Sampling Plans for Trommel Fines

It has been just over a year since I wrote an article here about the action being taken by the Environment Agency (EA) to ensure that all trommel fines producers properly classify their trommel fines as hazardous or non-hazardous waste. The EA had sent out a letter that stated “only when a waste assessment, carried out in accordance with WM3 guidance, shows the waste does not display any hazardous properties, can the non-hazardous mirror waste codes be assigned (19 12 12)”. The need to classify waste in accordance with WM3 Waste Classification Technical Guidance is not new and actually applies to all waste regardless of its LOW code.

So, where are we one year on from this?

I am pleased to say that I am not seeing the EA taking a heavy-handed approach. Rather, they appear to be raising this as an issue on Compliance Assessment Report (CAR) forms and Waste Audit Report (WAR) forms subsequent to visits to waste facilities. Even when an operator has little to no evidence of hazardous waste assessments this is typically not resulting in non-compliance points being given on the CAR forms. However, they are generally asking for Sampling Plans to be submitted to them within a set timeframe.

Sampling plans need achieve two objectives:

• Provide information on the ‘Basic Characterisation of the trommel fines.
• Propose an appropriate on-going compliance sampling and testing frequency.

Let’s look at the basic characterisation step. This is an investigation that is carried out to determine the variability within the trommel fines in terms of hazardous properties. Typically, this can be achieved by sampling the trommel fines three to five times over the course of one day. Then repeating this for around three days in total, over several weeks. This should provide sufficient data to determine an on-going compliance sampling and testing frequency.

Ideally, spot samples taken from the flow of trommel fines should be collected in a clean container and then transported to the lab. Ask the lab to do a total content analysis on the sample. You may be used to asking for landfill WAC tests however, WAC tests do not provide the correct results on which a hazardous waste assessment can be carried out. Once you have your lab results a hazardous waste assessment needs to be completed to determine if the trommel fines display any hazardous properties. Review all the hazardous waste assessment results from your samples, you may need to do some statistical modelling of the results to determine the probability of the fines being non-hazardous/hazardous. The more certain you are that the trommel fines are non-hazardous, the less frequently you will need to do on-going compliance sampling.

Yes, I agree this does sound like a lot of work and I think the EA also appreciate that this will take time. However, as long as proposals to complete this work are submitted, from my experience, the EA are being reasonable about providing the necessary time.

So think about your sampling plan as having two stages or versions to it.

Sampling Plan Version 1 – contains proposals on the basic characterisation sampling regime, how you will take your samples, what you will test for and how you will assess the results. Submit this report in response to a request from the EA.

Sampling Plan Version 2 – contains the results and interpretation of the results from the basic characterisation investigation and a proposal of the frequency of on-going compliance sampling. Submit this to the EA when it is complete.

I have talked about Sampling Plans and Trommel fines in my webinars which have been recorded and are free to download here. If you can’t find the answer to your queries there, then please do not hesitate to call the office where one of my experienced consultants or I will be happy to help you.