Blog & Insights

In many cases waste disposal is considered by the end of a project when the waste comes available and that is too late.

Why wait?

Why don't people look at the waste disposal aspects earlier in a project? Reasons can be that the quantity is not known yet or that the composition of the waste is not known. Due to the unknown composition it may not be possible to establish the hazards. In some cases the project resulting in the waste is done by an industrial services contractor and at the end of the project the waste is handed to the owner or operator of the plant. Waste disposal may be the responsibility of another part of the organisation that is not involved in for example maintenance projects. Or waste disposal is simply underestimated.

Integrate waste disposal

With most waste, but certainly when dealing with hazardous waste it pays off to consider disposal as early as possible in the project and integrate it in the planning. Not doing so can lead to serious delays and long times of getting stuck with waste. Many countries also limit the time that you can store waste leading to possible violations if you can't move it in time.

Dispose, treat or recycle

Depending on your waste stream it may be complex to get rid of and the more hazardous the fewer options you may have. Knowing your disposal options is an important step. Can you simple dispose, is treatment required or is it possible to recover materials that can be recycled? Is the solution nearby or far away? Advanced treatment and recycling facilities are often located in western countries. One of the reasons for this is that it is illegal under the UN Basel convention to move hazardous waste in to a developing country. Therefore waste treatment facilities in developing countries can only cater for the domestic market making it difficult to reach sufficient economy of scale.

Packaging

Another good reason to plan ahead is packaging having the right packaging from the start saves repacking when the waste can't be moved if packed wrong. Packaging of waste is regulated and important for the safety of transport, storage and handling. Sometimes suitable packaging is not locally available and needs to be imported. Limiting the time the waste is packed can also lead to savings, under some conditions, rain, moisture and sunlight packaging can deteriorate very fast and it is not uncommon that repacking is required prior to transport after long periods of storage.

Permitting

When waste has to be stored and moved permits will be necessary. Obtaining permits can take a lot of time as you have to work with governmental organisations. When waste has to be moved between countries permission is needed not only from the country of origin and the destination country, but from every intermediate country that the transport passes trough. Even when waste stays on board of a ship visiting a port the authorities of that country have to give permission for the waste to be on board. This system of permitting is regulated under the UN Basel convention. Obtaining all the permissions can take more than half a year depending on the countries involved. Some countries also require inland waste movement permits and special licenses and insurances for the vehicles used for the transport. Storage facilities need to be licensed for the storage of the waste and there may be limits to the time that waste can be stored. Regulatory frameworks differ by country. All issues that take time to clear if you want to make sure you stay within the rules.

Transport and storage

Pending the permits transport has to be organised and that is also not easy. Many transport companies, shipping lines in particular, don't like waste on board their vessels. Most simply refuse all waste and by doing so they make it even harder to find proper disposal solutions for complex hazardous waste. Some shipping lines do accept waste under strict conditions and only via specialized booking agents that work with experienced people in the field that know how to safely load and secure hazardous waste cargo. In all cases acceptance of the hazardous cargo is in the hands of the DG (Dangerous Goods) department of a shipping line and the final decision is with the captain of the vessel who can refuse cargo in exceptional cases. The hazardous cargo needs to be very well documented, not only in writing, often pictures of the cargo and it's securing in the containers are required too.

Depending on the departure port temporary storage may be needed at the port between delivery of the cargo and loading it on the vessel. Also for this short term storage the warehouse needs to be licensed to store the waste.

Conclusion

Not including waste disposal in your project can cause serious delays and unexpected additional cost. Altogether a lot has to be planned and organised to timely and legally dispose of hazardous waste. If you need a helping hand, let me know!

One of the hot topics in the oil & gas industry is decommissioning, the vast amounts of old platforms, pipes and other installations and equipment that needs to be dealt with. A golden opportunity for many and a possible bottomless pit for others.

Initially expected to kick off for 2015, now more like 2018, maybe even later.

Forecasts of the business volumes are going wild and many market developers are drooling by the looks of them and so are their bosses. But the market is still in the powerpoint phase.

Service and construction companies in the peripheral of oil & gas see it as the replacement of revenues lost due to the downfall in the industry but the oil & gas producers are not eager to start while their income is at an all time low.

Massive vessels and scrapyards are built by the big players in the market and also many of the smaller companies see a change to get a share of this huge cake.

The owners of the installations are procrastinating to say the least and in the mean time looking for all possible ways to reduce the cost or even prevent scrapping at the scale originally foreseen.

As a garbage man I'm often asked about the waste aspects of decommissioning, the hazardous, mercury waste in particular.

Some players see enormous streams of hazardous waste containing mercury and other elements and are looking at setting up local treatment installations to deal with it.

As far as I'm concerned we don't even know what the waste stream will look like. Although it would be great to receive massive amounts of cleaning waste at our plant I really don't think it will happen. Nor do I see many local contenders in the decommissioning being successful in setting up and running treatment facilities.

Right now there are a handful of mercury waste treatment plants like Batrec in the world and they seem to be able to cope with the existing waste streams and they all will confirm that it's not easy to run such an operation dealing with highly toxic waste.

I fear a lot of environmental issues if in 5 years from now we will have a handful of mercury waste facilities in every country with a serious oil & gas industry.

In the mean time the influential lobby of the oil & gas industry is using the delay to find support for other, cheaper options to deal with the installations up for decommissioning. Who can tell? We may end up with a lot of artificial reefs, fish farms, naval bases or lunar observatories to mention a few silly options.

In short, the industry knew that there would come a time to take their installations away and that they are dirty, but nobody expected the oil price to be this low as it is now when it's time to pack up.

Not as many installations will be scrapped in the way we anticipate now and the waste streams are hard to predict in both volume and composition.

Looking at the number of companies that is after a share of the decommissioning market the competition will be very fierce and as a result the margins will be thin. Too many fishing in the same market that didn't even kicked-off.

Or is it causing more hazardous waste to be disposed of illegally?

The Basel convention was initiated in 1989 to make sure hazardous waste would not end up being dumped in developing countries. It creates a framework of definitions, rules and cooperation between authorities regulating the transboundary movement of hazardous waste.

The Basel convention should make it easy to move waste to a proper disposal facility and difficult to move it anywhere else. But in practice it doesn't always work out that way and many difficulties are encountered before hazardous waste can be moved to the right destination.

Following some examples of the hurdles that have to be taken based on almost a decade of moving hazardous waste.

Some definitions first

When we talk about waste we have a "waste generator" that is responsible for proper disposal of it's waste and remains that under the Basel framework until the "disposal facility" signs of for final disposal. In every participating country there is an "authority" that is responsible for the execution of the Basel convention. And there are other involved parties providing services or executing other regulations like shipping lines, booking agents, consultants, trucking companies, railroads, customs, other local authorities, etc.

Some of the difficulties encountered

Waste generators often have no idea where to go with their waste due to lack of information. In many cases the presence of hazardous elements is ignored to avoid the issue and the cost. You can always ignore what you don't measure or check and act surprised if caught. The best guarantee for proper waste disposal is the involvement of global operating companies with public traded shares. They can't afford negative press and the potential effect on share prices is insignificant compared to the cost of responsible waste disposal.

Authorities

Under the Basel framework you need permission from all involved authorities before you can start moving hazardous waste.

The country of origin

The application procedure starts with the authorities in the country of origin of the waste with the complete information package that can easily be over 100 pages of documents. In some countries the authorities have little or no knowledge about the procedure or try to exploit the occasion of a Basel waste movement application. As an example by demanding to audit the destination facility, whereas the destination facility is under responsibility of the authorities in the destination country and there is no reason under the Basel framework for them to audit this facility. It does however result in nice pictures on Facebook and considerable extra cost and wasted time for the waste generator.

The country of transshipment

Often there is no direct connection between the country of origin and destination. In such cases it's necessary to plan a transshipment where the cargo moves from one vessel to another. The issues here are that different countries and sometimes different ports have different rules and demands. Some countries, like Singapore for example require a local agent and a security deposit. The maximum duration of the cargo being in the transshipment port differs per port and country, 3 days, 7 days, 10 days, hard to plan with shipping lines.

The countries that the shipment passes through

This is when a ship is just visiting a port with your cargo on board. All these authorities need to give permission, but some never react. Contact data not up to date, a revolution or civil war going on, mailbox full, staff changes, department moved, etc. Some authorities require a payment, but don't send an invoice. Some react only by email, but require information only by fax or postal service.

The country of disposal

In the destination country it's not always clear what the responsible authority is. The Basel convention lists the national authority but in some countries part of the execution of the Basel convention is distributed to the province or state where the disposal facility is located and they are not mentioned anywhere.

All together a lot of difficulties before you have permission to start the actual process of moving waste. Time consumed in the application process is 3 months minimum to a year in some cases!

Shipping lines and logistic companies

Several incidents in the past years caused shipping lines and ship captains to become much more aware of their risks and liabilities. Some of these incidents involved hazardous waste and many shipping lines are refusing to transport waste by now. The ones that still accept have driven up the prices to insane levels and shipments can only be booked over a handful of specialized agents.

Hazardous waste is still ending up in wrong places!

Considering the amount of difficulties encountered in moving hazardous waste and the very few people that have enough knowledge and experience to complete the whole process it's obvious that a lot of hazardous waste still ends up where it shouldn't.

Solutions

How to make it easier and assure that more waste is arriving at proper disposal facilities?

Stronger coordination between the country authorities so that all have the knowledge, or access to it and all use the same rules and procedures. This should also include a reporting mechanism for discrepancies and methods of enforcement in case of violations of the rules.

Set up an automated system that facilitates the process of applying for permissions. In this system a waste generator or service provider logs on, provides the details of the intended waste movement, uploads files, etc.

Increase participation of other involved parties like shipping lines, specialized agents, service providers, consultants, waste generators, waste disposal facilities, etc.

Initiate a whistle blower option where cases of mismanagement of waste can be reported if necessary anonymous. The environment is everyones responsibility and it shouldn't be easy to mess with it.