


DEFRA


107



percentile 95th

percentile max RSD

pH 165 3.67 5.99 5.87 6.97 7.68 9.2 18.1

% Dry Matter 162 0.13 2.07 1.4 3.68 9.05 10.8 112

Total N kg/ha 156 0.001 86 43.7 242 254 254 98.5

Total NH3 kg/ha 149 0.0025 20.2 11.4 51.8 75.1 153 140

Total P kg/ha 154 0.0341 21.6 11.8 53.3 133 146 150

Total K kg/ha 153 0.0127 20.7 6.35 51.8 128 158 164

Total S kg/ha 144 0.00643 26.6 7.01 77.5 109 543 257

Total Mg kg/ha 153 0.000112 6.67 1 14.6 40 59.3 202

Organic C kg/ha

3 14.6 14.6 14.6 14.6 14.6 14.6

C:N ratio 39 5 8.71 7.7 14.6 19.1 20 49.8

Zn kg/ha 151 6.35E-06 0.261 0.111 0.602 1.09 1.58 131

Cu kg/ha 151 3.99E-05 0.244 0.0283 0.75 1.99 2.85 235

Ni kg/ha 122 0.000012 0.202 0.0056 1 1.03 2.13 252

Pb kg/ha 121 6.35E-06 0.0256 0.00525 0.125 0.125 0.152 161

Cd kg/ha 121 2.1E-07 0.0119 0.0005 0.0125 0.125 0.125 288

Cr kg/ha 120 1.66E-05 0.0514 0.00515 0.125 0.125 0.8 253

Hg kg/ha 120 5.25E-06 0.0039 0.00125 0.0125 0.0125 0.0368 166

DEFRA


108

5.3.18 02 04 03

Risk Rank 18

LoW Code 02 04 03

No. of sites 25

LoW Description Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing; wastes from sugar processing; sludges from on-site effluent treatment

Descriptions used on forms Activated sludge; Soil and beet residues; Soil and beet residues; activated sludge; Biosludge



DEFRA


109


DEFRA


110



percentile 95th

percentile max RSD

pH 1 7.69 7.69 7.69 7.69 7.69 7.69

% Dry Matter 1 62.3 62.3 62.3 62.3 62.3 62.3

Total N kg/ha

Total NH3 kg/ha

Total P kg/ha

Total K kg/ha

Total S kg/ha

Total Mg kg/ha

Organic C kg/ha

C:N ratio

Zn kg/ha

Cu kg/ha

Ni kg/ha

Pb kg/ha

Cd kg/ha

Cr kg/ha

Hg kg/ha

N.B No data was available for missing determinands

DEFRA


111

5.3.19 19 05 99

Risk Rank 19

LoW Code 19 05 99

No. of sites 264

LoW Description Wastes from Waste Management Facilities, Off-Site Waste Water Treatment Plants and the Preparation of Water for Human Consumption and Water for Industrial Use; wastes from aerobic treatment of solid wastes; wastes not otherwise specified

Descriptions used on forms ABPR Compost; Biodegradable green and organic waste; Compost; Compost derived from segregated waste; Compost digestate; Compost leachate; Composted wood; Finished compost; Green waste; Sludge cake compost; Source segregated compost; Waste from aerobic treatment of waste



DEFRA


112


DEFRA


113



percentile 95th

percentile max RSD

pH 154 4.52 7.07 7.1 8.46 8.6 9.76 15.2

% Dry Matter 193 0.14 46.5 48.4 64.4 70.4 79.3 36

Total N kg/ha 159 0.0253 181 209 253 270 518 -52.8

Total NH3 kg/ha

74 0.012 27.4 12.1 52.3 114 244 191

Total P kg/ha 172 0.00277 27.5 20.4 48.6 74.7 258 120

Total K kg/ha 172 0.0057 87.8 71.3 149 210 894 128

Total S kg/ha 127 0.0084 62 28.6 143 214 695 154

Total Mg kg/ha 172 0.00152 41.7 18.6 79.8 113 989 220

Organic C kg/ha

23 1740 9010 5030 13600 14000 80100 177

C:N ratio 19 0.000695 13.2 12.4 16.8 21.5 24 37

Zn kg/ha 148 2.33E-05 2.33 1.7 5.36 6.56 13.9 96.5

Cu kg/ha 149 5.38E-05 0.841 0.504 2.35 3.15 4.56 117

Ni kg/ha 139 0.0005 0.322 0.224 0.715 0.992 2.14 114

Pb kg/ha 141 2.91E-05 1.97 0.546 4.34 13.8 14.2 196

Cd kg/ha 140 4.25E-07 0.00776 0.00498 0.016 0.026 0.125 170

Cr kg/ha 137 1.21E-05 0.294 0.173 0.781 0.896 1.6 109

Hg kg/ha 138 2.13E-06 0.00346 0.00137 0.00544 0.0144 0.0567 263

DEFRA


114

5.3.20 20 02 01

Risk Rank 20

LoW Code 20 02 01

No. of sites 63

LoW Description Municipal Wastes (Household Waste and Similar Commercial, Industrial and Institutional Wastes) Including Separately Collected Fractions; garden and park wastes (including cemetery waste); biodegradable waste

Descriptions used on forms Green waste compost;

Sorted Garden waste;

Biodegradable waste;

Biodegradable;

Green Waste Plant Tissue;

Twigs, leaves and wood;

Biodegradable garden and park waste;

Shredded green waste;

Composted mulch;

compost from green waste recycling;

Biodegradable waste



DEFRA


115



percentile 95th

percentile max RSD

pH 46 5.81 7.22 6.6 8.45 8.65 9.3 13

% Dry Matter 48 25.1 56 59.6 66.6 68.4 74.7 23.2

Total N kg/ha 39 21.2 233 248 346 367 498 -37.8

Total NH3 kg/ha 31 0.024 25.3 30.9 46.5 46.5 46.5 80.6

Total P kg/ha 44 0.0486 37.8 45.5 55.1 73.8 75.8 54.8

Total K kg/ha 42 12.2 144 130 258 286 291 53.3

Total S kg/ha 37 0.51 38.9 45 66.6 67.9 158 69.2

Total Mg kg/ha 43 0.114 70.8 63.5 93.9 103 787 167

Organic C kg/ha

9 2600 14200 3850 30300 57100 84000 188

C:N ratio 4 91 91 91 91 91 91

Zn kg/ha 41 0.0051 4.79 4.08 6.61 11.2 36.7 126

Cu kg/ha 41 0.0042 1.26 1.09 1.76 1.79 11.9 147

Ni kg/ha 36 0.124 0.613 0.492 0.728 2.2 2.37 84.4

Pb kg/ha 36 0.107 3.05 3.37 5.02 6.39 9.72 65.6

Cd kg/ha 36 0.000314 0.018 0.0165 0.0245 0.0417 0.1 113

Cr kg/ha 34 0.0387 0.931 0.937 1.39 1.6 7 125

Hg kg/ha 35 0.000753 0.00599 0.00797 0.0103 0.0118 0.012 59

DEFRA


116

5.3.21 19 05 03

Risk Rank 29

LoW Code 19 05 03

No. of sites 13

LoW Description Wastes from Waste Management Facilities, Off-Site Waste Water Treatment Plants and the Preparation of Water for Human Consumption and Water for Industrial Use; wastes from aerobic treatment of solid wastes; off-specification compost

Descriptions used on forms Compost;

Green waste composting



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percentile 95th

percentile max RSD

pH 10 4 6.72 7.3 7.61 7.66 7.7 17.7

% Dry Matter 10 40.6 57.5 53.3 73.3 86.6 100 30.3

Total N kg/ha 5 7.95 168 186 240 243 246 56.6

Total NH3 kg/ha 5 1.2 8.64 4.94 19.1 22.3 25.6 115

Total P kg/ha 4 31.1 62.2 65.3 84.7 85.9 87.2 41.2

Total K kg/ha 4 43 112 103 175 187 198 58.8

Total S kg/ha 2 16 61.9 61.9 98.7 103 108 105

Total Mg kg/ha 4 28.1 55.6 55.3 80.3 82 83.7 47.9

Organic C kg/ha

1 9940 9940 9940 9940 9940 9940

C:N ratio

Zn kg/ha 7 0.21 2.56 2.92 4.22 4.32 4.41 61.6

Cu kg/ha 7 0.66 2.31 1.37 4.9 4.95 5.01 78.6

Ni kg/ha 7 0.248 0.824 0.315 1.78 2.45 3.12 126

Pb kg/ha 7 0.0125 0.576 0.381 1.25 1.38 1.51 106

Cd kg/ha 7 0.00592 0.0166 0.0117 0.0294 0.0402 0.051 93.1

Cr kg/ha 7 0.051 0.344 0.292 0.632 0.639 0.645 64.7

Hg kg/ha 7 0.00108 0.00308 0.00194 0.00566 0.00609 0.00651 70.4

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5.3.22 19 06 99

Risk Rank 28

LoW Code 19 06 99

No. of sites 16

LoW Description Wastes from Waste Management Facilities, Off-Site Waste Water Treatment Plants and the Preparation of Water for Human Consumption and Water for Industrial Use; wastes from anaerobic treatment of waste; wastes not otherwise specified

Descriptions used on forms Digestate; Green waste; Digestate from biogas plant; Digestate; Green waste; Compost



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percentile 95th

percentile max RSD

pH 8 6.37 7.83 8.2 8.55 8.55 8.55 10.9

% Dry Matter 9 0.73 14.6 8.72 38.5 52 65.5 146

Total N kg/ha 9 7.77 220 248 381 460 540 77.6

Total NH3 kg/ha

7 2.6 136 178 267 329 392 104

Total P kg/ha 9 0.385 11.2 5.44 26.1 33.8 41.4 119

Total K kg/ha 9 3.24 54.1 51.3 87.4 147 207 114

Total S kg/ha 5 5.83 31.5 13 72.6 92.3 112 144

Total Mg kg/ha

8 0.18 10.8 2.76 25.3 40.8 56.3 174

Organic C kg/ha

1 40.2 40.2 40.2 40.2 40.2 40.2

C:N ratio

Zn kg/ha 6 0.0103 0.676 0.087 1.93 2.45 2.97 174

Cu kg/ha 6 0.00125 0.359 0.153 0.921 1.14 1.37 148

Ni kg/ha 3 0.000662 0.0751 0.000756 0.179 0.202 0.224 172

Pb kg/ha 3 0.00361 0.0645 0.00412 0.149 0.168 0.186 163

Cd kg/ha 3 1.23E-05 0.000354 0.000014 0.000832 0.000934 0.00104 167

Cr kg/ha 3 0.000679 0.0393 0.000776 0.0933 0.105 0.116 170

Hg kg/ha 3 1.75E-06 0.000256 0.000002 0.000611 0.000687 0.000763 172

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6. SAFE LOADING LIMITS

Compositional data has been acquired from paragraph 7 exemption application forms for wastes applied to land, for a number of determinands, including major nutrients and PTEs (potentially toxic elements). This data has been compiled and summarised for each six-digit EWC/LoW code (European Waste Catalogue/ List of Wastes Regulations), as presented in Section 5 of the report.

Legislative and code of practice limits exist for many of the determinands for which we have complied data. We have developed safe loading rates for each LoW code using the compiled data using these limits. The 250 kg/ha limit for nitrogen has been taken from that required for Nitrate Vulnerable Zones and levels of PTEs (potentially toxic elements) set by the Sewage Sludge Code of Practice22 as shown in Table 6.1.

Table 6.1 Code of Practice and Legislative Limits for PTEs and Nutrients

Determinand Limit (kg/ha)$

N 250

Zn 15

Cu 7.5

Ni 3

Pb 15

Cd 0.15

Cr 15

Hg 0.1 $ Limit for nitrogen can be averaged over two years. For PTEs limit can be averaged over 10 years

Safe loading rates have been calculated as follows:

Target Concentration (kg/ha) / Concentration of Determinand (kg/t wet weight) = Safe Loading Rate (t/ha)

The limit values were compared for both 90th percentile values and average values reported for each LoW code. The results of this exercise can be seen in Tables 6.2 and 6.3 respectively.

22 Code of Practice for Agricultural Use of Sewage Sludge, Department of the Environment, 1996 http://www.defra.gov.uk/environment/water/quality/sewage/pdf/sludge-cop.pdf

http://www.defra.gov.uk/environment/water/quality/sewage/pdf/sludge-cop.pdf

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Table 6.2 Limiting application rates based on average values

LoW Code

Total N wet

weight mg/kg

Zn wet weight mg/kg

Cu wet weight mg/kg

Ni wet weight mg/kg

Pb wet weight mg/kg

Cd wet weight mg/kg

Cr wet weight mg/kg

Hg wet weight mg/kg

Limiting application rate of waste (t/ha)

01 05 04

01 09 02 59 98 1211 141 835 345 1480 6477

02 01 03 38 235 482 474 501 456 437 877

02 01 06 57 135 662 931 8403 1948 667 4255

02 02 01 195 1374 1203 907 12160 797 1650 4393

02 02 02 1042 3856 1172 11111 150000

02 02 03 97 1321 1076 339 48864 2722 1950 7268

02 02 04 209 1597 913 503 32371 638 1803 3082

02 02 05 93 113636 937500 150000

02 02 44

02 02 99 109 2750 740 949 26638 818 1412 3564

02 03 01 366 1581 2333 1114 45534 1201 1741 3636

02 03 02 2988 3842 945 2113 27828 278 5566 1855

02 03 03 69 125 132 217 428 834 160 5025

02 03 04 440 2015 196 2194 30437 1071 9227 3122

02 03 05 422 3057 1484 1129 30000 483 2739 1869

02 03 99 227 2058 552 1145 21398 435 3391 2264

02 04 02 376 63 498 4742 617 573 3035

02 04 03 656 60 584 5080 1534 696 3210

02 04 99 103 7926 7978 1367 36758 610 1206 3745

02 05 01 671 14045 26671 14904 249538 20565 11311 3294

02 05 02 223 7253 5613 3165 90327 2286 10634 3500

02 05 09 4545 300 750 600 30000 15000 600

02 05 99 669 1757 3350 1694 144718 39933 2835 4000

02 06 01 399 10933 2620 957 26664 267 5333 1778

02 06 03 384 1962 1847 1327 36552 462 3103 2490

02 06 99 360 2564 2994 1796 16645 1057 1507 17271

02 07 01 355 13609 5906 8014 47281 13274 14915 14634

02 07 02 5208 41667 1320

02 07 03

02 07 04 201 1425 8228 6229 107514 12047 8359 3528

02 07 05 357 634 3108 11713 41234 6950 2287 2927

02 07 99 506 9284 5172 4274 43586 416 8048 2074

03 01 05 41 241 374 478 269 942 539 1146

03 03 01 329 2327 3391 1299 26877 24534 6362 3998

03 03 05 173 611 264 718 5080 1218 684 2900

03 03 11

03 03 99 182 1531 2136 1364 22727 4545 1943 37879

03 05 05

04 02 10 22 87 430 1485 4688 1500 418 826

04 02 20 37 233 415 861 3357 1395 914 1689

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LoW Code

Total N wet

weight mg/kg

Zn wet weight mg/kg

Cu wet weight mg/kg

Ni wet weight mg/kg

Pb wet weight mg/kg

Cd wet weight mg/kg

Cr wet weight mg/kg

Hg wet weight mg/kg

Limiting application rate of waste (t/ha)

07 05 12 170 5769 31250 23077 116279 30000 8451 4000

08 08 05 10870 9740 1622 93750 1299

10 10 13 503 887 755 395 2626 212 309 20101

10 13 04 864 959 2283 698 3203 306 541 17606

10 13 99 4498668 2093 2020 337 8776 10479 165 2375

12 03 99 31 1023 2029 1200 4747 949 927 15823

12 08 05

15 03 05 7653 3061

17 01 07

17 02 01

17 05 04 490 6173 158 16667 2013 2778 6426

17 05 06 204 181 519 219 668 578 493 849

17 08 02

19 05 03 47 206 120 162 873 335 259 1037

19 05 09 22 86 151 360 48 434 286 403

19 05 19 20 225 214 622 2118 1211 844 1478

19 05 99 24 151 261 269 132 646 286 921

19 06 03

19 06 04 41 3417 3333 15385 312500 50000 23438 50000

19 06 06 39

19 06 99 35 552 653 753 3357 6835 1365 7470

19 09 01 92 161 752 194 1018 80645 896 3840

19 09 02 140 304 503 143 1536 774 659 2511

19 09 05 163 478 749 167 1503 503 248 883

20 02 01 38 170 325 232 228 453 186 737

22 06 07 23 206 404

22 07 05

26 07 05

27 07 05

JH Willis Mix 140 1000 3753 6383 4382 6618 1311 2500

Mixed 102

Other 194 591 2446 4945 6000 2813 520 2000

Key: Cells coloured yellow are application rate limiting, cells coloured grey have less than 5 datapoints

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Table 6.3 Limiting application rates based on 90th Percentile Values


Total N wet

weight mg/kg

Zn wet weight mg/kg

Cu wet weight mg/kg

Ni wet weight mg/kg

Pb wet weight mg/kg

Cd wet weight mg/kg

Cr wet weight mg/kg

Hg wet weight mg/kg

Maximum application rate of waste (t/ha)

01 05 04

01 09 02 59 98 1211 141 835 345 1480 6477

02 01 03 22 99 226 274 228 232 187 430

02 01 06 34 47 275 339 3060 1005 238 2725

02 02 01 100 395 536 302 23006 300 600 2000

02 02 02 1042 3856 1172 11111 150000

02 02 03 49 577 536 136 30000 3000 1200 2439

02 02 04 86 694 490 306 29423 300 600 1000

02 02 05 54 113636 937500 150000

02 02 44

02 02 99 30 1944 141 375 30000 300 1071 2000

02 03 01 258 370 938 600 30000 300 600 2000

02 03 02 2778 3571 878 2113 16667 167 3333 1111

02 03 03 69 125 132 217 428 834 160 5025

02 03 04 164 1706 1054 1107 30000 300 6000 2000

02 03 05 201 1861 721 423 15000 150 1200 1000

02 03 99 60 701 1071 652 12304 300 1526 1203

02 04 02 376 63 498 4742 617 573 3035

02 04 03 656 60 584 5080 1534 696 3210

02 04 99 40 4434 6048 824 30000 250 652 2000

02 05 01 428 4286 8542 7692 194805 10870 5964 2000

02 05 02 110 3425 1948 740 30000 3000 6000 2000

02 05 09 4545 300 750 600 30000 15000 600

02 05 99 295 600 1500 1200 60000 30000 1200 4000

02 06 01 100 5716 1494 725 15000 150 3000 1000

02 06 03 117 577 821 568 23006 300 1788 1818

02 06 99 301 1276 1846 657 6911 381 565 17271

02 07 01 112 4065 2373 2586 31250 6522 10593 6667

02 07 02 5208 41667 1320

02 07 03

02 07 04 102 248 3289 3055 40431 15000 6565 2000

02 07 05 181 290 4934 8824 12500 3000 444 2000

02 07 99 164 6522 3261 2778 30000 300 6000 2000

03 01 05 24 161 215 177 190 684 305 333

03 03 01 219 1461 2568 855 18606 20753 6122 3997

03 03 05 93 287 162 455 3502 1187 394 2500

03 03 11

03 03 99 182 1531 2136 1364 22727 4545 1943 37879

03 05 05

04 02 10 19 79 408 593 4167 1500 314 667

04 02 20 22 113 307 424 2532 1154 612 769

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Total N wet

weight mg/kg

Zn wet weight mg/kg

Cu wet weight mg/kg

Ni wet weight mg/kg

Pb wet weight mg/kg

Cd wet weight mg/kg

Cr wet weight mg/kg

Hg wet weight mg/kg

Maximum application rate of waste (t/ha)

07 05 12 170 5769 31250 23077 116279 30000 8451 4000

08 08 05 10870 9740 1622 93750 1299

10 10 13 503 887 755 395 2626 212 309 20101

10 13 04 864 957 1583 495 2493 274 421 17337

10 13 99 4498668 2093 2020 337 8776 10479 165 2375

12 03 99 31 1023 2029 1200 4747 949 927 15823

12 08 05

15 03 05 7653 3061

17 01 07

17 02 01

17 05 04 285 6173 158 16667 1182 2778 3688

17 05 06 160 111 247 133 322 297 249 334

17 08 02

19 05 03 30 121 75 92 386 214 184 568

19 05 09 20 53 133 280 18 291 157 193

19 05 19 20 152 144 419 1427 817 569 999

19 05 99 9 96 119 140 166 267 109 698

19 06 03

19 06 04 41 3417 3333 15385 312500 50000 23438 50000

19 06 06 34

19 06 99 20 199 235 332 1913 3499 634 3254

19 09 01 92 161 752 194 1018 80645 896 3840

19 09 02 85 129 208 76 549 395 302 1450

19 09 05 163 310 486 167 974 326 161 573

20 02 01 25 113 265 161 168 328 143 514

22 06 07 23 206 404

22 07 05

26 07 05

27 07 05

JH Willis Mix 94 658 2147 4054 1963 3571 1003 2000

Mixed 102

Other 194 453 1697 3401 4286 1744 487 2000

Key: Cells coloured yellow are application rate limiting, cells coloured grey have less than 5 datapoints

The limiting determinand in each case is highlighted in yellow, and where there are less than 15 datasets available, in grey. The cells highlighted in yellow are the lowest application rate, and hence the limiting application rate for each LoW code. For example, based on 90th percentile values, the application rate of waste 20 02 01 would be limited 24.6 t/ha by nitrogen concentration. The data shows that for most wastes, the limiting determinand is the 250 kg/ha

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limit for nitrogen. For most wastes, levels of PTEs are of little concern, due to their low concentrations. As data for molybdenum, selenium, arsenic and fluoride were not available for most waste streams, this has not been included in the assessment.

As previously discussed, each LoW code contains a wide range of waste types which often exhibit very different compositional characteristics. Each waste type can be highly variable depending on its source, this variability is further compounded by the variability exhibited by a single waste from a single source. This means that the 90thpercentile and mean compositional values may not be representative of the majority of waste streams within a LoW code. This can be seen from the fact that in the majority of cases the median average (i.e. the 50th percentile) is smaller than the mean average. As an example, Figure 6.1 shows a histogram for wet weight zinc concentrations for waste streams in the 02 02 04 LoW category (wastes from the preparation and processing of meat. Fish and other foods of animal origin; sludges from on-site effluent treatment). The mean average for this LoW code is 9.3 mg/kg, but this is skewed by a small number of high results above 40 mg/kg. The majority of waste streams in this category have a zinc concentration of below the average of 9.3 mg/kg Zn.

Figure 6.1 Histogram showing zinc concentrations (wet weight mg/kg) in LoW code 02 02 04

The use of percentile or mean values to set safe loading limits is therefore likely to penalise the majority of wastes within the LoW code. WRc have therefore adopted the use of „look-up‟ tables for nitrogen and potentially toxic elements which provide the user with an opportunity to select a safe loading rate based on the actual quality characteristics exhibited by each individual waste. This provides the operator and regulator with a convenient way of assessing whether each waste is suitable for spreading to land and at what application rate.

The look-up tables are colour coded by risk of application: green for low risk (<0.75x limit value), orange for medium risk (0.75x-1x the limit value), and red if the concentration applied

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would lead to an exceedance of levels set in the Code of Practice (>1x the limit value). The table is read by looking up the wet weight concentration of the relevant determinand in the left hand column, and then looking up the intended application rate across the top row of the table. Reading this off gives the resulting loading rate in kg/ha, with the colour indicating whether this would be suitable. The loading rate will be set by the worst case parameter.

For example, Table 6.3 gives the lookup values for chromium. The table shows that at an application rate of 150 t/ha, and a chromium concentration of 50 mg/kg would result in a loading rate for chromium of 7.5 kg/ha. This cell is coloured green, as this is less than the limit value for chromium of 15 kg/ha.

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Table 6.4 Limiting application rates based on levels for chromium

Determinand: Cr kg/ha Loading Rate (kg/ha)Application

Rate of waste

(t/ha) -> 12.5 25 37.5 50 62.5 75 87.5 100 112.5 125 137.5 150 162.5 175 187.5 200 212.5 225 237.5 250

10 0.125 0.25 0.375 0.5 0.625 0.75 0.875 1 1.13 1.25 1.38 1.5 1.63 1.75 1.88 2 2.13 2.25 2.38 2.5

20 0.25 0.5 0.75 1 1.25 1.5 1.75 2 2.25 2.5 2.75 3 3.25 3.5 3.75 4 4.25 4.5 4.75 5

30 0.375 0.75 1.13 1.5 1.88 2.25 2.63 3 3.38 3.75 4.13 4.5 4.88 5.25 5.63 6 6.38 6.75 7.13 7.5

40 0.5 1 1.5 2 2.5 3 3.5 4 4.5 5 5.5 6 6.5 7 7.5 8 8.5 9 9.5 10

50 0.625 1.25 1.88 2.5 3.13 3.75 4.38 5 5.63 6.25 6.88 7.5 8.13 8.75 9.38 10 10.6 11.3 11.9 12.5

60 0.75 1.5 2.25 3 3.75 4.5 5.25 6 6.75 7.5 8.25 9 9.75 10.5 11.3 12 12.8 13.5 14.3 15

70 0.875 1.75 2.63 3.5 4.38 5.25 6.13 7 7.88 8.75 9.63 10.5 11.4 12.3 13.1 14 14.9 15.8 16.6 17.5

80 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

90 1.13 2.25 3.38 4.5 5.63 6.75 7.88 9 10.1 11.3 12.4 13.5 14.6 15.8 16.9 18 19.1 20.3 21.4 22.5

100 1.25 2.5 3.75 5 6.25 7.5 8.75 10 11.3 12.5 13.8 15 16.3 17.5 18.8 20 21.3 22.5 23.8 25

110 1.38 2.75 4.13 5.5 6.88 8.25 9.63 11 12.4 13.8 15.1 16.5 17.9 19.3 20.6 22 23.4 24.8 26.1 27.5

120 1.5 3 4.5 6 7.5 9 10.5 12 13.5 15 16.5 18 19.5 21 22.5 24 25.5 27 28.5 30

130 1.63 3.25 4.88 6.5 8.13 9.75 11.4 13 14.6 16.3 17.9 19.5 21.1 22.8 24.4 26 27.6 29.3 30.9 32.5

140 1.75 3.5 5.25 7 8.75 10.5 12.3 14 15.8 17.5 19.3 21 22.8 24.5 26.3 28 29.8 31.5 33.3 35

150 1.88 3.75 5.63 7.5 9.38 11.3 13.1 15 16.9 18.8 20.6 22.5 24.4 26.3 28.1 30 31.9 33.8 35.6 37.5

160 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40

170 2.13 4.25 6.38 8.5 10.6 12.8 14.9 17 19.1 21.3 23.4 25.5 27.6 29.8 31.9 34 36.1 38.3 40.4 42.5

180 2.25 4.5 6.75 9 11.3 13.5 15.8 18 20.3 22.5 24.8 27 29.3 31.5 33.8 36 38.3 40.5 42.8 45

190 2.38 4.75 7.13 9.5 11.9 14.3 16.6 19 21.4 23.8 26.1 28.5 30.9 33.3 35.6 38 40.4 42.8 45.1 47.5

200 2.5 5 7.5 10 12.5 15 17.5 20 22.5 25 27.5 30 32.5 35 37.5 40 42.5 45 47.5 50

Application Rate

>Stat limit

>0.75 Stat limit< Stat limit

Co

nc

en

tra

tio

n o

f d

ete

rmin

an

d (

mg

/kg

)

Target

Concentration 15

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Table 6.5 Limiting application rates based on average values for lead

Determinand: Pb kg/ha Loading Rate (kg/ha)Application

Rate of waste

(t/ha) -> 12.5 25 37.5 50 62.5 75 87.5 100 112.5 125 137.5 150 162.5 175 187.5 200 212.5 225 237.5 250

10 0.125 0.25 0.375 0.5 0.625 0.75 0.875 1 1.13 1.25 1.38 1.5 1.63 1.75 1.88 2 2.13 2.25 2.38 2.5

20 0.25 0.5 0.75 1 1.25 1.5 1.75 2 2.25 2.5 2.75 3 3.25 3.5 3.75 4 4.25 4.5 4.75 5

30 0.375 0.75 1.13 1.5 1.88 2.25 2.63 3 3.38 3.75 4.13 4.5 4.88 5.25 5.63 6 6.38 6.75 7.13 7.5

40 0.5 1 1.5 2 2.5 3 3.5 4 4.5 5 5.5 6 6.5 7 7.5 8 8.5 9 9.5 10

50 0.625 1.25 1.88 2.5 3.13 3.75 4.38 5 5.63 6.25 6.88 7.5 8.13 8.75 9.38 10 10.6 11.3 11.9 12.5

60 0.75 1.5 2.25 3 3.75 4.5 5.25 6 6.75 7.5 8.25 9 9.75 10.5 11.3 12 12.8 13.5 14.3 15

70 0.875 1.75 2.63 3.5 4.38 5.25 6.13 7 7.88 8.75 9.63 10.5 11.4 12.3 13.1 14 14.9 15.8 16.6 17.5

80 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

90 1.13 2.25 3.38 4.5 5.63 6.75 7.88 9 10.1 11.3 12.4 13.5 14.6 15.8 16.9 18 19.1 20.3 21.4 22.5

100 1.25 2.5 3.75 5 6.25 7.5 8.75 10 11.3 12.5 13.8 15 16.3 17.5 18.8 20 21.3 22.5 23.8 25

110 1.38 2.75 4.13 5.5 6.88 8.25 9.63 11 12.4 13.8 15.1 16.5 17.9 19.3 20.6 22 23.4 24.8 26.1 27.5

120 1.5 3 4.5 6 7.5 9 10.5 12 13.5 15 16.5 18 19.5 21 22.5 24 25.5 27 28.5 30

130 1.63 3.25 4.88 6.5 8.13 9.75 11.4 13 14.6 16.3 17.9 19.5 21.1 22.8 24.4 26 27.6 29.3 30.9 32.5

140 1.75 3.5 5.25 7 8.75 10.5 12.3 14 15.8 17.5 19.3 21 22.8 24.5 26.3 28 29.8 31.5 33.3 35

150 1.88 3.75 5.63 7.5 9.38 11.3 13.1 15 16.9 18.8 20.6 22.5 24.4 26.3 28.1 30 31.9 33.8 35.6 37.5

160 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40

170 2.13 4.25 6.38 8.5 10.6 12.8 14.9 17 19.1 21.3 23.4 25.5 27.6 29.8 31.9 34 36.1 38.3 40.4 42.5

180 2.25 4.5 6.75 9 11.3 13.5 15.8 18 20.3 22.5 24.8 27 29.3 31.5 33.8 36 38.3 40.5 42.8 45

190 2.38 4.75 7.13 9.5 11.9 14.3 16.6 19 21.4 23.8 26.1 28.5 30.9 33.3 35.6 38 40.4 42.8 45.1 47.5

200 2.5 5 7.5 10 12.5 15 17.5 20 22.5 25 27.5 30 32.5 35 37.5 40 42.5 45 47.5 50

Application Rate

>Stat limit


Co

nc

en

tra

tio

n o

f d

ete

rmin

an

d (

mg

/kg

)

Target

Concentration 15

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Table 6.6 Limiting application rates based on average values for zinc

Determinand: Zn kg/ha Loading Rate (kg/ha)Application

Rate of waste

(t/ha) -> 12.5 25 37.5 50 62.5 75 87.5 100 112.5 125 137.5 150 162.5 175 187.5 200 212.5 225 237.5 250

10 0.125 0.25 0.375 0.5 0.625 0.75 0.875 1 1.13 1.25 1.38 1.5 1.63 1.75 1.88 2 2.13 2.25 2.38 2.5

20 0.25 0.5 0.75 1 1.25 1.5 1.75 2 2.25 2.5 2.75 3 3.25 3.5 3.75 4 4.25 4.5 4.75 5

30 0.375 0.75 1.13 1.5 1.88 2.25 2.63 3 3.38 3.75 4.13 4.5 4.88 5.25 5.63 6 6.38 6.75 7.13 7.5

40 0.5 1 1.5 2 2.5 3 3.5 4 4.5 5 5.5 6 6.5 7 7.5 8 8.5 9 9.5 10

50 0.625 1.25 1.88 2.5 3.13 3.75 4.38 5 5.63 6.25 6.88 7.5 8.13 8.75 9.38 10 10.6 11.3 11.9 12.5

60 0.75 1.5 2.25 3 3.75 4.5 5.25 6 6.75 7.5 8.25 9 9.75 10.5 11.3 12 12.8 13.5 14.3 15

70 0.875 1.75 2.63 3.5 4.38 5.25 6.13 7 7.88 8.75 9.63 10.5 11.4 12.3 13.1 14 14.9 15.8 16.6 17.5

80 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

90 1.13 2.25 3.38 4.5 5.63 6.75 7.88 9 10.1 11.3 12.4 13.5 14.6 15.8 16.9 18 19.1 20.3 21.4 22.5

100 1.25 2.5 3.75 5 6.25 7.5 8.75 10 11.3 12.5 13.8 15 16.3 17.5 18.8 20 21.3 22.5 23.8 25

110 1.38 2.75 4.13 5.5 6.88 8.25 9.63 11 12.4 13.8 15.1 16.5 17.9 19.3 20.6 22 23.4 24.8 26.1 27.5

120 1.5 3 4.5 6 7.5 9 10.5 12 13.5 15 16.5 18 19.5 21 22.5 24 25.5 27 28.5 30

130 1.63 3.25 4.88 6.5 8.13 9.75 11.4 13 14.6 16.3 17.9 19.5 21.1 22.8 24.4 26 27.6 29.3 30.9 32.5

140 1.75 3.5 5.25 7 8.75 10.5 12.3 14 15.8 17.5 19.3 21 22.8 24.5 26.3 28 29.8 31.5 33.3 35

150 1.88 3.75 5.63 7.5 9.38 11.3 13.1 15 16.9 18.8 20.6 22.5 24.4 26.3 28.1 30 31.9 33.8 35.6 37.5

160 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40

170 2.13 4.25 6.38 8.5 10.6 12.8 14.9 17 19.1 21.3 23.4 25.5 27.6 29.8 31.9 34 36.1 38.3 40.4 42.5

180 2.25 4.5 6.75 9 11.3 13.5 15.8 18 20.3 22.5 24.8 27 29.3 31.5 33.8 36 38.3 40.5 42.8 45

190 2.38 4.75 7.13 9.5 11.9 14.3 16.6 19 21.4 23.8 26.1 28.5 30.9 33.3 35.6 38 40.4 42.8 45.1 47.5

200 2.5 5 7.5 10 12.5 15 17.5 20 22.5 25 27.5 30 32.5 35 37.5 40 42.5 45 47.5 50

Application Rate

>Stat limit


Co

ncen

trati

on

of

dete

rmin

an

d (

mg

/kg

)

Target

Concentration 15

DEFRA


131

Table 6.7 Limiting application rates based on average values for cadmium

Determinand: Cd kg/ha Loading Rate (kg/ha)Application

Rate of waste

(t/ha) -> 12.5 25 37.5 50 62.5 75 87.5 100 112.5 125 137.5 150 162.5 175 187.5 200 212.5 225 237.5 250

0.1 0.001 0.003 0.004 0.005 0.006 0.008 0.009 0.01 0.011 0.013 0.014 0.015 0.016 0.018 0.019 0.02 0.021 0.023 0.024 0.025

0.2 0.003 0.005 0.008 0.01 0.013 0.015 0.018 0.02 0.023 0.025 0.028 0.03 0.033 0.035 0.038 0.04 0.043 0.045 0.048 0.05

0.3 0.004 0.008 0.011 0.015 0.019 0.023 0.026 0.03 0.034 0.038 0.041 0.045 0.049 0.053 0.056 0.06 0.064 0.068 0.071 0.075

0.4 0.005 0.01 0.015 0.02 0.025 0.03 0.035 0.04 0.045 0.05 0.055 0.06 0.065 0.07 0.075 0.08 0.085 0.09 0.095 0.1

0.5 0.006 0.013 0.019 0.025 0.031 0.038 0.044 0.05 0.056 0.063 0.069 0.075 0.081 0.088 0.094 0.1 0.106 0.113 0.119 0.125

0.6 0.008 0.015 0.023 0.03 0.038 0.045 0.053 0.06 0.068 0.075 0.083 0.09 0.098 0.105 0.113 0.12 0.128 0.135 0.143 0.15

0.7 0.009 0.018 0.026 0.035 0.044 0.053 0.061 0.07 0.079 0.088 0.096 0.105 0.114 0.123 0.131 0.14 0.149 0.158 0.166 0.175

0.8 0.01 0.02 0.03 0.04 0.05 0.06 0.07 0.08 0.09 0.1 0.11 0.12 0.13 0.14 0.15 0.16 0.17 0.18 0.19 0.2

0.9 0.011 0.023 0.034 0.045 0.056 0.068 0.079 0.09 0.101 0.113 0.124 0.135 0.146 0.158 0.169 0.18 0.191 0.203 0.214 0.225

1 0.013 0.025 0.038 0.05 0.063 0.075 0.088 0.1 0.113 0.125 0.138 0.15 0.163 0.175 0.188 0.2 0.213 0.225 0.238 0.25

1.1 0.014 0.028 0.041 0.055 0.069 0.083 0.096 0.11 0.124 0.138 0.151 0.165 0.179 0.193 0.206 0.22 0.234 0.248 0.261 0.275

1.2 0.015 0.03 0.045 0.06 0.075 0.09 0.105 0.12 0.135 0.15 0.165 0.18 0.195 0.21 0.225 0.24 0.255 0.27 0.285 0.3

1.3 0.016 0.033 0.049 0.065 0.081 0.098 0.114 0.13 0.146 0.163 0.179 0.195 0.211 0.228 0.244 0.26 0.276 0.293 0.309 0.325

1.4 0.018 0.035 0.053 0.07 0.088 0.105 0.123 0.14 0.158 0.175 0.193 0.21 0.228 0.245 0.263 0.28 0.298 0.315 0.333 0.35

1.5 0.019 0.038 0.056 0.075 0.094 0.113 0.131 0.15 0.169 0.188 0.206 0.225 0.244 0.263 0.281 0.3 0.319 0.338 0.356 0.375

1.6 0.02 0.04 0.06 0.08 0.1 0.12 0.14 0.16 0.18 0.2 0.22 0.24 0.26 0.28 0.3 0.32 0.34 0.36 0.38 0.4

1.7 0.021 0.043 0.064 0.085 0.106 0.128 0.149 0.17 0.191 0.213 0.234 0.255 0.276 0.298 0.319 0.34 0.361 0.383 0.404 0.425

1.8 0.023 0.045 0.068 0.09 0.113 0.135 0.158 0.18 0.203 0.225 0.248 0.27 0.293 0.315 0.338 0.36 0.383 0.405 0.428 0.45

1.9 0.024 0.048 0.071 0.095 0.119 0.143 0.166 0.19 0.214 0.238 0.261 0.285 0.309 0.333 0.356 0.38 0.404 0.428 0.451 0.475

2 0.025 0.05 0.075 0.1 0.125 0.15 0.175 0.2 0.225 0.25 0.275 0.3 0.325 0.35 0.375 0.4 0.425 0.45 0.475 0.5

Application Rate

>Stat limit


Co

ncen

trati

on

of

dete

rmin

an

d (

mg

/kg

)

Target

Concentration 0.15

DEFRA


132

Table 6.8 Limiting application rates based on average values for mercury

Determinand: Hg kg/ha Loading Rate (kg/ha)Application

Rate of waste

(t/ha) -> 12.5 25 37.5 50 62.5 75 87.5 100 112.5 125 137.5 150 162.5 175 187.5 200 212.5 225 237.5 250

0.1 0.001 0.003 0.004 0.005 0.006 0.008 0.009 0.01 0.011 0.013 0.014 0.015 0.016 0.018 0.019 0.02 0.021 0.023 0.024 0.025

0.2 0.003 0.005 0.008 0.01 0.013 0.015 0.018 0.02 0.023 0.025 0.028 0.03 0.033 0.035 0.038 0.04 0.043 0.045 0.048 0.05

0.3 0.004 0.008 0.011 0.015 0.019 0.023 0.026 0.03 0.034 0.038 0.041 0.045 0.049 0.053 0.056 0.06 0.064 0.068 0.071 0.075

0.4 0.005 0.01 0.015 0.02 0.025 0.03 0.035 0.04 0.045 0.05 0.055 0.06 0.065 0.07 0.075 0.08 0.085 0.09 0.095 0.1

0.5 0.006 0.013 0.019 0.025 0.031 0.038 0.044 0.05 0.056 0.063 0.069 0.075 0.081 0.088 0.094 0.1 0.106 0.113 0.119 0.125

0.6 0.008 0.015 0.023 0.03 0.038 0.045 0.053 0.06 0.068 0.075 0.083 0.09 0.098 0.105 0.113 0.12 0.128 0.135 0.143 0.15

0.7 0.009 0.018 0.026 0.035 0.044 0.053 0.061 0.07 0.079 0.088 0.096 0.105 0.114 0.123 0.131 0.14 0.149 0.158 0.166 0.175

0.8 0.01 0.02 0.03 0.04 0.05 0.06 0.07 0.08 0.09 0.1 0.11 0.12 0.13 0.14 0.15 0.16 0.17 0.18 0.19 0.2

0.9 0.011 0.023 0.034 0.045 0.056 0.068 0.079 0.09 0.101 0.113 0.124 0.135 0.146 0.158 0.169 0.18 0.191 0.203 0.214 0.225

1 0.013 0.025 0.038 0.05 0.063 0.075 0.088 0.1 0.113 0.125 0.138 0.15 0.163 0.175 0.188 0.2 0.213 0.225 0.238 0.25

1.1 0.014 0.028 0.041 0.055 0.069 0.083 0.096 0.11 0.124 0.138 0.151 0.165 0.179 0.193 0.206 0.22 0.234 0.248 0.261 0.275

1.2 0.015 0.03 0.045 0.06 0.075 0.09 0.105 0.12 0.135 0.15 0.165 0.18 0.195 0.21 0.225 0.24 0.255 0.27 0.285 0.3

1.3 0.016 0.033 0.049 0.065 0.081 0.098 0.114 0.13 0.146 0.163 0.179 0.195 0.211 0.228 0.244 0.26 0.276 0.293 0.309 0.325

1.4 0.018 0.035 0.053 0.07 0.088 0.105 0.123 0.14 0.158 0.175 0.193 0.21 0.228 0.245 0.263 0.28 0.298 0.315 0.333 0.35

1.5 0.019 0.038 0.056 0.075 0.094 0.113 0.131 0.15 0.169 0.188 0.206 0.225 0.244 0.263 0.281 0.3 0.319 0.338 0.356 0.375

1.6 0.02 0.04 0.06 0.08 0.1 0.12 0.14 0.16 0.18 0.2 0.22 0.24 0.26 0.28 0.3 0.32 0.34 0.36 0.38 0.4

1.7 0.021 0.043 0.064 0.085 0.106 0.128 0.149 0.17 0.191 0.213 0.234 0.255 0.276 0.298 0.319 0.34 0.361 0.383 0.404 0.425

1.8 0.023 0.045 0.068 0.09 0.113 0.135 0.158 0.18 0.203 0.225 0.248 0.27 0.293 0.315 0.338 0.36 0.383 0.405 0.428 0.45

1.9 0.024 0.048 0.071 0.095 0.119 0.143 0.166 0.19 0.214 0.238 0.261 0.285 0.309 0.333 0.356 0.38 0.404 0.428 0.451 0.475

2 0.025 0.05 0.075 0.1 0.125 0.15 0.175 0.2 0.225 0.25 0.275 0.3 0.325 0.35 0.375 0.4 0.425 0.45 0.475 0.5

Application Rate

>Stat limit


Co

nc

en

tra

tio

n o

f d

ete

rmin

an

d (

mg

/kg

)

Target

Concentration 0.1

DEFRA


133

Table 6.9 Limiting application rates based on average values for nitrogen

Determinand: N kg/ha Loading Rate (kg/ha)Application

Rate of waste

(t/ha) -> 12.5 25 37.5 50 62.5 75 87.5 100 112.5 125 137.5 150 162.5 175 187.5 200 212.5 225 237.5 250

500 6.25 12.5 18.8 25 31.3 37.5 43.8 50 56.3 62.5 68.8 75 81.3 87.5 93.8 100 106 113 119 125

1000 12.5 25 37.5 50 62.5 75 87.5 100 113 125 138 150 163 175 188 200 213 225 238 250

1500 18.8 37.5 56.3 75 93.8 113 131 150 169 188 206 225 244 263 281 300 319 338 356 375

2000 25 50 75 100 125 150 175 200 225 250 275 300 325 350 375 400 425 450 475 500

2500 31.3 62.5 93.8 125 156 188 219 250 281 313 344 375 406 438 469 500 531 563 594 625

3000 37.5 75 113 150 188 225 263 300 338 375 413 450 488 525 563 600 638 675 713 750

3500 43.8 87.5 131 175 219 263 306 350 394 438 481 525 569 613 656 700 744 788 831 875

4000 50 100 150 200 250 300 350 400 450 500 550 600 650 700 750 800 850 900 950 1000

4500 56.3 113 169 225 281 338 394 450 506 563 619 675 731 788 844 900 956 1010 1070 1130

5000 62.5 125 188 250 313 375 438 500 563 625 688 750 813 875 938 1000 1060 1130 1190 1250

5500 68.8 138 206 275 344 413 481 550 619 688 756 825 894 963 1030 1100 1170 1240 1310 1380

6000 75 150 225 300 375 450 525 600 675 750 825 900 975 1050 1130 1200 1280 1350 1430 1500

6500 81.3 163 244 325 406 488 569 650 731 813 894 975 1060 1140 1220 1300 1380 1460 1540 1630

7000 87.5 175 263 350 438 525 613 700 788 875 963 1050 1140 1230 1310 1400 1490 1580 1660 1750

7500 93.8 188 281 375 469 563 656 750 844 938 1030 1130 1220 1310 1410 1500 1590 1690 1780 1880

8000 100 200 300 400 500 600 700 800 900 1000 1100 1200 1300 1400 1500 1600 1700 1800 1900 2000

8500 106 213 319 425 531 638 744 850 956 1060 1170 1280 1380 1490 1590 1700 1810 1910 2020 2130

9000 113 225 338 450 563 675 788 900 1010 1130 1240 1350 1460 1580 1690 1800 1910 2030 2140 2250

9500 119 238 356 475 594 713 831 950 1070 1190 1310 1430 1540 1660 1780 1900 2020 2140 2260 2380

10000 125 250 375 500 625 750 875 1000 1130 1250 1380 1500 1630 1750 1880 2000 2130 2250 2380 2500

Application Rate

>Stat limit


Co

nc

en

tra

tio

n o

f d

ete

rmin

an

d (

mg

/kg

)

Target

Concentration 250

DEFRA


134

Table 6.10 Limiting application rates based on average values for copper

Determinand: Cu kg/ha Loading Rate (kg/ha)Application

Rate of waste

(t/ha) -> 12.5 25 37.5 50 62.5 75 87.5 100 112.5 125 137.5 150 162.5 175 187.5 200 212.5 225 237.5 250

10 0.125 0.25 0.375 0.5 0.625 0.75 0.875 1 1.13 1.25 1.38 1.5 1.63 1.75 1.88 2 2.13 2.25 2.38 2.5

20 0.25 0.5 0.75 1 1.25 1.5 1.75 2 2.25 2.5 2.75 3 3.25 3.5 3.75 4 4.25 4.5 4.75 5

30 0.375 0.75 1.13 1.5 1.88 2.25 2.63 3 3.38 3.75 4.13 4.5 4.88 5.25 5.63 6 6.38 6.75 7.13 7.5

40 0.5 1 1.5 2 2.5 3 3.5 4 4.5 5 5.5 6 6.5 7 7.5 8 8.5 9 9.5 10

50 0.625 1.25 1.88 2.5 3.13 3.75 4.38 5 5.63 6.25 6.88 7.5 8.13 8.75 9.38 10 10.6 11.3 11.9 12.5

60 0.75 1.5 2.25 3 3.75 4.5 5.25 6 6.75 7.5 8.25 9 9.75 10.5 11.3 12 12.8 13.5 14.3 15

70 0.875 1.75 2.63 3.5 4.38 5.25 6.13 7 7.88 8.75 9.63 10.5 11.4 12.3 13.1 14 14.9 15.8 16.6 17.5

80 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

90 1.13 2.25 3.38 4.5 5.63 6.75 7.88 9 10.1 11.3 12.4 13.5 14.6 15.8 16.9 18 19.1 20.3 21.4 22.5

100 1.25 2.5 3.75 5 6.25 7.5 8.75 10 11.3 12.5 13.8 15 16.3 17.5 18.8 20 21.3 22.5 23.8 25

110 1.38 2.75 4.13 5.5 6.88 8.25 9.63 11 12.4 13.8 15.1 16.5 17.9 19.3 20.6 22 23.4 24.8 26.1 27.5

120 1.5 3 4.5 6 7.5 9 10.5 12 13.5 15 16.5 18 19.5 21 22.5 24 25.5 27 28.5 30

130 1.63 3.25 4.88 6.5 8.13 9.75 11.4 13 14.6 16.3 17.9 19.5 21.1 22.8 24.4 26 27.6 29.3 30.9 32.5

140 1.75 3.5 5.25 7 8.75 10.5 12.3 14 15.8 17.5 19.3 21 22.8 24.5 26.3 28 29.8 31.5 33.3 35

150 1.88 3.75 5.63 7.5 9.38 11.3 13.1 15 16.9 18.8 20.6 22.5 24.4 26.3 28.1 30 31.9 33.8 35.6 37.5

160 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40

170 2.13 4.25 6.38 8.5 10.6 12.8 14.9 17 19.1 21.3 23.4 25.5 27.6 29.8 31.9 34 36.1 38.3 40.4 42.5

180 2.25 4.5 6.75 9 11.3 13.5 15.8 18 20.3 22.5 24.8 27 29.3 31.5 33.8 36 38.3 40.5 42.8 45

190 2.38 4.75 7.13 9.5 11.9 14.3 16.6 19 21.4 23.8 26.1 28.5 30.9 33.3 35.6 38 40.4 42.8 45.1 47.5

200 2.5 5 7.5 10 12.5 15 17.5 20 22.5 25 27.5 30 32.5 35 37.5 40 42.5 45 47.5 50

Application Rate

>Stat limit


Co

ncen

trati

on

of

dete

rmin

an

d (

mg

/kg

)

Target

Concentration 7.5

DEFRA


135

Table 6.11 Limiting application rates based on average values for molybdenum

Determinand: Mo kg/ha Loading Rate (kg/ha)Application

Rate of waste

(t/ha) -> 12.5 25 37.5 50 62.5 75 87.5 100 112.5 125 137.5 150 162.5 175 187.5 200 212.5 225 237.5 250

0.2 0.003 0.005 0.008 0.01 0.013 0.015 0.018 0.02 0.023 0.025 0.028 0.03 0.033 0.035 0.038 0.04 0.043 0.045 0.048 0.05

0.4 0.005 0.01 0.015 0.02 0.025 0.03 0.035 0.04 0.045 0.05 0.055 0.06 0.065 0.07 0.075 0.08 0.085 0.09 0.095 0.1

0.6 0.008 0.015 0.023 0.03 0.038 0.045 0.053 0.06 0.068 0.075 0.083 0.09 0.098 0.105 0.113 0.12 0.128 0.135 0.143 0.15

0.8 0.01 0.02 0.03 0.04 0.05 0.06 0.07 0.08 0.09 0.1 0.11 0.12 0.13 0.14 0.15 0.16 0.17 0.18 0.19 0.2

1 0.013 0.025 0.038 0.05 0.063 0.075 0.088 0.1 0.113 0.125 0.138 0.15 0.163 0.175 0.188 0.2 0.213 0.225 0.238 0.25

1.2 0.015 0.03 0.045 0.06 0.075 0.09 0.105 0.12 0.135 0.15 0.165 0.18 0.195 0.21 0.225 0.24 0.255 0.27 0.285 0.3

1.4 0.018 0.035 0.053 0.07 0.088 0.105 0.123 0.14 0.158 0.175 0.193 0.21 0.228 0.245 0.263 0.28 0.298 0.315 0.333 0.35

1.6 0.02 0.04 0.06 0.08 0.1 0.12 0.14 0.16 0.18 0.2 0.22 0.24 0.26 0.28 0.3 0.32 0.34 0.36 0.38 0.4

1.8 0.023 0.045 0.068 0.09 0.113 0.135 0.158 0.18 0.203 0.225 0.248 0.27 0.293 0.315 0.338 0.36 0.383 0.405 0.428 0.45

2 0.025 0.05 0.075 0.1 0.125 0.15 0.175 0.2 0.225 0.25 0.275 0.3 0.325 0.35 0.375 0.4 0.425 0.45 0.475 0.5

2.2 0.028 0.055 0.083 0.11 0.138 0.165 0.193 0.22 0.248 0.275 0.303 0.33 0.358 0.385 0.413 0.44 0.468 0.495 0.523 0.55

2.4 0.03 0.06 0.09 0.12 0.15 0.18 0.21 0.24 0.27 0.3 0.33 0.36 0.39 0.42 0.45 0.48 0.51 0.54 0.57 0.6

2.6 0.033 0.065 0.098 0.13 0.163 0.195 0.228 0.26 0.293 0.325 0.358 0.39 0.423 0.455 0.488 0.52 0.553 0.585 0.618 0.65

2.8 0.035 0.07 0.105 0.14 0.175 0.21 0.245 0.28 0.315 0.35 0.385 0.42 0.455 0.49 0.525 0.56 0.595 0.63 0.665 0.7

3 0.038 0.075 0.113 0.15 0.188 0.225 0.263 0.3 0.338 0.375 0.413 0.45 0.488 0.525 0.563 0.6 0.638 0.675 0.713 0.75

3.2 0.04 0.08 0.12 0.16 0.2 0.24 0.28 0.32 0.36 0.4 0.44 0.48 0.52 0.56 0.6 0.64 0.68 0.72 0.76 0.8

3.4 0.043 0.085 0.128 0.17 0.213 0.255 0.298 0.34 0.383 0.425 0.468 0.51 0.553 0.595 0.638 0.68 0.723 0.765 0.808 0.85

3.6 0.045 0.09 0.135 0.18 0.225 0.27 0.315 0.36 0.405 0.45 0.495 0.54 0.585 0.63 0.675 0.72 0.765 0.81 0.855 0.9

3.8 0.048 0.095 0.143 0.19 0.238 0.285 0.333 0.38 0.428 0.475 0.523 0.57 0.618 0.665 0.713 0.76 0.808 0.855 0.903 0.95

4 0.05 0.1 0.15 0.2 0.25 0.3 0.35 0.4 0.45 0.5 0.55 0.6 0.65 0.7 0.75 0.8 0.85 0.9 0.95 1

Application Rate

>Stat limit


Co

nc

en

tra

tio

n o

f d

ete

rmin

an

d (

mg

/kg

)

Target

Concentration 0.2

DEFRA


136

Table 6.12 Limiting application rates based on average values for selenium

Determinand: Se kg/ha Loading Rate (kg/ha)Application

Rate of waste

(t/ha) -> 12.5 25 37.5 50 62.5 75 87.5 100 112.5 125 137.5 150 162.5 175 187.5 200 212.5 225 237.5 250

0.2 0.003 0.005 0.008 0.01 0.013 0.015 0.018 0.02 0.023 0.025 0.028 0.03 0.033 0.035 0.038 0.04 0.043 0.045 0.048 0.05

0.4 0.005 0.01 0.015 0.02 0.025 0.03 0.035 0.04 0.045 0.05 0.055 0.06 0.065 0.07 0.075 0.08 0.085 0.09 0.095 0.1

0.6 0.008 0.015 0.023 0.03 0.038 0.045 0.053 0.06 0.068 0.075 0.083 0.09 0.098 0.105 0.113 0.12 0.128 0.135 0.143 0.15

0.8 0.01 0.02 0.03 0.04 0.05 0.06 0.07 0.08 0.09 0.1 0.11 0.12 0.13 0.14 0.15 0.16 0.17 0.18 0.19 0.2

1 0.013 0.025 0.038 0.05 0.063 0.075 0.088 0.1 0.113 0.125 0.138 0.15 0.163 0.175 0.188 0.2 0.213 0.225 0.238 0.25

1.2 0.015 0.03 0.045 0.06 0.075 0.09 0.105 0.12 0.135 0.15 0.165 0.18 0.195 0.21 0.225 0.24 0.255 0.27 0.285 0.3

1.4 0.018 0.035 0.053 0.07 0.088 0.105 0.123 0.14 0.158 0.175 0.193 0.21 0.228 0.245 0.263 0.28 0.298 0.315 0.333 0.35

1.6 0.02 0.04 0.06 0.08 0.1 0.12 0.14 0.16 0.18 0.2 0.22 0.24 0.26 0.28 0.3 0.32 0.34 0.36 0.38 0.4

1.8 0.023 0.045 0.068 0.09 0.113 0.135 0.158 0.18 0.203 0.225 0.248 0.27 0.293 0.315 0.338 0.36 0.383 0.405 0.428 0.45

2 0.025 0.05 0.075 0.1 0.125 0.15 0.175 0.2 0.225 0.25 0.275 0.3 0.325 0.35 0.375 0.4 0.425 0.45 0.475 0.5

2.2 0.028 0.055 0.083 0.11 0.138 0.165 0.193 0.22 0.248 0.275 0.303 0.33 0.358 0.385 0.413 0.44 0.468 0.495 0.523 0.55

2.4 0.03 0.06 0.09 0.12 0.15 0.18 0.21 0.24 0.27 0.3 0.33 0.36 0.39 0.42 0.45 0.48 0.51 0.54 0.57 0.6

2.6 0.033 0.065 0.098 0.13 0.163 0.195 0.228 0.26 0.293 0.325 0.358 0.39 0.423 0.455 0.488 0.52 0.553 0.585 0.618 0.65

2.8 0.035 0.07 0.105 0.14 0.175 0.21 0.245 0.28 0.315 0.35 0.385 0.42 0.455 0.49 0.525 0.56 0.595 0.63 0.665 0.7

3 0.038 0.075 0.113 0.15 0.188 0.225 0.263 0.3 0.338 0.375 0.413 0.45 0.488 0.525 0.563 0.6 0.638 0.675 0.713 0.75

3.2 0.04 0.08 0.12 0.16 0.2 0.24 0.28 0.32 0.36 0.4 0.44 0.48 0.52 0.56 0.6 0.64 0.68 0.72 0.76 0.8

3.4 0.043 0.085 0.128 0.17 0.213 0.255 0.298 0.34 0.383 0.425 0.468 0.51 0.553 0.595 0.638 0.68 0.723 0.765 0.808 0.85

3.6 0.045 0.09 0.135 0.18 0.225 0.27 0.315 0.36 0.405 0.45 0.495 0.54 0.585 0.63 0.675 0.72 0.765 0.81 0.855 0.9

3.8 0.048 0.095 0.143 0.19 0.238 0.285 0.333 0.38 0.428 0.475 0.523 0.57 0.618 0.665 0.713 0.76 0.808 0.855 0.903 0.95

4 0.05 0.1 0.15 0.2 0.25 0.3 0.35 0.4 0.45 0.5 0.55 0.6 0.65 0.7 0.75 0.8 0.85 0.9 0.95 1

Application Rate

>Stat limit


Co

ncen

trati

on

of

dete

rmin

an

d (

mg

/kg

)

Target

Concentration 0.15

DEFRA


137

Table 6.13 Limiting application rates based on average values for arsnic

Determinand: As kg/ha Loading Rate (kg/ha)Application

Rate of waste

(t/ha) -> 12.5 25 37.5 50 62.5 75 87.5 100 112.5 125 137.5 150 162.5 175 187.5 200 212.5 225 237.5 250

0.5 0.006 0.013 0.019 0.025 0.031 0.038 0.044 0.05 0.056 0.063 0.069 0.075 0.081 0.088 0.094 0.1 0.106 0.113 0.119 0.125

1 0.013 0.025 0.038 0.05 0.063 0.075 0.088 0.1 0.113 0.125 0.138 0.15 0.163 0.175 0.188 0.2 0.213 0.225 0.238 0.25

1.5 0.019 0.038 0.056 0.075 0.094 0.113 0.131 0.15 0.169 0.188 0.206 0.225 0.244 0.263 0.281 0.3 0.319 0.338 0.356 0.375

2 0.025 0.05 0.075 0.1 0.125 0.15 0.175 0.2 0.225 0.25 0.275 0.3 0.325 0.35 0.375 0.4 0.425 0.45 0.475 0.5

2.5 0.031 0.063 0.094 0.125 0.156 0.188 0.219 0.25 0.281 0.313 0.344 0.375 0.406 0.438 0.469 0.5 0.531 0.563 0.594 0.625

3 0.038 0.075 0.113 0.15 0.188 0.225 0.263 0.3 0.338 0.375 0.413 0.45 0.488 0.525 0.563 0.6 0.638 0.675 0.713 0.75

3.5 0.044 0.088 0.131 0.175 0.219 0.263 0.306 0.35 0.394 0.438 0.481 0.525 0.569 0.613 0.656 0.7 0.744 0.788 0.831 0.875

4 0.05 0.1 0.15 0.2 0.25 0.3 0.35 0.4 0.45 0.5 0.55 0.6 0.65 0.7 0.75 0.8 0.85 0.9 0.95 1

4.5 0.056 0.113 0.169 0.225 0.281 0.338 0.394 0.45 0.506 0.563 0.619 0.675 0.731 0.788 0.844 0.9 0.956 1.01 1.07 1.13

5 0.063 0.125 0.188 0.25 0.313 0.375 0.438 0.5 0.563 0.625 0.688 0.75 0.813 0.875 0.938 1 1.06 1.13 1.19 1.25

5.5 0.069 0.138 0.206 0.275 0.344 0.413 0.481 0.55 0.619 0.688 0.756 0.825 0.894 0.963 1.03 1.1 1.17 1.24 1.31 1.38

6 0.075 0.15 0.225 0.3 0.375 0.45 0.525 0.6 0.675 0.75 0.825 0.9 0.975 1.05 1.13 1.2 1.28 1.35 1.43 1.5

6.5 0.081 0.163 0.244 0.325 0.406 0.488 0.569 0.65 0.731 0.813 0.894 0.975 1.06 1.14 1.22 1.3 1.38 1.46 1.54 1.63

7 0.088 0.175 0.263 0.35 0.438 0.525 0.613 0.7 0.788 0.875 0.963 1.05 1.14 1.23 1.31 1.4 1.49 1.58 1.66 1.75

7.5 0.094 0.188 0.281 0.375 0.469 0.563 0.656 0.75 0.844 0.938 1.03 1.13 1.22 1.31 1.41 1.5 1.59 1.69 1.78 1.88

8 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1 1.1 1.2 1.3 1.4 1.5 1.6 1.7 1.8 1.9 2

8.5 0.106 0.213 0.319 0.425 0.531 0.638 0.744 0.85 0.956 1.06 1.17 1.28 1.38 1.49 1.59 1.7 1.81 1.91 2.02 2.13

9 0.113 0.225 0.338 0.45 0.563 0.675 0.788 0.9 1.01 1.13 1.24 1.35 1.46 1.58 1.69 1.8 1.91 2.03 2.14 2.25

9.5 0.119 0.238 0.356 0.475 0.594 0.713 0.831 0.95 1.07 1.19 1.31 1.43 1.54 1.66 1.78 1.9 2.02 2.14 2.26 2.38

10 0.125 0.25 0.375 0.5 0.625 0.75 0.875 1 1.13 1.25 1.38 1.5 1.63 1.75 1.88 2 2.13 2.25 2.38 2.5

Application Rate

>Stat limit


Co

nc

en

tra

tio

n o

f d

ete

rmin

an

d (

mg

/kg

)

Target

Concentration 0.7

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Table 6.14 Limiting application rates based on average values for flouride

Determinand: F kg/ha Loading Rate (kg/ha)Application

Rate of waste

(t/ha) -> 12.5 25 37.5 50 62.5 75 87.5 100 112.5 125 137.5 150 162.5 175 187.5 200 212.5 225 237.5 250

15 0.188 0.375 0.563 0.75 0.938 1.13 1.31 1.5 1.69 1.88 2.06 2.25 2.44 2.63 2.81 3 3.19 3.38 3.56 3.75

30 0.375 0.75 1.13 1.5 1.88 2.25 2.63 3 3.38 3.75 4.13 4.5 4.88 5.25 5.63 6 6.38 6.75 7.13 7.5

45 0.563 1.13 1.69 2.25 2.81 3.38 3.94 4.5 5.06 5.63 6.19 6.75 7.31 7.88 8.44 9 9.56 10.1 10.7 11.3

60 0.75 1.5 2.25 3 3.75 4.5 5.25 6 6.75 7.5 8.25 9 9.75 10.5 11.3 12 12.8 13.5 14.3 15

75 0.938 1.88 2.81 3.75 4.69 5.63 6.56 7.5 8.44 9.38 10.3 11.3 12.2 13.1 14.1 15 15.9 16.9 17.8 18.8

90 1.13 2.25 3.38 4.5 5.63 6.75 7.88 9 10.1 11.3 12.4 13.5 14.6 15.8 16.9 18 19.1 20.3 21.4 22.5

105 1.31 2.63 3.94 5.25 6.56 7.88 9.19 10.5 11.8 13.1 14.4 15.8 17.1 18.4 19.7 21 22.3 23.6 24.9 26.3

120 1.5 3 4.5 6 7.5 9 10.5 12 13.5 15 16.5 18 19.5 21 22.5 24 25.5 27 28.5 30

135 1.69 3.38 5.06 6.75 8.44 10.1 11.8 13.5 15.2 16.9 18.6 20.3 21.9 23.6 25.3 27 28.7 30.4 32.1 33.8

150 1.88 3.75 5.63 7.5 9.38 11.3 13.1 15 16.9 18.8 20.6 22.5 24.4 26.3 28.1 30 31.9 33.8 35.6 37.5

165 2.06 4.13 6.19 8.25 10.3 12.4 14.4 16.5 18.6 20.6 22.7 24.8 26.8 28.9 30.9 33 35.1 37.1 39.2 41.3

180 2.25 4.5 6.75 9 11.3 13.5 15.8 18 20.3 22.5 24.8 27 29.3 31.5 33.8 36 38.3 40.5 42.8 45

195 2.44 4.88 7.31 9.75 12.2 14.6 17.1 19.5 21.9 24.4 26.8 29.3 31.7 34.1 36.6 39 41.4 43.9 46.3 48.8

210 2.63 5.25 7.88 10.5 13.1 15.8 18.4 21 23.6 26.3 28.9 31.5 34.1 36.8 39.4 42 44.6 47.3 49.9 52.5

225 2.81 5.63 8.44 11.3 14.1 16.9 19.7 22.5 25.3 28.1 30.9 33.8 36.6 39.4 42.2 45 47.8 50.6 53.4 56.3

240 3 6 9 12 15 18 21 24 27 30 33 36 39 42 45 48 51 54 57 60

255 3.19 6.38 9.56 12.8 15.9 19.1 22.3 25.5 28.7 31.9 35.1 38.3 41.4 44.6 47.8 51 54.2 57.4 60.6 63.8

270 3.38 6.75 10.1 13.5 16.9 20.3 23.6 27 30.4 33.8 37.1 40.5 43.9 47.3 50.6 54 57.4 60.8 64.1 67.5

285 3.56 7.13 10.7 14.3 17.8 21.4 24.9 28.5 32.1 35.6 39.2 42.8 46.3 49.9 53.4 57 60.6 64.1 67.7 71.3

300 3.75 7.5 11.3 15 18.8 22.5 26.3 30 33.8 37.5 41.3 45 48.8 52.5 56.3 60 63.8 67.5 71.3 75

Application Rate

>Stat limit


Co

nc

en

tra

tio

n o

f d

ete

rmin

an

d (

mg

/kg

)

Target

Concentration 20

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7. CONCLUSIONS AND RECOMMENDATIONS

7.1 General

Based on the assessment of available data:

A wide range of wastes are currently spread to land under exemption, these include over 75 different LoW classifications. These 75 LoW codes, 22 were identified as potentially presenting a higher risk to the environment.

Correct coding and description of wastes is essential in order to assess the risks posed by waste streams being spread to land. Many waste streams within the same LoW code exhibit markedly different properties and should ideally be evaluated at a sub-level i.e. in greater detail than the LoW code. This is reflected in the large observed variability across most parameters within the same LoW code.

Only 1.3% of the exemptions registered in the 12 months evaluated were for ecological improvement, the remainder were for agricultural improvement.

The analytical data submitted by Paragraph 7 operators indicates that although many wastes provide valuable nutrients and soil conditioning properties, in some cases the agricultural benefit is negligible.

More obligation should be placed on operators to prove agricultural benefit or ecological improvement for exempt sites.

The largest source of waste spread to land under Paragraph 7 exemptions is from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing LoW code 02 xx xx. This LoW chapter code makes up 56.4% of the waste currently spread to land (by weight).

Large between plant variability was observed for many waste streams. WRc were not able to obtain any data on between-load-with-plant, or within-load variability from operators in the timescales of the project, however, it may be useful to collect this data in order to identify suitable analytical schedules to support notifications.

In general the reported levels of potentially toxic elements in wastes spread to land was low on the basis of the data provided. It was clear that if the information is not specifically requested on the application form additional analyses are not undertaken. For example, metal concentrations provided by operators generally cover only the basic suite of 7 metals suggested as the minimum on the guidance document.

Organics and pesticide data was only provided by a small number of operators. Biodegradability data was not provided on any of the notifications assessed for this project, although it is an important factor in deciding agricultural benefit.

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7.2 Follow-up inspections

The number of follow-up inspections carried out by the Environment Agency varied between areas, ranging from 5% to 100%. Low follow-up rates were mainly due to the fact that there is no requirement for the operator to tell the regulator when he is spreading waste, and unannounced inspections are therefore an ineffective form of regulation for this type of exemption.

7.3 Pollution Incidents

Since the Waste Management Licensing Regulations (England & Wales) (Amendment) Regulations were bought in to force in April 2005, there have been 33 category 1 and 2 pollution incidents involving Paragraph 7 exemptions. 44 successful prosecutions (including formal cautions) relating to Paragraph 7 exemptions have been taken by the Environment Agency since 2005 (as at January 2009).

The main type reported incident involving Paragraph 7 exemptions was complaints of odour. Due to the poor quality of the data WRc have to date been unable to establish whether any particular waste streams cause more environmental issues than others.

7.4 Recommendations

Correct coding of wastes by LoW code is essential, and standardisation of notifications for waste analysis (preferably in electronic format), should be considered. This will enable clear and unambiguous comparison between waste types. The collecting of notifications of waste spread under the Environment Agency modern regulatory position statement should be centralised and stored electronically, so that it can be interrogated to monitor risk.

The number of waste types spread on a single field should be restricted, and a tiered degree of regulation should be introduced to take in to account the variation of risk by waste type, rather than the current single tier approach.

Waste returns should be required of sites to show how much waste has been spread in comparison with how much was applied for.

Minimum requirements for agricultural benefit should be set.

The number of wastes spread on a single site should be limited (currently there is no limit).

Better data is required on the variability of waste streams, with more than one sample per year required for the high risk waste streams where the operator cannot show that the waste stream is inherently homogenous and consistent.

Up to date data should be required for renewal notifications (we were unable to assess any renewal notifications for this study due to this reason).

Notification to the Environment Agency of when spreading is to be carried out should be required. Follow-up inspections of the exempt sites should be tied in with when the waste is spread.

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The amount of information collected on pollution incidents should be increased, particularly to show whether the site is registered exempt.

Details should be kept on waste spread under the Agricultural Waste Regulations 2005 on waste type and quantity.

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REFERENCES

Code of Practice for Agricultural Use of Sewage Sludge, Department of the Environment, 1996

Hazardous Waste. Interpretation of the definition and classification of hazardous waste. Technical Guidance Note WM2. Environment Agency, 2008: http://publications.environment-agency.gov.uk/pdf/GEHO0603BIRB-e-e.pdf

Fertiliser Recommendations for Agricultural and Horticultural Crops (RB209), Defra 2000

Review of Defra‟s „Fertiliser Recommendations (RB209)‟ publication, ADAS, 2006

Commission of the European Communities v Kingdon of Spain, C-416/02, 2005

Defra whole farm approach - http://www.defra.gov.uk/farm/wholefarm/index.htm

Davis, RD, and Rudd C, (April 1998) Investigation of the criteria for, and guidance on, the landspreading of industrial wastes. WRc report No. UC3757

Guidance on sampling and testing of wastes to meet landfill waste acceptance procedures, Version 1, April 2005

Specification for Topsoil, BS 3882:2007

http://www.environment-agency.gov.uk/static/documents/Business/MWRP_001_v4_Oct_2008.pdf

The regulation of materials being considered under the Waste Protocols Project, Version 2, Environment Agency, July 2008

Anerobic digestate Quality Protocol, WRAP and Environment Agency, January 2009, http://www.environment-agency.gov.uk/static/documents/Business/W524AnaerobicDigestatev4(1).pdf

Using the List of Wastes Codes, Environment Agency, April 2006

Defra (2009), Protecting our Water, Soil and Air - A Code of Good Agricultural Practice for farmers, growers and land managers http://www.defra.gov.uk/farm/environment/cogap/pdf/cogap090202.pdf

http://publications.environment-agency.gov.uk/pdf/GEHO0603BIRB-e-e.pdf

http://www.defra.gov.uk/farm/wholefarm/index.htm



http://www.environment-agency.gov.uk/static/documents/Business/W524AnaerobicDigestatev4(1).pdf

http://www.environment-agency.gov.uk/static/documents/Business/W524AnaerobicDigestatev4(1).pdf

http://www.defra.gov.uk/farm/environment/cogap/pdf/cogap090202.pdf

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APPENDIX A DATA GATHERING: EXEMPTION NOTIFICATIONS

A.1 INSTRUCTIONS GIVEN TO DATA GATHERING TEAM

Instructions for data entry – Waste exemptions – Project 15070-0

Background

As part of Defra‟s review of waste spread to land for agricultural benefit, WRc are carrying out a risk assessment for the waste types sent to land. To do this, we are collecting information on waste types, characteristics of the waste (contaminants and nutrient content), the receiving soils the waste is being spread to, and how the spreading is managed.

In order to spread waste to land for agricultural benefit, the operator must first notify for an „exemption‟ from the Environment Agency. The application for the exemption which the operator must complete requires: details of the operator, waste being spread, soil type etc.

We have obtained some 1900 scanned application documents for one year from the Environment Agency. To help us complete the risk assessment, we now need to compile this data in to a single database. The instructions given below outline how we intend to do this.

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The application form

All notifications for exemptions will be provided on the same type of form, with a first sheet that looks like this:

When you open the document, some notifications will have other documentation before you get to this sheet, so just scroll through these until you get to the sheet that look like this using these buttons:

The information we need from this form is explained below, please ignore all sections and questions not mentioned here.

The standard form is nine pages long, and we require information from various sections. Attached to the form will be supporting information in the same document. Included in this will be details of analysis of the waste being spread and soil, which all needs to be recorded on the relevant sections on the datasheet, explained in more detail below. The easiest way to enter data on to the datasheet will probably be to work through it as it is set out here.

Applications will vary in quality and the amount of information that is supplied to support the application. It is very unlikely you will be able to complete all fields on the data sheet.

Many of the notifications may have a substantial amount of supporting documents. From this you will have to select the data that should be entered on to the system, which may take a bit of getting up to speed with.

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Please take great care when entering data on to the datasheet, particularly with units as the data is useless if we get these wrong.

The datasheet

The information from the notifications need to be entered on to the „edm datasheet‟ Excel spreadsheet. There is a separate line for each application form.

Once you have opened the application form using Microsoft picture viewer, please search for its corresponding entry on the spreadsheet using the P reference (P1234 etc). All data relating to that application should all be entered on the same line, in the relevant tabs.

For most notifications entering the key information on to the spreadsheet should take about 15-20 minutes. If you find that it takes much longer than this please contact me.

On many column headings you will find comments boxes with extra information on how to fill in that particular field. If this doesn‟t provide you with enough information to fill in the column please ask me.

The questions

Page 2, Question 1.2

These details should match the details already given on the spreadsheet, no new information needs to be entered. The address given is the site address rather than the main contact address.

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Page 2, Question 2.1, 2.2 and 2.3 – New application or renewal?

Please enter in Column G of the spreadsheet whether application is a new application or a renewal (registrations for spreading waste to land must be renewed every year).

If the operator has marked that he is renewing his registration by ticking the second box down on question 2.1, please enter the registration number in the same format as that given on the application in Column H on the spreadsheet. Column F states whether the application is a renewal or new application, but we are not sure how accurate this information is, so please confirm this in the adjacent column.

Where the application is a renewal, and the operator has indicated that no details have changed since the last renewal (by answering „no‟ to question 2.3 on page 2), there is no requirement for the operator to give any further details about waste to be spread. Where the application is a renewal, no more information need be entered on to the spreadsheet, and you can move on to the next application.

Any notifications with a 3-digit reference number will not be present on the form, please leave the space for info from these notifications blank on the spreadsheet.

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***If you cannot find the form, please enter an ‘X’ in the ‘Original Application Ref.’ column***

Page 3, Question 3.1 – About the waste

Details will be provided for at least one waste type. Please enter the details as they are given on the sheet. This data needs to be entered on to the „waste analysis‟ tabs on the spreadsheet for each waste type.

You can enter information on up to 10 waste types, each waste type entered on a separate tab (waste 1, waste 2, waste 3 etc.). Please enter the information on the spreadsheet exactly as it appears on the form. If the correct entry is not available from the drop down menus in Excel, please ask.

In this section, as with the above example, the information may be provided on a separate sheet rather than on the application form. This is usually done where there are more than 3 waste streams being spread to land.

For the „Total amount to be used‟ field, if at all possible please give an absolute amount i.e. tonnes (T) rather than tonnes per hectare (T/h). This may need to be calculated from the number of hectares the waste is spread and the waste spread per hectare. The amount of waste spread per hectare may be available either from question 4.12 or from supplementary information to the form.

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The LoW code (column K on the spreadsheet) is a six digit code which identifies the waste type. This field is entered via a drop-down list. If the LoW code given is not available from the pick list please make a note of it and see me.


Please enter pm to the spreadsheet whether the operator has answered Yes or No to question 3.5. Where no answer has been given, please enter N/D (= no data).

Page 3, Question 3.7 – Capacity of the storage facility

Page 3, Question 3.8 – Intended storage

Please enter on spreadsheet exactly as it is given

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Page 4, Question 4.6 – Is the land currently used for agriculture

Please enter Yes or No from the pick list.

Page 4, Question 4.9 and 4.10– Has the land been treated with any waste in the last 12 months?

Please enter „yes‟ or „no‟. If yes, please enter TOTAL amount of waste that has been spread in the previous 12 months. If the operator has entered „see data previously supplied‟ or similar (as in the example above), please leave these columns blank.

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Please enter area of land to be treated in hectares.

Page 5, Question 5.1 – Benefits and improvements

Please enter on the datasheet whether operator is notifying for benefit to agriculture (depending on which box has been ticked).

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Question 5.3 and .54 – How often do you intend to spread waste and when?

Please enter on to spreadsheet whether the operator has indicated they will spread the waste once or several times. Please give an overall start and end date of when the spreading will take place. If the spreading is due to take place all year, please put the completion date as one year after the start date.

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Question 5.5 Method of application

Please choose method of application from drop down menu. If it is not available, please ask.

Question 5.6 – Intended rate of application

Please enter intended rate of application, together with the units. Where the operator has entered „up to 250 t/h‟ as in the above example, please enter 250. 250 t/ha is the maximum allowed to be spread, so this may be quite common.

We do not require any information from pages 6-7, questions 6 – 9.

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Supporting documents

After the form will be all the supporting documentation on nutrient content and potential pollutant content of the waste. Also there will be information on the soil type and analysis.

There is unlikely to be information supplied enough to fill in all fields, as we have included all possible information which the operator may supply. If the operator has not supplied information on a certain field, please leave it blank.

Waste analysis

Amount spread

The total amount spread of all wastes should be given in answer to question 4.12. Where there is only one waste stream, that number should be entered here. However, where there is more than one waste stream, the application rate (t/ha) will most likely be given in the supporting documentation.

If you cannot find any information on application rates please leave blank.

Amount spread Waste Analysis

Amount spread per hectare (waste 1)

Amount spread per hectare (unit) - waste 1 pH

Is waste treated prior to spreading?

Date sampled

Lab name

If any of the information is missing, please leave cell blank.

Nutrient Content of the waste

Nutrients

Total Nitrogen (as N) Unit

Available Nitrogen (as N)

Moisture content Unit

C:N ratio

Neutralising capacity

Neutralising capacity (units) Phosphorus Unit

Potassium Unit Sulphur units Mg Unit Dry matter Unit Other nutrient info

As a minimum, there should be details in the application on Total N, Phosphorus, Potassium and Magnesium. Please make sure you enter the units, and check whether analysis is quoted

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as dry weight (e.g. mg/kg DM) or wet weight. When quoting wet weight make sure you know the moisture content of the waste.

You will likely have to leave many of these fields blank (for example, neutralising capacity is only relevant to high pH wastes which are being used to treat acidic soils). Where there is no data, please leave blank.

Where analysis has been provided in duplicate for a waste, there is space to enter this information, starting at Column BE

Potentially toxic elements

Potentially toxic elements (PTEs)

Method of

analysis for PTEs Zn Unit Cu Unit Ni Unit Pb Unit Cd Unit Hg Unit

Other PTE information

The above six elements are the minimum analysis required for each waste. Please make sure you enter units, and indicate whether analysis is on wet weight or dry weight basis.

If other analysis has been supplied, please briefly describe what this is on „Other PTE information‟ field – for example “analysis provided for a further 5 elements”.

Where analysis has been provided in duplicate for a waste, there is space to enter this information, starting at Column BE

Other

Other

Organics pollution data Alkalinity Units

Biodegradation data?

It is unlikely that this information will be supplied for many wastes. Please leave blank where no data has been supplied.

Soil analysis

There are three tabs to enter information on soil analysis on to for where analysis has been supplied for more than one field.

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If analysis has only been supplied for one soil, please leave other tabs blank.

Soil analysis

Soil type

pH of soil

P concentration in soil]

Units K concentration in soil]

Units Mg concentration in soil]

Units Crop type

Total NH3

Total NH3 unit

Total NO3

Total NO3 unit

Water holding capacity

Nitrogen mineralisation rate

Soil respiration rate

moisture content

Lime requirement

Lime requirement (Units)

SNS index

As above, there will not be enough information to fill many of the columns, although all operator should provide details of N, P and K conc. in the soil. If there is no information, please leave column blank.

PTE content

Potentially toxic elements (PTEs)

Method of analysis for PTEs Zn Unit Cu Unit Ni Unit Pb Unit Cd Unit Hg Unit Other PTE info

Please enter PTE concentrations along with units

Crop analysis

Crop analysis

Yield

Nutrient off-take

-P P Units

Nutrient off-take

- K K Units

Nutrient off-take

- N N units

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There may be no information supplied in order to complete these fields. Please fill in if the data has been supplied, otherwise please leave blank.

A.1 Instructions given to data gathering team – Extra Information

As part of Defra‟s review of waste spread to land for agricultural benefit, WRc are carrying out a risk assessment for the waste types sent to land. To do this we are collecting information on waste types, characteristics of the waste (contaminants and nutrient content), the receiving soils the waste is being spread to and how the spreading is managed.

The information provided on waste types, the receiving soils and waste analysis and the rate of application are highly important to the interpretation and accuracy of the results on this project and we ask that you pay careful attention when transferring data in these areas.

In order to provide some additional support, we have put together this document for use as a reference guide in combination with the instructions you have already received.

Waste and Soil Reporting Units

Reporting of waste and soil analysis results is often confusing when the exact reporting units are not clear.

The following notes give some guidance on what might be found as units from analysis reports.

General

Solid - Solid wastes and soils

General units- (preferred units in bold)

Solids

% w/w

mg/g = g/kg = kg/t

ppm = mg/kg = g/t

Liquids

µg/ml = mg/l = g/m3

g/l = kg/m3

Total contents - Often only reported as per kg (x/kg) or as a percentage (%).

Actual units may on a basis of

Dry matter (x/kg DM) or Dry solids (x/kg DS) - means the same. Per kg of water free material.

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Fresh weight (x/kg FW), Wet weight (x/kg wet wt) or as received (x/kg AR) - means the same. Per kg of wet material and includes the moisture.

Extractable nutrients - these are amounts that are extractable with different water based solutions. Represent the available nutrients of the solid waste.

Actual units usually reported as x/l which refers to the concentration measured in the extract. Sometimes related back to the solid material, e.g. x/kg.

If an analysis does not say extractable but simply states the element i.e. P. then assume it is total P.

Liquid wastes

Reporting units are usually in volume, x/l or x/m3.

Sometimes reported as weights x/kg or x/t which refers to whole liquid weight and for most water based liquids assume the weight is the same as the volume.

Some parameters reported as x/kg DM in which case the dry matter content of the liquid must also be known.

Specific parameters

Nitrogen -

Total N - is amount of all N species measured as elemental N. e.g.

Solid waste and soil often measured as % or g/kg (which means g N/kg)

Then need to know if units are on a DM, DS, FW, or AR.

Liquid waste is usually measured as % or g/l (kg/m3).

Available N strictly includes mineral nitrogen (NH3, NO3-, NO2-) and any organic N that may be mineralised as the waste decomposes. Often is referred to the sum of extractable NH3 and NO3-.

Extractable nitrogen - These are often measured as compounds and may be reported in units of the compound or as elements.

Ammonia

Usually reported as mg/l. Means mg NH3/l.

Sometimes reported as

Elemental ammonia nitrogen - mg N/l or mg NH3-N/l

Ammoniacal Nitrogen - mg N/l or mg NH4-N/l

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Nitrate

Usually reported as mg/l. Means mg NO3/l.

Sometimes reported as

Elemental nitrate nitrogen - mg N/l or mg NO3-N/l

Nitrite

The same rules apply to nitrite, e.g. mg NO2-N/l.

Phosphorous and phosphate

Total Phosphorous in all solids and liquids

Usually measured as either the element (P) or as the oxide (P2O5) and expressed as a % or as g/kg or kg/t.

Need to be clear what units are:-

e.g. as element (g P/kg) or as oxide (g P2O5/kg) in solids or per litre in liquids.

Phosphate

May be reported as total phosphate but usually refers to extractable phosphate.

Usually reported mg/l so need to clear whether is either the element (mg P/l or mg PO4-P/l) or as the phosphate ion (mg PO4/l).

Note soil nutrient status is based on extractable phosphate reported as mg P/l.

Potassium

Total potassium in all solids and liquids.

Usually measured as either the element (K) or as the oxide (K2O, often called potash) and expressed as a % or as g/kg or kg/t.


e.g. as element (g K/kg) or as potash (g K2O /kg) in solids or per litre in liquids.

Note soil nutrient status is based on extractable potassium reported as mg K/l.

Magnesium

Total magnesium in all solids and liquids

Usually measured as either the element (Mg) or as the oxide (MgO) and expressed as a % or as g/kg or kg/t.


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e.g. as element (g Mg/kg) or as potash (g MgO /kg) in solids or per litre in liquids.

Note soil nutrient status is based on extractable potassium reported as mg Mg/l.

Sulphur and sulphate

Total sulphur in all solids and liquids

Usually measured as either the element (S) or as the oxide (SO3) and expressed as a % or as g/kg or kg/t.


e.g. as element (g S/kg) or as oxide (g SO3 /kg) in solids or per litre in liquids.

Sulphate

May be reported as total sulphate but usually refers to extractable sulphate.

Usually reported mg/l so need to clear whether is either the element (mg S/l or mg SO4-S/l) or as the sulphate ion (mg SO4/l).

Note soil nutrient status is based on extractable sulphate reported as mg/l but usually means mg S/l. Need to be sure this is as the element and notas sulphate ion

Other elements

All other elements should be reported as elements so only need to be sure whether is as /kg DM or as /kg FW.

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APPENDIX B DATA GATHERING: CONTACTING OPERATORS AND REGULATORS

B.1 ENVIRONMENT OFFICERS QUESTIONNAIRE

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APPENDIX C METHODOLOGY FOR ASSESSING IMPACTS AND PRIORITISING HIGH RISK WASTES

Introduction

Identifying high risk wastes by assessing their environmental impact is a key step in the assessment of impact of waste spread to land under Paragraph 7 exemptions from Environmental Permitting.

To categorise waste types by their overall risk presented for each waste type, a methodology has been developed to attribute a risk score to each waste, allowing comparison of waste types.

In order to fully characterise the risk presented from each waste, the two main factors which must be considered are:

Amount of waste spread (total and amount per hectare) - the total amount spread of any waste in England and Wales, and the average loading per hectare.

Properties of the waste – Characteristics of the waste, broken down in to the following six catagories:

Metal concentration in the waste (Zn, Pb, Cu, Ni, Cd, Hg)

Nutrient content (N and P)

Biodegradability/ C:N ratio (Greenhouse gas potential)

Pathogen potential

Organic pollutants

Reported pollution incidents relating to waste type As detailed below, a score will be derived for both the amount of waste spread and the properties of the waste, and turned in to multiplying factors to obtain the overall risk score.

This assessment is a first-pass assessment and necessarily does not take in to account every possible characteristic of the waste, and is in part qualitative. As such, we will examine the data in more detail for each waste before a final priority list is decided upon.

Methodology

The overall risk for each waste is given by the following calculation.

Overall risk = Waste properties risk score x Waste spread risk score

Where:

Waste spread risk score = Total waste score x waste per hectare score

Waste properties risk score = Z x Y x X x W x V x U

Where Z to V are equal to either 1.0 or 1.25:

Z = Metal concentration in the waste (Zn, Pb, Cu, Ni, Cd, Hg)

Y = Nutrient content (N and P)

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X = Biodegradability/ C:N ratio (Greenhouse gas potential)

W = Pathogen potential

U = Organic pollutants

V = Reported pollution incidents relating to waste type

And Z to U = 1.25 or 1

The calculation is explained further over the following sections.

Waste spread risk score

Total waste score

The total amount of each waste type spread to land is considered to be the most important factor when considering overall environmental risk of the waste. We therefore propose to weight it accordingly, with the highest multiplying factors of any category. Each waste will be given a score of 1 – 3 as follows:

Mass spread (t) 0 – 10 000 10 001 – 50 000 >50 000

Score 1 2 3

The mass spread figure is the sum in tonnes of each waste type spread per year.

Waste per hectare score

The average loading per hectare is also key in terms of environmental risk. The wastes will be divided in to three categories depending on the average amount spread per hectare, and scored as follows:

Mass spread (t/h) 0 - 100 101 - 200 >201

Score 0.5 1 1.5

The total waste score and the waste per hectare score are then multiplied together to give a waste spread risk score.

Waste properties risk score

The six waste properties will also be considered as part of the assessment. To simplify the calculations are far as possible, each waste is placed in one of two risk groups:

Low risk (score: 1)

High risk (score: 1.25)

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The multiplying factor for each category are then multiplied together, to produce the over waste properties risk score.

Heavy metal content

The six metals for which analysis is required as part of an application for a paragraph 7 exemption are:

Zinc

Lead

Cadmium

Nickel

Mercury

Copper

Concentration of these metals will form the basis of the calculation for metals contents, which will be obtained from para 7 application forms.

We have chosen to compare levels of metals to threshold values set in the compost standard BSI PAS100:2005 levels. These limits were chosen as they are given as they are absolute limits, and were set in order to protect human health and the environment when compost is applied to land. The PAS 100 limits are as follows:

Metal Threshold Value (mg/kg DM)

Zinc 400

Lead 200

Cadmium 1.5

Nickel 50

Mercury 1.0

Copper 200

The 90th percentile of metal concentrations for the dataset for each waste will be determined. This will give an indication of the range of data, while discounting any outliers.

Where the amount of metal present in the waste is less than the threshold value, it will be given a score of zero. Where the concentration is greater than the threshold value, a score will be given based on the calculation of the ratio - concentration: threshold value. For example, for a waste that has a Zn concentration of 600 mg/kg DM, the score for Zn will be 1.5. This calculation is repeated for each metal to give an overall metals score:

Zn score + Pb score + Cd score + Ni score + Hg score + Cu score = overall metals score

Where the overall metals score is <3, the waste will be considered low risk with respect to metals and given a multiplying factor of x1. Where the score is >3 it will be considered there is

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some degree of risk, and a multiplying factor of x1.25 applied. This will identify where individual metals have a high concentration, or where there are a range of metals with slightly elevated concentrations.

Nutrients

A similar approach will be taken for scoring the nutrient quantity in each waste to the approach used for. Nitrogen and phosphate will be considered in the assessment of nutrient content, and will be compared against 5% levels of both nitrogen and phosphorus. Again, where N and P are present below these threshold levels, a score of 0 will be given, and where it is over, a score equal to the ratio of concentration {nutrient: threshold value} will be given, and the two scores from N and P summed:

N score (where N > 5% DM) + P score (where P > 5% DM) = overall nutrients score

Where the overall nutrients score is >1.5, a multiplying factor of x1.25 will be applied. Where the overall nutrients score is <1.5, the multiplying factor will be x1.

Microbial pathogens, organic pollutants and biodegradability (greenhouse gas potential)

The above three categories are grouped together as there is very little data available from the literature, and it is expected that little data will be available from the application forms. The initial review of para 7 application forms has similarly shown very few operators have provided data of this type of analysis.

An approach similar to that above will be taken where wastes which have a perceived risk in relation to these categories will be given a multiplying factor of x1.25, and those with a smaller risk will be given a multiplying factor of x1.

The process of applying these multiplying factors will necessarily be subjective due to the lack of available data for waste materials.

Pollution Incidents

The number of pollution incidents reported to the Environment Agency for any particular waste stream will be obtained from Environment Agency systems. We will then score the incidents for each waste as follows:

Non-serious incident (CICS category 3 or 4) = 1 point

Serious incident (CICS category 1 or2) = 3 points

The total number of points for each waste will then be summed. If the total points score for any particular waste is greater than 3, it will be given a multiplying factor of x1.25 and if it is less than 3, a multiplying factor of x1 will be applied.

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Final Scoring

Following determination of the multiplying factor for each category has been determined, these are applied and the overall risk score is determined. A spreadsheet tool has been developed to obtain the score for each waste once the subjective risk assessment has been carried out. Criteria for each category is summarised below.

Group Category Multiplying factor Criteria

Wa

ste

sp

rea

d

Total tonnes spread in England and Wales

Grouped in to <10 000 t/y (x1), 10 000 – 50 000 (x2) or >50 000 (x3)

Based on total waste spread for each waste

Average loading rate (t h-1)

Grouped in to <100 t/ha (x0.5), 100 – 200 t/h (x1), >200 t/h (x1.5)

Based on average loading rate

Wa

ste

pro

pert

ies

Metal concentration in the waste (Zn, Pb, Cu, Ni, Cd, Hg)

Score <3 (x1) or score >3 (x1.25)

Individual metal concentrations divided by respective PAS100 limits. Where ratio >1, ratios are summed to give overall score.

Nutrient content (N and P)

Score <1.5 (x1) or >1.5 (x1.25)

N and P concentration for each waste divided by 5%. Where this ratio >1, ratios are summed

Biodegradability/ C:N ratio (Greenhouse gas potential)

No risk (x1) or Some risk (x1.25)

Qualitative assessment

Pathogen potential No risk (x1) or Some risk (x1.25)


Organic pollutants No risk (x1) or Some risk (x1.25)


Reported pollution incidents relating to waste type

Score <3 (x1) or score >3 (x1.25)

Where serious pollution incident reported score 2, non-serious = 1. Scores are summed for each waste

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