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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities

Simon Pollard, Dave Purchase and Sue Herbert

Guidance Note: 25

8 November 2000

Title: A Practical Guide to Environmental Risk Assessment for Waste Management Facilities

Guidance Note 25 Version: 2

Approval Dr Jimi Irwin Distribution:

Signature

Date 8 November 2000

Environment Agency & External

A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2

Keywords: waste management licensing, environmental risk assessment Links to Duties and Powers: Environmental Protection Act Part II, sections 35(3), (4), (5), (8), 36(3), 37 & 42(1); Waste Management Licensing Regulations, regulation 19, Schedule 4, paragraphs 4(1)(a), 6. Public Domain References: see bibliography Internal References: see bibliography Contact Details: Simon Pollard, Risk Analysis Manager, National Centre for Risk Analysis and Options Appraisal, Steel House, 11 Tothill Street, London, SW1H 9NF; Tel: 020 7664 6832; Fax: 020 7664 6836; email: simon.pollard@environment-agency.gov.uk David Purchase, Regional Waste Licensing Manager, North West Region, P.O. Box 12, Richard Fairclough House, Knutsford Road, Warrington, WA4 1HG; Tel: 07768 276931; Fax: 01925 242209; email: dave.purchase@environment-agency.gov.uk Status: Environment Agency, External Acknowledgements: The Agency acknowledges contributions from the following in the preparation of Version 2: Agency staff: Dave Bliss, Ian Brindley, Karen Byrom, Charlotte Danvers, Bill Darbyshire, Steve Eland, Peter Elliott, Dave Fleming, Jan Gronow, Mike Harget, Jill Leather, Mark Maleham, Tony Marsland, David Parr, Brian Payne, Pandora Rene, Jonathan Smith, Mark Stringer and Howard Thorp. Industry the Environmental Services Association Risk Assessment Sub-group: Beth Bracewell (Sita), Pat Corker (Aspinwall), Francis Crozier (Entec), Lesley Heaseman (Chair) (M J Carter and Associates), Nick Holmes (ESA), Graham Peacock (Biffa), Jon Weetman (Shanks), Chris Young (WRc). The Agency further acknowledges the contributions and feedback received from Agency staff in the development of the Shell Licensing Kits and training in their use. This Guidance Note replaces Version 1 (issued as Version 1.1, Consultation Draft for Comment, 8 March 1999). The Environment Agency officers, servants or agents accept no liability whatsoever for any loss or damage arising from the interpretation or use of information, or reliance upon the views, contained herein.

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2

EXECUTIVE SUMMARY This document provides technical guidance to Environment Agency staff and to applicants on the practical environmental risk assessment tools that can be used in the waste management licensing process to assist in the design and operation of sites to prevent pollution. It should be used alongside the DETR/EA Guidelines for Environmental Risk Assessment and Management (DETR, Environment Agency and Institute for Environment and Health, 2000), that provide general guidance on the Agencys expectations of risk assessment work. It supports the Agencys Licensing Process, the Library of Licence Conditions and Working Plan Specifications and the Shell Licensing Kits that have been derived from the Library to apply to specific types of waste management facility. The tools described fit within the tiered approach to environmental risk assessment which is adopted by the Agency (Figure 1). The guidance is arranged in the following sections: 1. Introduction Introduces the concept and stages of environmental risk assessment. Describes the context and coverage of the principal guidance documents on environmental risk assessment as applied to waste management facilities, including this guidance. 2. The approach to risk assessment and risk management. Describes the source-pathway-receptor approach as the basis for risk assessment, and the risk assessment and risk management questions which are being asked and answered at each tier and stage of the assessment. Explains the relationship between risk assessment and risk management systems. Links this approach to options appraisal and cost benefit assessments, and to other permitting regimes for waste management installations (PPC permitting and Landfill Directive). 3. The use of risk assessment in waste management licensing. Describes the relationship between the tiered approach to risk assessment and risk-based licensing, based on the Agencys licensing tools the Licensing Process, the Library and the Shell Licensing Kits and the resulting products of the process the licence conditions and the working plan. Explains what an applicant should provide in terms of a risk assessment and working plan. Includes an Agency decision flowchart for the use of the Shells. 4. Developing the conceptual model. Explains the importance of good problem definition, and the development of a good conceptual model as the basis for a risk assessment, and how it is carried out and developed through Tier 1, 2 and 3 assessments. 5. Tier 1: Screening of environmental risks. Explains what Tier 1 screening assessment is, based on the source-pathway-receptor approach, and describes its use in the form of the Shell Risk Assessments which form the basis of the Shell Licensing Kits. Discusses the use of scoring in the rating and prioritisation of risks and risk management systems. 6. Tiers 2 and 3: Detailed environmental risk assessment. Outlines the types of detailed assessments which may be carried out under Tiers 2 and 3. The descriptions given of these techniques are not prescriptive, but summarise the general philosophy and approach of each technique. Examples of these approaches are given in the

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appendices. The approach described in this guidance allows for flexibility in selection of specific risk assessment tools, within the overall good practice framework described. Further information on the Agencys general approach to environmental risk assessment can be found in DETR, Environment Agency and Institute for Environment and Health (2000) and the references in the bibliography.

Figure 1: Tiered Approach to Environmental Risk Assessment and Management (after DETR, Environment Agency and Institute for Environment and Health (2000) Problem Formulation

* Stages w ith each t ier of Risk Assessment


Hazard Identification Identification of Consequences Magnitude of Consequences

Risk Prioritisation

Tier 1 Risk Screening *

Tier 2 Generic Quantitative Risk Assessment *

Tier 3 Tailored Quantitative Risk Assessment *

Probability of Consequences

Options Appra isal Economics Social Issues Technology Management

Significance of the Risk

Risk Management
Collect data & iterate processes where necessary

Tiered approaches to risk assessment allow application of tools in proportion to the complexity and priority of the risk. They also help in ensuring problems are properly defined and scoped out prior to the application of numerical methods. This is the approach promoted in the revised DETR/EA Guidance on Environmental Risk assessment and Risk Management (DETR, Environment Agency and Institute for Environment and Health, 2000).

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CONTENTS
1
1.1 1.2 1.3

INTRODUCTION............................................................................................................1
What is environmental risk assessment? ..............................................................................................................1 Scope and Context of this Guide............................................................................................................................1 Further information and guidance ........................................................................................................................2

2
2.1 2.2 2.3 2.4 2.5 2.6 2.7 2.8

THE APPROACH TO RISK ASSESSMENT AND RISK MANAGEMENT...........7


Introduction...............................................................................................................................................................7 The source-pathway-receptor concept as the basis for risk assessments.....................................................7 Options appraisal and risk management decisions......................................................................................... 10 Risk management measures for waste management facilities ....................................................................... 11 Primary and residual risk management ............................................................................................................ 11 The need to consider risk management measures for the site as a whole.................................................... 12 Where do costs and benefits fit in?..................................................................................................................... 12

Environmental risk assessments for licensing in relation to those for PPC permits and the Landfill Directive............................................................................................................................................................................. 13
3
3.1 3.2

THE USE OF RISK ASSESSMENT IN WASTE MANAGEMENT LICENSING 15


Risk assessment and waste management regulation ....................................................................................... 15

Environmental risk assessment questions for waste management licensing: stages, tiers, tools and techniques.......................................................................................................................................................................... 15
3.3 3.4 3.5 3.6 3.7

Waste management licences and risk-based conditions................................................................................. 16 The Library of Licence Conditions and Shell Licensing Kits ........................................................................ 17 The tiered approach in relation to the Library and Shells............................................................................. 18 What should an applicant provide?.................................................................................................................... 21 Licence conditions, risk assessments, risk management systems and working plans................................ 21

4 5
5.1 5.2 5.3 5.4 5.5 5.6 5.7 5.8 5.9

DEVELOPING THE CONCEPTUAL MODEL ........................................................23 TIER 1: SCREENING OF ENVIRONMENTAL RISKS .........................................27
Introduction............................................................................................................................................................ 27 Screening of environmental risks for waste management sites ..................................................................... 27 Shell Risk Assessments.......................................................................................................................................... 28 The source of environmental risks................................................................................................................... 29 Hazardous events and pathways......................................................................................................................... 30 Environmental receptors...................................................................................................................................... 31 The environmental risks that are assessed........................................................................................................ 31 The risk management systems that may be required, and default standards.............................................. 31 Site-specific variation from the default risk management requirements...................................................... 31 Scoring, rating and prioritisation of environmental risks......................................................................... 33

5.10

TIERS 2 AND 3: DETAILED ENVIRONMENTAL RISK ASSESSMENT...........35

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6.1 6.2 6.3 6.4 6.5

Detailed quantitative risk assessments............................................................................................................... 35 Tier 2: Generic Quantitative Risk Assessment ................................................................................................ 37 Tier 3: Tailored risk assessment........................................................................................................................ 37 Event and fault tree analysis................................................................................................................................ 38 The selection of appropriate data for tailored risk assessment..................................................................... 40

7 8 9

GLOSSARY....................................................................................................................41 BIBLIOGRAPHY..........................................................................................................44 APPENDICES ................................................................................................................46

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1 1.1

INTRODUCTION
What is environmental risk assessment? Risk assessment is a management tool that aids decision-making and which is used widely within regulation, business and finance. It involves the separate consideration of the likelihood and the consequences of an event, for the purposes of making decisions about the nature and significance of any risks, and how best to manage any unacceptable risks. It is an activity which is familiar to and performed by us all, albeit intuitively. Environmental risk assessment requires an understanding of the source of a hazard to, or from, the environment, the characteristics of an environmental receptor that may be at risk from that hazard, and the means, or pathway, by which the receptor may be affected by that hazard. Environmental risk assessment is fundamental to all phases of development of waste management facilities, from the strategic planning level through to the licensing of an individual facility (see the Environment Agency policy on the location and impact of waste management facilities given in Environment Agency, 2000j). At the strategic level, risk assessment informs decisions about land use, and subsequently underpins assessment of the environmental impact associated with the site location that is considered through the development planning process. In the context of waste management licensing, environmental risk assessment is used to enable the operator and the Agency to identify whether and what risk management options, or mitigation measures, are required to adequately prevent, control, minimise and/or mitigate the identified risks to the environment from that site. These measures are normally stipulated as licence conditions or in the working plan. Environmental risk assessment is essential for all waste management facilities and the risk information gained will be key to regulatory decisions made by the Agency and others.

1.2

Scope and Context of this Guide This Guide describes the current Agency approach and supporting tools for environmental risk assessment in waste management licensing. It explains the use of some practical tools that will assist licence applicants and Agency officers in carrying out and reviewing risk assessments, so that they can identify and define the engineered and operating systems that will be necessary and appropriate to ensure that any unacceptable risks are managed effectively. The Guide does not represent a specification for work, nor does it aim to be prescriptive or to set out how standards themselves are defined by the Agency. It should be used alongside other Agency licensing tools and guidance, taking into account relevant statutory and best practice guidance, to inform the decision-making process. Applicants have flexibility in their selection of specific techniques and professional judgement will be required of Agency staff and applicants as to what level of detail is required. Guidance on this is included. Whilst this Guide focuses on risk assessment for the licensing phase of development of a waste management facility, readers must bear in mind that, in the same way that licensing is not carried out in isolation from the outcome of the planning process, risk assessment for licensing should not be divorced from earlier risk assessments carried out for planning purposes. The principles and approach to risk assessment, described in this Guide, are equally applicable to risk assessment at the planning phase, although the level of detail of a

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2

risk assessment required at the licensing phase will often be greater. Risk assessment is an iterative, developing activity, and that carried out for licensing purposes should always build on and take account of earlier risk assessment findings. Table 1, based on that included in the Environment Agency policy on the location and impact of waste management facilities (Environment Agency, 2000j), provides a brief overview of the level of risk assessment typically required for the different phases of development of a waste management facility. This table is not intended to be prescriptive, but to indicate how the requirements of risk assessment change, and increase in detail, through the process of planning and developing a facility. Figure 2 develops this further to show that the focus of the risk assessment work (or effort) changes through these development phases from the macro scale where the interest is in land use and major issues such as site location, fundamental design principles, to the micro scale, where the effort is spent on ensuring that detailed design and operational matters are adequate.
1.3

Further information and guidance The Department of the Environment, Transport and the Regions (DETR) and the Environment Agency have produced a range of guidance to support the use of environmental risk assessment, both in general and also with specific application to waste management regulation. These will be of assistance to users of this document. The context and coverage of some of the principal documents is shown in Figure 3. The following documents are particularly noted. For those unfamiliar with the practical aspects and basic terminology of environmental risk assessment, the Environment Agency has produced a general document Introducing Environmental Risk Assessment (Environment Agency, 2000a). Information and general guidance on the tiered approach to environmental risk assessment and the practical considerations involved can be found in Guidelines for Environmental Risk Assessment and Risk Management (DETR, Environment Agency and Institute for Environment and Health, 2000). This Guide adopts and supports the principles described in the Guidelines. Guidance on risk assessment requirements for planning purposes is being developed by the Environment Agency (e.g. Environment Agency, 2000g). With respect to the specific requirements of Regulation 15 of the Waste Management Licensing Regulations 1994 (assessment of the impact on groundwater), the Agency has issued separate guidance (Environment Agency 1999a).

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Table 1 : Overview of waste management facility development phases and environmental risk assessment
DEVELOPMENT PHASE

KEY ISSUES CONSIDERED Site location Basic function (e.g. broad types of waste, overall capacity)

LEVEL OF RISK ASSESSMENT 1 Risk screening (Identify major hazards and receptors)

ASSESSMENT TOOLS Maps of location of major and minor aquifers (vulnerability maps) eventually locations of groundwater bodies under the Water Framework Directive; Catchment protection zones (e.g. Groundwater Source Protection Zone 3, Dee catchment); Floodplain maps; Statutory conservation zones (SSSI etc). As above, but all groundwater protection zones, mapped conservation areas etc. Scoping guidance.

PHASE 1: Strategic planning, e.g.: Waste local plans Mineral local plans

PHASE 2A: Pre-planning assessments scoping and screening assessments for Environmental Impact Assessment Regulations. PHASE 2B: Planning applications 2 ; and Stage 1 PPC applications (where appropriate)

Fundamental elements of design and operation.

Risk screening (Identify all hazards and receptors)

PHASE 3: Environmental authorisations 2 ; e.g. Waste management site licence, IPC, PPC

Operational principles, site layout, major construction elements e.g. type of landfill lining. Initial design without benefit of planning conditions. Detailed design taking into account planning conditions, formal feedback from Agency etc.

Tiered risk assessment on major elements of design, construction and operation. (Assess all pathways and impacts)

Site specific assessment site investigations, local mapping etc. Risk assessment guidance and tools (e.g. LandSim) Site specific assessment, as above. Risk assessment for waste management licensing (this guidance, Shell Risk Assessments and, for example, LandSim).

Review and/or identify all hazards and receptors Tiered risk assessment on detailed design, construction and operation. (Assess all pathways and impacts)

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Notes: 1. See DETR, Environment Agency and Institute for Environment & Health, 2000. 2. Planning applications and environmental authorisations may be progressed in parallel.

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Figure 2: Risk Assessment Effort related to Waste Management Facility Development Phases

Tier 3 Risk Assessment Tier 2 Licensing

Planning Application Scoping Assessment Macro Intermediate Scale of Analysis Micro Strategic Planning Waste Management Facility Development Phases

Tier 1

T3 Tier

T3

T3

T2

T2

T2

T1 Macro Micro Scale

T1 Macro Micro Scale

T1 Macro Micro Scale

STRATEGIC PLANNING
Legend:

PLANNING

LICENSING

Risk Assessment Effort Scale: Macro Intermediate Micro e.g. Site location, basic function e.g. Site layout, major construction elements e.g. Material specifications, operation details

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Guidance on risk assessment requirements for planning purposes DETR, Environment Agency & Institute for Environment and Health, 2000. Guidance on Environmental Risk Assessment and Risk Management. Guidance on specific risk assessments supporting the use of the Library DETR statutory guidance relevant to risk assessment Environment Agency, 1998. Interim Framework Policy for Landfill Engineering. Environment Agency, 1999. Interim Internal Guidance on Interpretation and Application of Regulation 15. Environment Agency, 1999b & 2000c. Library of Licence Conditions and Working Plan Specifications. Department of the Environment, 1994a. Circular 11/94; Department of the Environment, 1995. W aste Management Paper 26B.

Generic guidance on principles of environmental risk assessment for public domain environmental risk assessments

Environment Agency, 2000g (in preparation). Scoping Guidance on the Environmental Impact Assessment of Projects.

Leaflet introducing general principles for non-specialists

Environment Agency, 2000a. Introducing Environmental Risk Assessment .

Environment Agency, 2000. A Practical Guide to Environmental Risk Assessment for Waste Management Facilities (GN25) (this guidance).

Translation of general principles to waste management licensing

Environment Agency, 2000d. Shell Risk Licensing Kits: Guidance on their Derivation, Content and Use. Environment Agency, 2000d. Individual Shell Risk Assessment packs for selected site categories from the range A1-A25.

Framework and guidance for application of risk assessment in use of Library

Guidance on the use of simple risk assessment templates for standard sites

Simple risk assessment templates for standard site categories

Site-specific risk assessment for waste management site: operators document, which may be produced from agreed template, or modified with more detailed assessment

Site-specific risk assessment for waste management site (Not guidance. Document supplied to Agency in support of application, or by Agency in support of Agency modification)

Figure 3: Context and coverage of principal guidance documents on environmental risk assessment as applied to waste management licensing

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2 2.1

THE APPROACH TO RISK ASSESSMENT AND RISK MANAGEMENT


Introduction Environmental risk assessment and risk management typically involves answers being sought to the following questions: What environmental hazards are present and what are their properties? How might the receptors become exposed to the hazards and what is the probability and scale of exposure? Given exposure occurs at the above probability and magnitude, what is the probability and scale of harm? How significant is the risk and what are the uncertainties? What needs to be done to prevent, control or minimise the risks?

The Agency adopts a tiered approach to answering these questions, in accordance with good practice, which is described in its general guidance on environmental risk assessment and management (DETR, Environment Agency and Institute for Environment and Health, 2000). This is outlined in Figure 1, and indicates that assessment and appraisal effort should be targeted where risks or uncertainties are high. Early risk screening and prioritisation avoids unnecessary detail and allows the level of approach to be matched to the needs of the problem. If the risk management decision cannot be made based on an initial screening assessment, then more detailed approaches are used, focusing on the key risks identified. The emphasis is on: i) understanding the environmental setting; ii) using simple, qualitative tools; and iii) applying greater levels of sophistication according to need. However, it is important that all risk assessments, whether simple or complex, are carried out in a robust, systematic and transparent manner.
2.2

The source-pathway-receptor concept as the basis for risk assessments Fundamental to the good practice framework for risk assessment shown in Figure 1 is the source-pathway-receptor approach. For a risk to exist, there must be an identified or plausible relationship between the three individual components of: source i.e. the hazardous substance or material receptor i.e. the entity (e.g. human, water body, ecosystem, building, etc) that is vulnerable to the adverse effects of the hazardous substance or material pathway i.e. the mechanism by which the receptor and source can come into contact (e.g. by a hazardous event or action on site giving rise to a release of the hazardous substance or material to atmosphere or to ground).

The source for waste management facilities is defined by the hazardous properties of the waste types and operations to which they will be subjected on the proposed site. (It may also include the events which lead to the hazards associated with those wastes and/or operations being transferred into the environment, although, as used in this guidance, it is more

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 appropriate to link such hazardous events with the pathways by which the hazards are transferred.) The environmental receptors (or targets) are those entities which are liable to be adversely affected by the identified hazards transferred from the defined source into the environment by the identified pathways. These include, but are not necessarily restricted to: People outside the site boundary. (People within the site boundary are only considered where they may be trespassers or others who have gained unauthorised access site security requirements are imposed to prevent this situation occurring. People who are legitimately on site - including site staff and other people who are authorised or doing other legitimate business - are covered specifically by the Health and Safety at Work Act 1974 and are not considered in the environmental risk assessment); Properties outside the site boundary, including public and private property and places where the public have access this may also include livestock or other animals which are kept (rather than wild) outside the site boundary (or within the site boundary); Ecosystems, especially habitats designated in accordance with the Habitats Directive, and other designated sites; Surface water in the vicinity of the site; Groundwater in the vicinity of the site; Atmosphere, which is a receptor in regard to the risk of global warming. The pathways for a defined source of environmental hazards are the means by which the identified hazards are transferred into the environment, and thence to any defined receptors in the environment. Hazardous events and the pathways by which the resulting hazards are transferred into the environment are intimately linked. They include the following environmental pathways: Direct emissions of heat and shock due to fire or explosion; Releases of polluting emissions by one or more of the following routes: - air (or atmosphere) as pathway (it may also be a receptor for certain risks see below); - ground (including via services); - water (surface water and groundwater are receptors in their own right see below); Other vectors for environmental hazards: - dust - pests; - scavengers; - litter; - noise. If humans (or animals) are exposed to hazardous substances or emissions via one or more of the above environmental pathways, harm to their health may occur through a number of exposure pathways. Typically these may include: inhalation or ingestion of, or dermal contact with, hazardous substances; and the direct effects of heat and shock in the case of fires or explosions. Humans may also suffer harmful effects on health through serious detriment to the amenity of their locality. The type and magnitude of the harmful effects will depend upon the dose received, the particular dose-response relationships for those hazardous substances, and other more

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 specific factors such as the sensitivities of the individuals. The resulting effects on health may be direct or indirect, acute or chronic. The assessment of the risks of harm from exposures to hazardous substances and emissions is very complex and subject to wide variability between individuals. It is not specifically considered except in some more detailed and complex Tier 2 and Tier 3 risk assessments, although it may form the basis of certain environmental quality criteria or targets. In Tier 1 and many Tier 2 and 3 assessments, it is sufficient for the assessment to identify whether or not a significant exposure of identified human or animal receptors is likely to occur, in order to decide whether or not risk management measures need to be provided. Box 1 provides an example of the source-pathway-receptor approach for a landfill generating landfill gas. Box 1: Example of source-pathway-receptor approach. Consider the case of methane gas emanating from an active landfill site. Methane represents an explosion hazard between certain defined concentrations in confined spaces. Methane emanating from the source (the active landfill site) at sufficient pressure poses a high risk of harm (injury, loss of life and damage to property) to receptors in the vicinity of the site (persons and buildings) where the likelihood (or probability) of concentrations building up to the lower explosive limit is high, due to the presence of suitable environmental pathways for landfill gas migration and ingress into buildings (such as permeable ground strata or manmade drains, conduits, etc). The source in this example is the biodegradable, methanogenic waste within the landfill site, which is generating methane gas. The potential pathways are the permeable ground strata, or manmade drains, conduits, etc, around the landfill site. The potential receptors are the buildings and their occupants in the vicinity of the site. If the risk assessment identifies that the risk exists from methane to nearby housing, the Agency will stipulate in the licence conditions that the operator provides and maintains specified systems to manage the identified risks from landfill gas emanating from the site; for example, that they: a) provide, operate and maintain a landfill gas management system that meets defined design and performance standards (for example, this may include a membrane around the waste to contain landfill gases, a landfill gas collection system, and a landfill gas flaring or energy recovery system); and provide monitoring points and boreholes for landfill gas around the site in such positions that landfill gas migrating through the ground strata from the site can be detected; and carry out a defined programme of monitoring landfill gas at those monitoring points, including analysis and reporting of the results and the carrying out of defined actions if the measured levels of landfill gas exceed defined values.

b)

c)

The operator will then provide the necessary information on the systems that they will provide and maintain to meet these requirements, in their working plan and other supporting documentation.

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If it can be shown for a particular site, that there is no plausible connection or pathway between potential releases from a specified hazardous source (e.g. a specified treatment operation being carried out on specified wastes with one or more environmentally hazardous properties) and environmental receptors which are known or expected to exist in the vicinity of the site, then the situation cannot be considered to present a risk as there is no realistic source-pathway-receptor relationship. A decision that a realistic source-pathway-receptor relationship exists does not always mean that there must be firm evidence of the presence of all three components: source, pathway and receptor. However, it must be evident that the source has hazardous properties that have the potential to adversely affect the receptors in question. Furthermore, the presence of the receptors must be proven or be a realistic possibility. It may not always be possible to prove the presence of a pathway linking the two, but again this must be a realistic likelihood rather than a theoretical possibility. In making decisions about source-pathway-receptor relationships for waste management facilities, the Agency will give consideration to being precautionary in the light of expected changes and events over the lifetime of the facility, which may result in the nature of the relationship changing with time. Decisions will be made on a site-specific basis, bearing in mind the need to be both proportionate and precautionary. If a plausible source-pathway-receptor relationship is identified for a particular site, this will normally be taken by the Agency to demonstrate the need for appropriate risk management measures to prevent the anticipated risks being realised. In many cases, robust decisions about the presence of a plausible source-pathway-receptor relationship will be sufficient for decision-making about the need for risk management measures. It may not be necessary, desirable or cost-effective to resort to more detailed quantitative assessments of the probability and scale of risks involved, except in cases (such as the design of landfill liner systems) where it may be necessary to enable detailed design of the risk management measures. This is the basis of the tiered approach to risk assessment shown in Figure 1, that the level of effort put into assessing risk reflects the priority of the risk and how any risks would be dealt with. For many waste management facilities, it will be more appropriate to put most effort into design and management of the facility, provided that robust initial decisions are made about source-pathway-receptor relationships. Guidance on Tier 1 risk assessments (and the use of the Agencys Tier 1 Shell Risk Assessment tools) is given in Chapter 5, and on Tier 2 and Tier 3 assessments in Chapter 6.
2.3

Options appraisal and risk management decisions The purpose of carrying out an environmental risk assessment is to inform a risk management decision; that is, to determine what risk management measures need to be taken to prevent and control the identified risks. There may be more than one way of managing the identified risks, and the decision as to which is the best option may need to be informed by an appraisal of their relative costs and benefits. Waste licensing decisions include a qualitative consideration of likely costs and

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 benefits through the application of the test of reasonableness, and this is discussed in more detail in section 2.7. The applicant or operator will normally have assessed the different design options for a given facility at the stage of conceptual/outline design, prior to their licence application. The decision on whether the proposed waste management facility represents the best practicable environmental option (BPEO) will generally be made at the planning stage. Where a detailed options appraisal is required at this stage it may need to take into account relevant factors of technology, economics, social issues and management. This document does not include guidance on such detailed options appraisals, since these are generally not required for the purpose of preparing licence conditions. If there are circumstances where a detailed options appraisal is required at the licensing or modifications stage, then specialist guidance should be sought. As with the tiered approach to risk assessment, the approach taken should be proportional to the outcome, meaning that the resources required to undertake the options appraisal should not be disproportionate to the costs and benefits of the decision.
2.4

Risk management measures for waste management facilities Detailed guidance on the risk management measures covered by specific licence conditions and working plan specifications is given in the Library of Licence Conditions and Working Plan Specifications (Environment Agency, 2000c) and in the Shell Licensing Kits which are derived from it (Environment Agency, 2000 d). (These are described in section 3.4.) The complexity of the measures needed will depend upon the type and level of risks that the waste management operations in question present to the environment. The measures needed to prevent and control the risks may be relatively simple, such as operational procedures requiring simple actions and documentation, or relatively complex, such as engineered systems requiring fully documented and quality assured stages of design, construction, testing and validation, operation and maintenance. An example of the former would be waste acceptance and control procedures for a transfer station handling inert, non-hazardous or low hazard, non-special wastes. An example of the latter would be the systems underlying the provision of an engineered site liner for a landfill, or of a groundwater monitoring programme for a landfill. These will place different levels of demand on supporting systems such as record-keeping, and the training and competence of site staff. If the risk management provisions (simple or complex) are to be effective, they must be specified and carried out to an appropriate and auditable standard. Risk management provisions to prevent emissions to the environment will usually consist of a combination of operational procedures and controls, engineered containment of emissions, and, as relevant and appropriate, monitoring of emissions with actions to control and minimise any emissions that do occur.

2.5

Primary and residual risk management It is important to recognise that, where risk management measures are provided, there remains a risk that these will fail to perform to the required performance standard. This is

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 referred to in the Library and Shell risk assessment approaches as the residual risk; that is, the risk to the environment posed by the identified hazard, taking into account the primary risk management measures that will be provided. Such failures can occur due to faults in design, installation, and operation (including maintenance). The causes of faults and failures may include failures in hardware, software, and procedures; and will often include an element of human error. It is essential that provision be made to minimise the likelihood of residual risks so as to ensure that the required standard of environmental protection is realised throughout the life of the site. The necessary residual risk management should be provided so as to prevent such failures giving rise to significant functional failure of the primary risk management system under consideration. Typically, this will be provided by the following measures: during the design stage, through the site investigations and risk assessments supporting the design process, the use of recognised design standards, and adherence to a formalised design quality assurance process; during the installation stage, through adherence to a formalised construction quality assurance process, supported where appropriate by a testing/commissioning stage; during the operational stage, through adherence to documented operational procedures and maintenance programmes, supported by: - monitoring of the process performance and emissions; and - documented procedures for dealing with deviations from defined performance and emission standards; and - periodic reviews of performance against the environmental emission standards and of the environmental risk management systems for the site.
2.6

The need to consider risk management measures for the site as a whole It will be evident from the preceding discussion that risk management measures, both for the site and for particular operations, should be regarded as an integrated whole. A change to one part or element of the system, such as the design standards, or the quality and content of record-keeping, or the training and competence of staff, will potentially change the effectiveness or performance of the risk management system as a whole. This means that any proposed changes to any part of a risk management system should be assessed for their effect on the overall performance of the risk management measures, to ensure that the necessary standards of environmental protection are maintained for that system and for the overall site operations. This is the reason that the licence conditions set a requirement for proposed changes to the working plan to be supported by a review of the relevant risk assessments, and to be prenotified to and, where necessary, approved by the Agency before implementation.

2.7

Where do costs and benefits fit in? Under Section 39 of the Environment Act, the Agency has a duty to take account of likely costs and benefits in deciding whether or not to exercise its powers, and in deciding how to exercise those powers. It is important to note that this duty: i) does not supersede the Agencys obligations to discharge specific duties, comply with legal requirements or meet objectives; and

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 ii) does not require the consideration of costs and benefits to involve their quantification or moneterisation.

In its waste licensing decisions, the Agency has a duty to prevent pollution of the environment, harm to human health and serious detriment to amenities of the locality. Licence conditions prepared using the Library or Shells are aimed at satisfying this duty and meeting the statutory guidance (Department of the Environment, 1994a) which states that conditions should be: proportionate in their requirements to the risks involved and the benefits to be obtained; goal-based, having defined objectives and specified standards and, where appropriate, specifying the means to their fulfilment; but should not: serve as an end in themselves; be over-prescriptive; or impose an unjustifiable or disproportionate burden on the licence holder, especially small businesses. Risk management offers the benefit of risk reduction, so risks can be characterised with reference to the costs of implementing measures to mitigate them. A level of judgement on the test of reasonableness is therefore required on the part of the regulator when preparing licence conditions, and also when preparing subsequent licence modifications.
2.8

Environmental risk assessments for licensing in relation to those for PPC permits and the Landfill Directive The Pollution Prevention and Control (England and Wales) Regulations 2000 (SI 2000 No. 1973) came into force on 1 August 2000. A number of types of waste management installations, as defined in Chapter 5 of Schedule 1 of the Regulations, will need to be regulated under the PPC regime instead of the waste management licensing regime. Existing licences for these types of installations will be replaced by PPC permits in accordance with the programme defined in Schedule 3 to the Regulations. As such, these installations will then be subject to assessments of whether they satisfy the requirements of the best available techniques (or BAT) criterion, as defined in Regulation 3. The Agency is currently developing guidance on an assessment methodology (the E2 guidance and methodology) for this purpose. This will be developed, so far as practicable, to be consistent with the relevant related methodologies under planning legislation (EIAs) and the Control of Major Hazards (COMAH) Regulations. It will incorporate: i) a stage to assess and compare options, to determine the best practicable environmental option (BPEO) for a proposed installation, consistent with the planning stage; and ii) an environmental impact assessment stage to determine, for those options where the technical standards for BAT are not defined or else an alternative is sought, whether the preferred option satisfies the BAT requirement. Consistent with the Agencys tiered approach and the approach for waste management licensing covered by this guidance, the PPC E2 approach will incorporate screening assessments as a basis, although it may be that, due to the nature of the requirements under

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 the PPC regime, this will lead to a greater degree of use of detailed technical assessments of the Tier 2 and Tier 3 type. This is not likely to significantly affect the guidance given in this document for those sites which remain within the waste management licensing regime. The EU Landfill Directive comes into force on 16 July 2001, and is expected to be introduced in England and Wales through the PPC regime. All landfills will be required to adhere to new requirements regarding their design and operation, and over a period of time all landfill waste management licences will be replaced with PPC permits that comply with the Landfill Directive requirements. The Agency is developing further guidance on risk assessment requirements for landfills under the Landfill Directive and this document will be revised, as appropriate, in due course.

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2
3

THE USE OF RISK ASSESSMENT IN WASTE MANAGEMENT LICENSING


Risk assessment and waste management regulation The siting, operation and decommissioning of waste management facilities carries certain risks that are assessed at various times within a facilitys life, from design through construction and operation to decommissioning and licence surrender. Environmental risk assessment can be applied at the following stages: at the strategic planning, pre-planning and planning stages (through submission of environmental impact assessments and environmental statement s, including risk assessments; if detailed options appraisals are necessary they will usually be carried out at these stages); during the process of waste management licensing (through the use of the Library and Shells, and including requirements for a Regulation 15 assessment) (this process may be carried out in parallel to the planning application); during the site supervision stage (through the use of the Agency Site Inspection Methodology and the use of the Operator Pollution Risk Appraisal (OPRA for Waste) technique for prioritising inspections on a risk assessment basis these are complementary to and consistent with the Library and Shell risk assessment tools) prior to modification of the licence or amendment of the working plan, resulting from changes to operation (through the use of the Library and Shells, and including requirements for a Regulation 15 assessment); and prior to site completion/closure and licence surrender (through the Licence Surrender process, using the supporting risk assessment guidance for that process). Procedural and technical guidance is provided by the various waste management papers and Agency documents, to which readers are referred. The scope and methodology of the risk assessment will be dictated by the specific requirements of each stage and the purpose for which the assessment is being carried out. While it should not automatically be presumed that a risk assessment undertaken for one stage will necessarily be adequate for another, there will usually be a degree of overlap, and opportunities should be taken to make use of valid and reliable assessments of risks which have been produced at earlier stages and which are of relevance to waste management licensing. In particular, the potential to screen risks during any environmental impact assessment (EIA) carried out at the planning stage should be regarded as a valuable opportunity to undertake work of relevance to licensing the site. Similar opportunities should be sought through the preparation of site-specific risk assessments supporting a Regulation 15 assessment for facilities where List I and II substances are of relevance.

3.1

3.2

Environmental risk assessment questions for waste management licensing: stages, tiers, tools and techniques Environmental risk assessment for waste management licensing should not be carried out either for its own sake or in isolation, but in order to assist the making of risk management decisions in a cost-effective manner. The practical objective is to provide answers to the questions of:

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 i) what risk management measures are required for a particular site; and hence ii) what needs to be specified in the licence conditions and described in the working plan. Appendix 1 provides a breakdown of these into the following questions:
A. What is the nature of the site (including the waste management operations) and its environmental setting? B. Is there a risk to the environment from the waste management operations on this site? B1. What hazards are present and what are their properties? B2: What are the potential environmental consequences that may arise from the identified hazards? B3. What is the magnitude of the consequences for the identified potential receptors? B4. How might the receptors become exposed to the hazards? B5. What is the probability of the hazard occurring? B6: What is the probability of the receptors becoming exposed to the hazard? B7: What is the probability of harm resulting from exposure to the hazard? B8. How significant is the risk? B9. What are the uncertainties? (Is a more detailed risk assessment needed?) C. What are the options for management of the identified risks? D. What needs to be done to minimise the environmental risks?

E. Does the risk assessment need to be reviewed or revised?

The table in Appendix 1 indicates how, in addressing these questions: a) the tiered approach to risk assessment and the identification of appropriate risk management measures would be applied at Phase 3 (Environmental authorisation: waste management licensing see Table 1); and b) hazard identification, risk assessment and identification of appropriate risk management measures would be carried out using the tools and techniques appropriate for waste management licensing, The table includes an example of how a Shell Risk Assessment approach would be applied (as explained in the following sections and Chapter 5) in the case of a waste transfer station handling household, industrial and commercial wastes, for the particular hazard of wastes which are likely to produce emissions of dust to atmosphere.

3.3

Waste management licences and risk-based conditions A waste management licence is issued with conditions attached. The conditions relate to the activities the licence authorises; and the precautions to be taken and/or works to be carried out in connection with, or in consequence of those activities. Requirements may therefore be

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 imposed in the licence, to be complied with before the activities authorised by the licence have begun, or after they have ceased. The objective of a waste management licence is to ensure that the licensed facility does not cause either pollution of the environment or harm to human health and does not become seriously detrimental to the amenity of the locality. The Agency aims to set licence conditions which specify (to the level of detail necessary to meet this objective) the risk management provisions and the standards they must meet. It is a basic requirement of waste management licensing that licence conditions should be specific to the site in question. This does not obviate the use of templates, or the use of benchmark requirements for typical sites as default standards, provided that the process is supported by a risk assessment of the sources, pathways and receptors of environmental risk for the site in question in relation to its specific environment. Use of the Library and Shell tools enables the Agency to set licence conditions based on the assessed environmental risks at the specific site in question. The licence conditions will require an appropriate type and level of engineered and operational systems to be provided that will prevent, control and minimise those risks to acceptable standards.

3.4

The Library of Licence Conditions and Shell Licensing Kits The Library provides tools for: the production of risk-based site-specific licence conditions, based on the use of Library Condition Templates; and the production and assessment of working plans, based on the use of Working Plan Specifications. Licences drafted using the Library and this guidance contain a customised set of conditions reflecting the environmental risks identified from a site-specific risk assessment. However, the Library is a complex tool applicable to the full range of waste management operations that span the whole spectrum of environmental risk. The work involved in preparing, assessing, consulting and finalising the site-specific risk assessment, the working plan and the licence conditions, can be complex and demanding on resources. As experience of using the Library and the Licensing Process has grown it has become apparent that there are opportunities for streamlining the process. As a consequence Shell Licensing Kits are being developed and issued in order to provide optional starter packs for typical sites in certain categories falling within the Agencys site classification system (A1 to A24). This classification is currently used by the Agency for waste management licensing process records and Agency OPMs, for the site inspection methodology and OPRA for Waste, and for waste strategy site classifications. Each Shell Licensing Kit is intended to stand alone, without recourse to the Library or its supporting guidance unless necessary for particular issues. Each kit includes, specific to the category of site covered: Guidance notes on the derivation, content and use of the Shell Licensing Kit. A Shell Risk Assessment pack, based on a generic Tier 1 screening risk assessment for a typical site in that category, which is used by the applicant to produce a risk assessment

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 which is specific to their proposed site, and which identifies the risk management provisions that will be required and will be described in the working plan. (The structure of the Shell Risk Assessment is discussed in more detail in Section 5.) A specification of the information needed in the working plan for a typical site in that category (based on the Shell Risk Assessment), which is used by the applicant to produce the site-specific working plan, describing the risk management systems that will be provided on the basis of the site-specific risk assessment. A template of the licence conditions for a typical site in that category (derived from the relevant Library condition templates), which is used by the Agency to prepare the sitespecific licence conditions, taking into account the applicants site-specific risk assessment and working plan.

The Shell approach permits a degree of flexibility in how the specified standards can be delivered. In producing site-specific conditions, variations from the shell licence template can be accommodated provided that they are justified on the basis of the site-specific risk assessment and recorded in the audit trail documentation. This will provide the necessary support for the resulting site-specific licence. Each site/application will still require individual decisions to be made specifically in respect of it. However, properly used, shell licensing kits will enable significant streamlining of the risk assessment and licence drafting processes. They will also assist in ensuring that operating standards required for sites of the same type are consistent, whilst still allowing licences to reflect site-specific differences, e.g. in risk management requirements.
3.5

The tiered approach in relation to the Library and Shells The Library of Licence Conditions includes an Index of Library Conditions, which provides a tabular framework, based on the type of facility and the waste management operations, for identifying: the Library Condition templates which will need to be included in the licence; and for risk-based conditions the risk management provisions which the condition will cover in its requirements; and the level of risk assessment which is required for the site. Application of the Library risk assessment framework allows for the fact that a comprehensive risk assessment for any single waste site may require more than one tier of approach, according to the issues under study. This allows for an increasing focus on those aspects of the facility that present a higher risk and may require more detailed assessment. The framework does not prescribe the risk assessment tools that should be used within each tier, but does suggest the applicability of Tier 1-type screening tools, and more detailed Tier 2-type generic and Tier 3-type tailored risk assessments based on quantified modelling techniques (refer to Figures 1 and 2). The framework indicates a level of risk assessment that would normally be required but it is recognised that site-specific issues may override and place more onerous requirements on specific installations. Application of individual risk assessment tools within the overall framework is at the discretion of the applicant. Figure 4 shows how the use of the Library and Shell Kits fits into the Agencys tiered approach to risk assessment (as outlined in Figure 1). The Agency decision process for using Shell Licensing Kits in processing an application is shown in the flowchart in Figure 5.

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2

Review of site design and operation, where necessary

Pre-application tools: Development of conceptual model, and scoping of site design, operation, & environment (some of this will have been carried out during the statutory planning process)

Risk assessment tools Tier 1: Risk screening assessment (using Shell Risk Assessment pack where available)
Need to compare risk management options Deviations from Shell Risk Assessment; &/or need for detailed quantitative assessment

Ranked risk management options

Risk scoring, ranking & prioritisation (see section 5.10)


Ranked risk management options

Tier 2: Generic quantitative RA


Complex risks

Tier 3: Tailored quantitative RA

Iteration and review of risk assessment or risk management standards, where required

Risk assessment outcome : Site-specific risk assessment


Default risk management standards Tailored risk management standards

Use of Shell Licensing Kit tools: Shell Licence Template; Shell Working Plan; Shell Financial Provision Assessment; Shell Audit Trail.

Sitespecific variations, where required

Use of Library tools: Licence Condition Templates; Working Plan Specifications ; Financial Provision Assessment; Library Audit Trail.

Licence and working plan preparation output: Site-specific: Risk management systems; Working plan; Licence conditions; Financial provision assessment; Licence conditions audit trail.

Figure 4: Tiered Environmental Risk Assessment Approach applied to Waste Management Licensing

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2
2

Pre-application discussions

Agency Decisions
Has a Shell Kit been issued to cover this type of site? Yes No

Agency Actions
Use Library of Licence Conditions & supporting guidance Follow full process for use of Library

No

Does the applicant/operator want to follow the Shell Licensing Kit for this application? Yes Provide applicant with copy of appropriate Kit and explain its use

Application received
Assessment of application Shell Risk Assessment pack Does the risk assessment completed by the applicant/operator (Section 2 of the pack) fit the site and proposed operations? Yes Do the risk management system standards accepted or proposed by the applicant/operator (Section 2 of the pack) provide the necessary level of environmental protection? Yes Assessment of application Shell Working Plan Does the working plan provide the necessary information in the necessary form? Yes Drafting of licence conditions Shell Licence Template Do the Shell licence conditions require site-specific variations (other than the standard inserts)? No Finalising licence conditions Shell Audit Trail Finalise and quality assure licence conditions, and complete audit trail No Do the applicants financial provisions give the necessary level of cover? Yes Yes No No No

Completion of the following actions should, subject to satisfactory outcome, be followed by returning to the Decision chain
Identify relevant deviations from fit; As appropriate (see guidance) either carry out or require operator to carry out risk assessment to necessary level of detail Identify relevant site-specific standards; As appropriate (see guidance) either provide or require operator to provide justification for site-specific standard

Identify necessary amendments; Require operator to provide amended working plan section(s)

Identify necessary variations; Carry out justified amendments; Use Library Condition Templates for any justified additional conditions; Record changes in audit trail

Assessing financial provision Shell Financial Provision Assessment

Identify necessary amendments; Require operator to provide amended financial provision

Process financial provision

Figure 5:

Decision flowchart for the use of Shell Licensing Kits in applications

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2

3.6

What should an applicant provide? The Agency requires a specific risk assessment to be submitted for all applications for a waste management licence. This must be developed according to the principles and good practice set out in this guidance and must be site-specific. The Agency expects applicants will wish to work through the tiered approach outlined in Figures 1 and 4, using the Library risk assessment framework or, where a Shell Licensing Kit is available, the relevant Shell Risk Assessment tool. It is expected that risk assessments undertaken in support of Environmental Impact Assessments (EIAs) and the relevant planning application will be used to inform this process, where they have been carried out. The degree of sophistication of the risk assessment should reflect the particular conditions of the site. However, all environmental risk assessments should be based upon reasonable scenarios, data and assumptions. The development of a clear conceptual model (see Section 4) is critical to the analysis. Tier 1 risk screening assessments may be sufficient where these give a clear demonstration of the anticipated level of risk and that the proposed risk management provisions are fit for purpose, giving the required standard of environmental protection (see Section 5). This may include, where justified, an assessment that the hazard and associated risks are so insignificant, that they do not require prevention, control, or monitoring. (The available Shell Risk Assessments have been developed to fulfil these requirements for the categories of site to which they apply see Section 5.) The output of the Tier 1 assessment should be a statement with justification, of the risks identified and a specification of appropriate risk management provisions. The statement should include details of any significant uncertainty or disagreement over the required standards or their justification, and proposals for resolving these. Where a Tier 1 analysis provides insufficient understanding of the risks, a Tier 2 or Tier 3 assessment should be carried out, as appropriate (see Section 6). The output should be a description of the identified risks according to significance, identification of those risks requiring control or reduction and details of the proposed risk management measures. It should provide sufficient understanding of the contributing factors to establish the various options for managing the risk (see Figure 1 and section 2.3).

3.7

Licence conditions, risk assessments, risk management systems and working plans In licence conditions prepared using the Library or Shells, Condition 1.1 sets limits for the waste management operations that may be carried out on the site under the licence, and condition 1.2 sets limits on the wastes that may be received on the site and subjected to those operations, in terms of the types of waste and their environmentally hazardous properties. The specification of the operations and of the waste types and hazards, taken together, characterise the source of the risks to the environment that will be posed by the site. They therefore determine the measures that will be necessary to prevent and manage those risks to the environment, and the scope of the other licence conditions that will be necessary. Those other licence conditions will define the risk management systems that must be provided by the operator, and will set the performance standards that those systems must meet. The

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 working plan will therefore need to describe the site operations and risk management systems to a level of detail that shows, clearly and convincingly, that those requirements and standards will be met. The licence conditions and sub-conditions prepared using the Library or Shell templates will fall into two basic types: conditions that set absolute standards which include specifying the means by which they shall be achieved; and conditions that set a standard but specify the means by which it shall be achieved by including a reference to specified section(s) of the working plan. Although the working plan is produced by the operator and is their document, those sections specifically referenced in the licence conditions become an operational and enforceable part of any licence issued. The Agency therefore approves those referenced sections of the working plan prior to the issue of a licence. The licence conditions will also include: a general requirement that any proposed changes to those referenced sections of the working plan must be supported by an assessment of their effect on the environmental risks of the site, and notified to the Agency before they are implemented; and a specific requirement for those sections of the working plan which are identified as describing environmentally significant risk management provisions, that the changes are approved by the Agency before they are implemented.

The environmental risk assessment of the site therefore becomes a living document which is kept under review throughout the life of the site.

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2

DEVELOPING THE CONCEPTUAL MODEL


Fundamental to environmental risk assessment is the problem definition (or formulation) stage, which enables a clear picture to be established of the site and its environment, based upon the nature of the site (including the wastes to be received and handled, and the waste management operations to be carried out) and its environment al situation (including the potentially vulnerable environmental receptors in the vicinity of the site). Irrespective of the tier of the assessment being undertaken, the first key steps are to identify the hazards and consequences that might arise. The hazards for a waste management facility can be readily identified from knowledge of the types of wastes to be accepted and the processes they will undergo at the facility, be they treatment, storage, disposal, etc. Then, it is critical to have an understanding of the circumstances of exposure what or who is exposed to which hazards and by what means; i.e. the receptors and the pathways. The assessor should draw a picture of the site and its environment, which will enable them to identify and analyse: the sources of environmental hazard that the site will present during its operations; the potential events and pathways by which the environment will be exposed to those hazards; the potential receptors or targets who will be impacted by those hazards; and the potential consequences to or effects upon those receptors or targets.

This will usually be achieved by literally sketching out and then refining drawings and plan(s) of the site, which show the proposed, or existing, waste management facility and its environment. This will enable the assessor to develop a valid and reliable model (a conceptual model) of the site, its hazards and its environment. The model may be based solely on plans and/or diagrams, but will more usually include a table or spreadsheet which identifies the sources of environmental hazards that the site will present, the potential pathways and the potential receptors, and helps the assessor to screen and assess the environmental risks with confidence. (DETR, Environment Agency and Institute for Environment & Health, 2000.) The plans, diagrams and models will be progressively developed through the Tier 1 screening assessment, and may be further refined, by data collection, for example, to support detailed quantified assessments at Tier 2 and Tier 3. The final, site-specific environmental risk assessment is based on a combined pictorial and analytical model of the site that reliably represents the site and its environment to the required levels of detail and accuracy. The plans and models will typically develop through the following stages: Pre-licensing application discussions to develop the conceptual model for a site may be based initially upon outline plans and designs. These may start out as outline sketches and develop from there. They will usually be developed in support of the planning application.

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 Conceptual pictures and models are a useful starting point for scoping the site and its environment. Figure 6 shows examples of simple conceptual models for landfill catchments (taken from Environment Agency, 2000k in preparation). By the time the licence application is being submitted for consideration, the conceptual model will need to be based upon a detailed scale plan of the site and its surroundings. Site-specific scale drawings and plans are usually essential for a Tier 1 screening assessment to be carried out, in order to ensure that the model used is relevant, valid and reliable for the site in question. These will usually be available in the form of the outline or detailed plans and designs that the applicant has produced for their planning application. The applicant may also have developed an environmental risk assessment model to support an EIA submitted with the planning application. Figure 7 shows an example of the sort of site-specific plan (in this case, of a combined landfill and transfer station) that could be used. Examples of environmental receptors that may be relevant to the site-specific risk assessment are indicated on the conceptual plan by call-out boxes. These would be taken into consideration in the Tier 1 risk screening assessment (see Chapter 5). The risk management measures which are assessed as being necessary to prevent harm to these receptors would then be incorporated in the detailed design and plans for the site, as the conceptual model is developed. The plans and model are then refined as the risk assessor (Agency and/or applicant) reviews the risk assessment against the actual site and its environment. This development progresses as necessary through the various tiers of assessment, until understanding develops to the level appropriate to the risk management decision. The plans and model for a site must be developed on the basis of the actual site and its environment, and while desk-based studies and reviews may provide some of the basis, site-based inspections and reviews are essential. While development of the site-specific model and assessment should be led by the applicant/operator, it should be based upon active discussion with the Agency officer dealing with the application, who should also consult the Agency officer who is or will be responsible for inspecting the site against its licence conditions.

Further guidance on developing conceptual models (with specific application to modelling contaminant transport processes in the subsurface) is provided in Environment Agency, 2000h.

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2

Figure 6: Examples of conceptual models - simplified landfill catchment drawings.

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2
People & Property; e.g. inhabitants, workers, school, hospital, factory, offices. People & Property; e.g. inhabitants, houses. Perimeter fence Sewer connection Leachate lagoon Site office & laboratory Main road Car park Quarantine storage lagoon Groundwater below & in vicinity of site

People & Property; e.g. inhabitants, workers, buildings, livestock. Farm house & barns

Phase 1 landfill composite lined

Clay bund

Weighbridges & office Gate Wheel spinner Transfer station Concrete pad Exempt area Wheel wash Surface water

Ecosystems; e.g. designated Habitat, SSSI.

Phase 2 landfill composite lined

1 2

Bays 3 Screener Perimeter fence 0 10 20 30 40 50 m River / stream

Figure 7:

Example of a conceptual plan of a combined landfill and transfer station, indicating examples of potential environmental receptors

A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2

5 5.1

TIER 1: SCREENING OF ENVIRONMENTAL RISKS


Introduction This chapter explains what Tier 1 screening assessment is, based on the source-pathwayreceptor approach, and describes its use in the form of the Shell Risk Assessments which form the basis of the Shell Licensing Kits. Examples and relevant tables are given, supported by Appendix 1, 2, 3 and 4. It discusses the use of scoring in the rating and prioritisation of risks and risk management systems. An example is given in Appendix 5.

5.2

Screening of environmental risks for waste management sites A typical screening assessment of the environmental risks of a site consists of a qualitative assessment which identifies: what risks there are to the environment from the proposed site operations what standards of environmental protection are required to manage those risks which, if any, of the identified environmental risks require a more detailed technical risk assessment: a) to resolve uncertainty over the identification or significance of the risk; and/or b) to determine the necessary standards of environmental protection. Screening assessments should be based upon a conceptual model which analyses the sourcepathway-receptor links for the site, and, as described in Section 4, this model usually takes the form of a table, matrix or spreadsheet. This identifies the sources of the hazards, the pathways through which those hazards may be transmitted into the environment and by which they might reach the things we wish to protect (i.e. the environmental receptors). Situations in which either a source, a pathway or a receptor will not be present, or where the likelihood of them becoming connected is justifiably negligible, can be screened out. Where there is significant uncertainty concerning the presence or connection of a source, pathway or receptor, then the situation should not be screened out without further investigation or more detailed assessment. In waste management licensing, the identification of a plausible or likely link between the source of an environmental hazard via a potential pathway to a potential receptor is considered to be sufficient to warrant risk management measures being stipulated in the licence conditions, unless the site-specific risk assessment demonstrates that, for the site in question, the environmental risk is so low that such measures are unnecessary. The scope, type and standard of risk management measures that will be required will depend upon the environmental hazard and upon the identified environmental risks. In waste management licensing, many sites will fall within typical categories (such as various types of transfer stations) where the activities they carry out and the environmental risks they give rise to are known and understood well enough that the risk management provisions they will typically require can be identified and specified as default risk management standards. These are standards that will normally be required in default of any more detailed sitespecific assessments indicating that either a lesser or a higher standard of risk management

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 provision is required for that particular site. This is the level of assessment that is provided through the Shell Risk Assessment approach. As uncertainty increases however, and the likelihood of severe consequences become less clear, a more detailed assessment of the source-pathway-receptor is necessary to understand the nature of the risks and how to avoid, or manage them. The Shell Risk Assessment approach can be used to identify where these more detailed assessments are needed.
5.3

Shell Risk Assessments Shell Risk Assessments are Tier 1 screening assessments. These are for use in defined circumstances by the applicant/operator and by the Agency in producing a site-specific risk assessment in support of the licence application or a licence modification. Each Shell Risk Assessment is based on: a typical site for the category of site in question (for example, A11: Household, Commercial and Industrial waste transfer station), which is defined in terms of: the waste categories that will typically be permitted on that category of site, including references to the relevant Level 1 waste categories listed in the UK Waste Classification Scheme (UKCWS); and the waste management operations that will typically be permitted on that category of site, which will fall within the general classifications of storage (or keeping), treatment (including physical, chemical, biological and combinations thereof) and disposal (including treatment operations which are an inherent part of the disposal), and which will also include the handling operations which are inherently associated with those operations. (The waste operations will be classified within the licence conditions with reference, where applicable, to the Waste disposal and Waste recovery classification list (the D and R list) which is given in the Waste Management Licensing Regulations 1994, Schedule 4, Parts III and IV.) Typical sites can be regarded as those which provide a good fit with the shell risk assessment, the shell licence conditions and working plan. A good fit is defined as where neither the applicants risk assessment nor the Agencys evaluation of that risk assessment, justify either: a) detailed quantitative risk assessments to be carried out; or b) significant variations in the risk management provisions from those described in the working plan or from the default standards; or c) significant variations from the default standards specified in the shell licence conditions. Appendix 2 provides an example from the Shell Licensing Kits used by the Agency. Hazards and risks can be ranked or scored using qualitative indicators, such as high, medium, or low, and this can be useful in helping to identify the type and degree of risk management measures that are appropriate in a particular case. Box 2 explains how this works in the Shell Risk Assessment tools.

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 Box 2: Rating of environmental risks in the Shell Risk Assessment tools. Each Shell Risk Assessment tool has been constructed upon the basis of a generic assessment of whether, for a defined typical site of that type, the source risk (the risk that the site will give rise to hazardous releases or emissions) is high, medium, low or insignificant. This is done on the basis of a generic conceptual model of the type and amount of each waste handled, its associated hazardous properties, and the waste management activities to which it is subjected. Where the Shell Risk Assessment identifies a source risk, it also generically identifies the plausible or likely environmental pathways for the identified releases and the plausible or likely receptors at risk from those releases (people, properties, groundwater, surface water, etc). The presence of a receptor for that risk indicates that a risk management system is required. The vulnerability and proximity of receptors is not assessed or scored as high, medium, low or insignificant in the Shell Risk Assessment. The Shell Risk Assessment specifies the default risk management measures that are considered as being appropriate for such a typical site, taking into account whether the source risk is assessed to be high, medium, low or insignificant. These measures are specified to generic standards for that type of site to reduce the identified risks through appropriate requirements for: engineered containment operational procedures monitoring action plans and remediation measures. Either the Agency or the applicant may carry out a more detailed assessment to show that for the site in question these are such as to justify either higher or lower standards of risk management than those specified in the default requirements for the generic typical site. This may be based on a detailed assessment of the vulnerability and proximity of receptors for the site in question. Thus, the Shell Risk Assessment tool establishes a decision-making framework appropriate to that type of site, in which a Yes/No decision can be made for each hazard, as to whether there is a linkage and hence a risk. A Yes answer indicates that the identified risk management systems need to be provided for that site to the standards specified as a default, and a No indicates that they do not need to be provided. This can be regarded as the simplest form of scoring system for risk, equivalent to assigning a binary score of 1 or 0. Where there is uncertainty or disagreement over whether the answer is Yes or No then a more detailed assessment is needed to resolve the question.

5.4

The source of environmental risks The source is analysed in terms of the hazardous properties of the waste types and operations to which they will be subjected on the proposed site. The hazards are listed in Appendix 3, and are those resulting from:

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 a) specific properties of special wastes, classified using the codes for special waste hazardous properties: H1 to H14 (as defined in the Special Waste Regulations 1996 (as amended)); and b) hazardous properties of wastes (whether special or non-special) which are not covered by the above, but which could give rise to an environmental risk these include properties which are covered by the appropriate difficult waste codes for property (H15 to H20) and form (F1 to F6) as listed in the UK Waste Classification Scheme (Environment Agency, 1998); and c) other waste operation related hazards, such as noise, which are not covered by the above, which are within the terms of reference of the licence and which could give rise to an environmental risk. The Source definition also includes under each hazard classification, the relevant risk phrases and the UK Waste Classification first level waste categories which include wastes which may display those hazards.

5.5

Hazardous events and pathways The hazardous events and pathways that are assessed are (see section 2.2): Direct emissions of heat and shock due to fire or explosion; Releases of polluting emissions by one or more of the following routes: - air (or atmosphere) as pathway (it may also be a receptor for certain risks see below); - ground (including via services); - water (surface water and groundwater are receptors in their own right see below); Other vectors for environmental hazards: - dust - pests; - scavengers; - litter; - noise.

As discussed in section 2.2, if humans (or animals) are exposed to hazardous substances or emissions via one or more of the above environmental pathways, harm to their health may occur through a number of exposure pathways. Typically these may include: inhalation or ingestion of, or dermal contact with, hazardous substances; and the direct effects of heat and shock in the case of fires or explosions. Humans may also suffer harmful effects on health through serious detriment to the amenity of their locality. These exposure pathways are not explicitly assessed in Tier 1 Shell Risk Assessments. It is sufficient for the assessment to identify whether or not a significant exposure of identified human or animal receptors is likely to occur, in order to decide whether or not risk management measures need to be provided.

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5.6

Environmental receptors The environmental receptors that are assessed are (see section 2.2): People outside the site boundary. (People within the site boundary are only considered where they may be trespassers or others who have gained unauthorised access site security requirements are imposed to prevent this situation occurring. People who are legitimately on site - including site staff and other people who are authorised or doing other legitimate business - are covered specifically by the Health and Safety at Work Act 1974 and are not considered in the environmental risk assessment); Properties outside the site boundary, including public and private property and places where the public have access this may also include livestock or other animals which are kept (rather than wild) outside the site boundary (or within the site boundary); Ecosystems, especially habitats designated in accordance with the Habitats Directive, and other designated sites; Surface water in the vicinity of the site; Groundwater in the vicinity of the site; Atmosphere, which is a receptor in regard to the risk of global warming.


5.7

The environmental risks that are assessed The risks that are assessed are environmental pollution risks, including harm to human health. Serious detriment to the local amenity is included where it straddles the line between amenity and environmental pollution; that is, where the detriment is such that a source-pathwayreceptor relationship is identified that is likely to have an adverse effect on human health; e.g. dust or odour emissions, pest infestations.

5.8

The risk management systems that may be required, and default standards The environmental risk management systems that are specified are those that will typically be required for sites that fit the shell risk assessment. These include provisions, such as maintenance, monitoring, etc, which will typically be required to manage and minimise the residual risks arising from failure of first lines of defence such as engineered site containment and drainage systems. These are included as default standards in the corresponding shell licence conditions for that category of site, which are identified in the assessment table. They represent a reasonable precautionary standard; to deviate from this standard would require a detailed risk assessment to justify a different standard from the default.

5.9

Site-specific variation from the default risk management requirements Each Shell Risk Assessment includes guidance on when the Agency officer dealing with the application and reviewing the applicants completed risk assessment should consider imposing a requirement for additional or higher levels of risk management, because the risk presented by the site in question may be higher than that for the typical site of that type. This may be because: i) the wastes which are handled by the site are atypical and exhibit hazardous properties which are atypically high; or

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 ii) the waste management operations are atypical and the risks of hazardous releases or emissions is atypically high; or iii) the environmental receptors are atypically vulnerable to hazardous releases or emissions in terms of their sensitivity (e.g. hospitals) and/or their proximity to the site. Where appropriate, the relevant OPRA for Waste (Environment Agency 2000e) risk assessment criteria are referred to for guidance and as an aid to the decision (the relevant OPRA assessment criteria are given in Appendix 4). These should only be used as indicative guidance, and will not be a substitute for more specific consideration of the receptors potentially at risk. Where receptors are identified as being highly sensitive to the hazard, or at high vulnerability or risk of exposure, more detailed modelling and assessment may be required in order to identify and specify appropriate risk management standards, or to resolve uncertainty or disagreement over those proposed. The Agency officer dealing with the application should consult the Agency officer who is or will be responsible for inspecting the site against its licence conditions on this, as they will be familiar with the use of OPRA for such sites and with the presence of potentially vulnerable receptors in the vicinity of the site. This should take place at the same time as the conceptual model for the site is being reviewed on the site (see Section 4). For example, for a waste transfer station where the Tier 1 assessment identifies receptors at high risk of exposure which include: a) domestic dwellings, schools, hospitals, SSSIs or designated Habitats, then: a covered building which provides containment of aerial emissions may need to be considered as a necessary requirement rather than an option; and for some hazards, scientific monitoring of aerial emissions may need to be considered as a necessary requirement. (the need to consider this may be indicated by an OPRA Environmental Appraisal targetbased score for Human Dwellings, Population Density and Environmental Targets which is equal to or greater than 15); or b) a groundwater protection zone (GPZ) or vulnerable major aquifer, then scientific monitoring of groundwater quality may need to be considered as a necessary requirement, (the need to consider this may be indicated by an OPRA Source score which is equal to or greater than 15, combined with an Environmental Appraisal target-based score for Groundwater which is equal to or greater than 10); or c) a surface water body which is of high quality, then scientific monitoring of surface water quality may need to be considered as a necessary requirement, (the need to consider this may be indicated by an OPRA Source score which is equal to or greater than 15, combined with an Environmental Appraisal target-based score for Surface Water which is equal to or greater than 10). The OPRA score is only indicative and will not in itself provide sufficient justification for the Agency to impose such requirements. If a need for scientific monitoring or another higher level of risk management is identified for a site, then the Agency should justify that need and the standards required on the basis of a more detailed risk assessment regarding that risk management provision. Where scientific monitoring is so justified by the assessment, the

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 necessary conditions should be added to the shell-derived, site-specific licence conditions. The applicant should be required to provide working plan sections detailing the relevant risk management systems, for referencing to these licence conditions, or else the Agency may prescribe detailed requirements. Area referral to Region is recommended in these circumstances.
5.10

Scoring, rating and prioritisation of environmental risks Within waste management regulation the identification of a plausible or likely connection between a source, pathway and receptor is usually sufficient to warrant risk management measures (in the absence of a detailed assessment justifying otherwise), and the prioritisation of risks is not applied within Shell Risk Assessments. This is because risk management measures may not be common across different types of risk. For example, the provision of a risk management system to prevent and control, for example, landfill gas emissions, would not justify a failure to provide a risk management system to prevent and control dust emissions. (This does not prevent the same risk management system from providing prevention and control for different hazards, where this is appropriate; in this example, the landfill cap will, on completion, provide some of the protection from both landfill gas and dust hazards. But the risk and the management system provided must be assessed on their own merits in each case.) Hazards and risks can be ranked or scored using qualitative indicators, such as high, medium, or low, and this can be useful in helping to identify the type and degree of risk management measures that are appropriate in a particular case. Box 2 in section 5.3 explained how this works in the example of the Shell Risk Assessment tools. The use of semi-quantitative indicators to score probability and consequence and to rank risks, can assist where there is a need to understand whether the risks in question are driven by the probability of their occurrence or by their consequences if they do occur. This may be useful where there is a need to compare different approaches to risk management or to scope out more detailed studies. However, scoring systems (particularly those employing numerical scales, such as 1-5) are liable to convey a spurious impression of scientific precision, and should only be employed where their use can be shown to add value to the decision or inform it in a way that would not be obtained by considering the actual risks to the identified receptors, and the actual specifications of the system that will be required to manage those risks to a defined and enforceable standard. Risk prioritisation requires a separate consideration of probability and consequence. In most instances this can follow on from the source-pathway-receptor analysis used in the screening assessment or Shell Risk Assessment. The hazard and source characteristics and the sensitivity of the receptor dictate the consequences. Probability is usually dominated by the availability of the linkage between the source and receptor. The benefit of rating and prioritisation is to distinguish between low probability, low consequence risks and high probability, high consequence risks. The latter will usually require some further level of analysis, although this is not to infer that low probability, low consequence risks will not need to be addressed. The following points need to be borne in mind when considering the use of a rating and prioritisation assessment: National Centre for Risk Analysis and Options Appraisal Page 33

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Rating and prioritisation approaches usually incorporate a numerical scoring system that reflects the magnitude of the probability or consequences of adverse effects occurring at a location. At this level of assessment scoring systems are arbitrary. Scores can not reflect absolute risk and scoring systems need to be simple, clear, easy to follow and reproducible. Critically, they should never assume a degree of sophistication in their design beyond what they can deliver in terms of distinguishing between risks. They should never be used to estimate or infer absolute levels of risk that are then compared with risk criteria or to test the effectiveness of detailed risk management options. The value of prioritising risks within a band (for example, for ranking all risks in order of the highest to the lowest), is of limited value if all risks must be addressed. This will usually be the case in setting conditions for waste management licenses. This is because it will not be acceptable to omit risk management requirements from the licence conditions on the grounds that, based on a scoring and ranking assessment, the risk in question comes low on the rank ordering list or is relatively insignificant. More sophisticated tools are available for detailed estimates of risk, and scoring systems implying high levels of precision should not be employed, given the relative nature of risk prioritisation. Where different scales are used for scoring (e.g. 1-5 vs. 1-30), these should be properly justified.

An example of a risk rating assessment is given in Appendix 5, in which it can be seen that the scoring system used and the results obtained do not add significant value to the qualitative assessment or to the risk management and licensing decisions. In general: Risk rating systems can: - distinguish between risks posed by facilities or situations of a generic type; - allow prioritisation of risks from risk scores, usually through the separation of probability and consequence; - allow comparisons between situations with similar risk, but with different driving factors; - accommodate simple what if questions; - allow fast screening of numerous facilities or situations; - prioritise and focus further risk assessment effort; - support the identification of high risk situations which may develop after authorisation or licensing. Risk rating systems cannot: - provide absolute estimations of risk; scores are relative - provide a degree of resolution beyond that inherent to the subjectivity of the scoring system; scores are best banded in ranges; - be applied without training.

A good example of the valid use of risk rating and prioritisation features in the OPRA for Waste scheme (Environment Agency, 2000e) and the features of such schemes are detailed in the National Centre for Risk Analysis and Options Appraisals Guidance Note on Risk Rating Systems (GN17) (Environment Agency, 1999c).

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6 6.1

TIERS 2 AND 3: DETAILED ENVIRONMENTAL RISK ASSESSMENT


Detailed quantitative risk assessments Where there is potential for linkages to exist, and the Tier 1 screening assessment/Shell Risk Assessment indicates that those linkages need a more detailed assessment, the sourcepathway-receptor analysis may be developed to include the following: construction of a source (contaminant, hazard), pathway, receptor table for the facility or situation under study, paying specific attention to the completion of discrete linkages (hazard identification); an evaluation of the actual or potential connectivity of these components (exposure assessment); consideration of the relative likelihood and scale of exposure and scale of consequences by reference to the nature of the hazard (potency), availability of the pathway and sensitivity of the receptor (risk estimation); classification of the relative magnitude of the risk together with a justification for the assignment of risk class (risk characterisation). For example, the temporal and seasonal aspects may be important for a particular hazard and a particular site. Problems with exposure to dust may be identified as an issue, especially in the summer months, which requires detailed exposure assessment in order to justify a requirement for environmental monitoring points to measure dust emissions. Likewise, the performance of a liner system needs to be assessed beyond the working lifetime of a site. The development of a more detailed assessment may be justified in these cases, to identify whether increased standards of protection will be necessary. These aspects usually involve considerable uncertainty and a precautionary approach is usually adopted where the risks are identified as significant. Detailed quantitative risk assessments are required where either: the Tier 1 screening assessments indicate that they are necessary for that site due to its particular circumstances (for example: the need for and design of engineered containment for a landfill will normally require detailed risk assessment); or the applicant/operator wishes to justify more relaxed standards of risk management than are indicated in relevant standards or Agency guidance as being typically required for the identified environmental risks, due to site-specific factors (for example: operations involving the handling, storage or treatment of non-inert wastes will normally require an engineered site surface providing containment and sealed drainage the applicant/operator may be able to provide a detailed assessment of the site and its environment for consideration by the Agency, which indicates that there is no significant risk to either groundwater or surface water from their proposed operations and that a lower standard of site surface containment and drainage is acceptable); or the Agency wishes to impose more rigorous standards of risk management than are indicated in relevant standards or Agency guidance as being typically required for those environmental risks, due to site-specific factors (for example: operations involving the handling, storage or treatment of non-inert wastes will not normally require either groundwater monitoring or surface water monitoring where an engineered site surface providing containment and sealed drainage is provided the Agency may, by providing a detailed assessment of the site and its environment, show that there is a significant risk to

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 either groundwater or surface water from the proposed operations, even with such engineered containment and drainage, and that appropriate monitoring is required). If a detailed risk assessment is to be conducted, a principal consideration is the type of risk being assessed. At the licensing stage, the Agency is usually concerned with three main types of situation: the risk of an initiating event that may result in a release (e.g. the failure of a landfill gas extraction system; or the puncture of a landfill liner); the risk of exposure to the wider environment following a release (e.g. loss of a drinking water supply due to contamination from an leachate plume released from a landfill site); and the risk of harm resulting from exposure (e.g. risks to human or ecological health as a result of exposure to asphyxiant gases). Within the context of a tiered approach, these types of risk require the use of quite distinct risk assessment tools. Systems with engineering features (engineering landfills, capping systems) are amenable to fault and event tree analysis that assesses the performance characteristics and the root cause(s) of failure; whereas environmental exposures often require distribution modelling, which attempts to characterise the transport of contaminants in the environment by reference to numerical models. Risks of harm, beyond the reference to environmental standards, require a more detailed understanding and evaluation of physical, chemical or biological damage. Quantitative risk assessment is used for high priority, complex risks and is a specialist area of expertise. A variety of numerical models and computer software, such as LANDSIM, have been developed to assist in the quantification of risks from waste management sites. Two approaches are possible: Tier 2 generic risk assessment: where a representative numerical model is used to simulate the facility under study in order to assess the nature and level of risks involved and to inform the general type of risk management measures required; and Tier 3 tailored risk assessment where attempts are made to tailor the generic model specifically to the site under study, using assumptions and input parameters that reflect the site-specific conditions. Both Tier 2 and Tier 3 assessments involve a quantitative assessment of the risks that apply to the particular waste management facility. The principal difference between the two tiers is the extent to which the assumptions built into the model and the input parameters are generic or site-specific. In a Tier 2 assessment most of the assumptions will be generic, chosen as part of the model development to be representative of typical conditions (cf. the Tier 1 Shell Risk Assessment approach). This has the advantage that the assessment is easier and quicker to complete than a Tier 3 assessment, requiring less site-specific data. However, because the assumptions are largely generic, the extent to which the assessment exactly models the site circumstances will be less than for a Tier 3 assessment. Use of either generic or tailored risk assessment approaches requires that: inputs are matched to outputs when carrying out simulations using the model; that is, the user of the model understands the means and manner in which the selection of the input variables will affect the relevant outputs failure to understand this relationship will tend to lead to the situation of garbage in-garbage out in the modelling;

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6.2

the data used as inputs to the model is justified and referenced; and the data ranges are not subject to bias which will distort the resulting outputs.

Tier 2: Generic Quantitative Risk Assessment Generic quantitative risk assessment adopts models representative of a general situation; eg. the generalised engineered landfill. For example, LANDSIM is a performance assessment model for landfills and is capable of selecting from a wide range of liner types, landfill geometries, drainage systems and leachate strengths to estimate contaminant breakthrough curves. However, it does not represent any actual site under consideration per se because of the site-specific complexities, and it should be used with caution (e.g. does it fit the conceptual model of the site?). Use of the model is explained elsewhere (Environment Agency, 1996). An example is given in outline in Appendix 6. The value of these approaches is that they: allow adoption of recognised equations in a probabilistic mode; allow an intrinsic handling of uncertainty; formalise the decision-making approach; facilitate a full assessment of all possible outcomes within the constraints of the model that has been set up; provide an assessment more meaningful than a qualitative treatment in isolation; allow sensitivity analyses of components of risk; and allow and promote discussion of expert judgement issues. Most generic models operate in predictive mode and are concerned with improving an understanding of how a system behaves rather than being over-concerned with the accuracy of output. They provide a more accurate means of assessing risks than a Tier 1 assessment, and they are an aid to selecting and designing risk management measures. With appropriate use, the pattern of results generated from these generic models should not be so divergent from a tailored risk assessment that radically different decisions would have been made; over cell design, for example.

6.3

Tier 3: Tailored risk assessment Tailored risk assessment extends use of the generic tool to include site-specific assumptions and input parameters. Adoption is usually restricted to complex, high priority cases, such as radioactive waste repositories, for example. Where used, it will often involve construction of one of several models linked together. This level of risk assessment is a highly specialised and expert activity. The types of risk assessment tools that are likely to be applied in tailored risk assessment include the use of fault and event tree analysis and the use of groundwater distribution models to predict the travel time and characteristics of contaminant plumes following release. The use of event and fault tree analysis and the selection of appropriate data for risk assessment are outlined in sections 6.4 and 6.5 respectively. Specialist assistance should be sought for any tailored risk assessment.

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6.4

Event and fault tree analysis Event and fault tree analysis is used for assessing the risks of an initial release, usually from containment. There are two basis approaches, both of which calculate the probability of the event by considering the causes of the incident. The first involves the use of historical, statistical data on the failure of containment. The second approach uses a method called synthesis analysis, to break the system down into contributing factors and causes. There is a general problem of demonstrating very low probability; that is, in obtaining a statistically meaningful estimate of rare or accidental events. It is therefore valuable to collect event data over time, as much of this is useful in reliability and availability studies. This type of information is valuable for testing results from synthesis analysis against historical data to determine whether the approaches used lead to comparable predictions. When historical performance data are not sufficient, synthesis analysis is used. The two most common methods used are fault trees and event trees. These techniques are initially qualitative in nature, although they provide the basis for quantitative analysis, if required. They can be made highly site-specific, being tailored to the system being analysed. They can identify event scenarios that have not been realised in the past, which allows for the introduction of risk reduction measures to reduce the likelihood of an event taking place in the future. In fault tree analysis the aim is to select an undesired event (such as a failure of containment, usually called the top event) and trace it back to the possible causes, which can be component failures, human errors or any other possible events that can lead to the fault. The causes are related using simple logic relationships (i.e. AND/OR gates) to allow for the construction of a logical structure that models the failure of the system (Figure 8 gives an example of the way a fault tree is constructed). The technique produces a list of the events that could lead to the fault (i.e. top event) being realised. Event tree analysis operates in the opposite way. The starting point is an initiating event (the failure of a leachate treatment system, for example) and the technique is often used to follow the consequences of such an event. Fault tree and event tree analyses still require data to quantify the contributory causes. Quantification often involves value judgements made on the basis of professional expertise, which can be difficult to justify when not substantiated by historical records.

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 Release to groundwater
Logic gate (AND gate) Top event

&

Intermediate event Release to ground

Ground

water present

or or

Logic gate (OR gate)

Release to unsurfaced ground

Release to ground via hardstanding

Release to ground via impermeable pavement & sealed drainage

&

&

&

Leak

Emitting waste

Operator

error

Emitting waste

Operator error

Emitting waste

&

Base event

Leak in system

Maintenance error

Figure 8: Tools and techniques for environmental risk assessment: fault tree example National Centre for Risk Analysis and Options Appraisal

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6.5

The selection of appropriate data for tailored risk assessment. Early dialogue between operators and the Agency on the scoping of a tailored risk assessment is valuable. It may cover aspects such as: assumptions within a conceptual model; agreeing receptors that should be considered at different stages of proposal development; the appropriateness of default values; and appropriate level of site investigation required to support the risk assessment. Tools such as LANDSIM used for tailored risk assessment should be considered as within a broad spectrum of possible risk assessment tools and should never be seen as providing the answer to all problems. In situations where the hydrogeology is complex and the aquatic environment is particularly sensitive, for example, more complex assessment tools are almost certainly a necessity. Conversely, if the site hydrogeology and sensitivity do not warrant a detailed treatment, the risk assessor may be able to reach a robust decision on the basis of less intensive risk assessment process. By necessity, numerical models demand numerous assumptions. The y are only tools and the assumptions need to be understood in order to properly interpret the results. The predictions from a tailored assessment should always be considered in the light of input data quality, model assumptions, uncertainty within the conceptual model and parameter sensitivity analysis. Only then is it possible to reach a robust decision whether to accept the predicted risks, to refine the model by collecting more data, or to move to a more complex assessment tool.

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7

GLOSSARY
Conceptual model: a risk assessment tool consisting of a presentation in visual (sketches, drawings, plans) and written form (tables, matrices, spreadsheets) of the hypothesised relationships between sources, pathways and receptors for a site in its environmental setting. A conceptual model represents the problem under study and is used as the basis on which to develop a site specific risk assessment. The level of detail required of the model will depend upon the complexity of the risk assessment. The model is not static and will often modification as new information about the risks becomes apparent and more sophisticated levels of analysis are applied. Consequences: the effects (or impacts) of a particular situation, action or event. Impacts may be positive (benefits) or negative (costs, or harms). Risk assessments usually focus on assessing the potential negative consequences (the harm) that may result from the realisation of identified hazards. Environmental risk assessment : the systematic identification, assessment, estimation and characterisation of risks to or from the environment from a particular event, activity, operation, process or design. Environmental risk assessments are carried out and reported by suitably qualified or competent persons, to a defined scope, using recognised tools and techniques. Harm: the damage to a receptor that results when a hazard is realised. Hazard: a property or situation that in particular circumstances could lead to harm. Impact: see Consequences. Receptors : identified individuals, environmental populations or components, structures, assets and property that may potentially be exposed to an identified hazard, and that may consequently suffer harm. Probability: the likelihood of an event occurring, or expression of chance usually denoted mathematically either as: the ratio or percentage of the occurrence of a particular event as one among a number of possible events (e.g. a 20%, or one in five chance); or the frequency of occurrence of a particular event in a given period of time (e.g. an annual probability of one in a million). Pathways: the routes or means by which defined hazards may potentially realise their consequences at the receptors. Risk: a combination of the probability, or frequency, of occurrence of a defined hazard and the magnitude of the consequences of the occurrence. Scope: the agreed boundaries of the risk assessment and the risks to be assessed within those boundaries.

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BIBLIOGRAPHY
Department of the Environment, 1994a. Circular 11/94 in relation to The Waste Management Licensing Regulations 1994. The Stationery Office, Norwich, London. Department of the Environment, 1994b. Waste Management Paper No 4 (WMP 4) Licensing of Waste Management Facilities. The Stationery Office, Norwich. (Revised in DETR, 2000.) Department of the Environment, 1995. A Guide to Risk Assessment and Risk Management for Environmental Protection. The Stationery Office, Norwich, London. Department of the Environment. Waste Management Paper No 26A (WMP26A) Landfill Completion. The Stationery Office, Norwich. Department of the Environment. Waste Management Paper No 26B (WMP26B) Landfill Design, Construction and Operational Practice. The Stationery Office, Norwich. Department of the Environment. Waste Management Paper No 27 (WMP27) Landfill Gas. The Stationery Office, Norwich. DETR, 2000. Waste Management Paper No 4 (WMP 4)(Revised) Licensing of Waste Management Facilities. The Stationery Office, Norwich. DETR, Environment Agency and Institute for Environment and Health, 2000. Guidelines for Environmental Risk Assessment and Management, Revised Guidance, DETR, Environment Agency and Institute for Environment and Health. The Stationery Office, Norwich. Environment Agency, 1997. A Guide to Risk Analysis at the National Centre for Risk Analysis and Options Appraisal. Environment Agency, London. Environment Agency, 1998. Interim Framework Policy for Landfill Engineering. Environment Agency, Bristol Environment Agency, 1999a. Interim Internal Guidance on Interpretation and Application of Regulation 15. Environment Agency, Bristol. Environment Agency, 1999b. Library of Licence Conditions & Working Plan Specifications, Volumes 1 & 2, Edition 2. Environment Agency, Bristol. (Being replaced by Environment Agency, 2000b). Environment Agency, 1999c. Guidance Note on Risk Rating Systems (GN17). National Centre for Risk Analysis and Options Appraisal, Environment Agency, London. Environment Agency, 2000a. Introducing Environmental Risk Assessment. National Centre for Risk Analysis and Options Appraisal, Environment Agency, London. Environment Agency, 2000b. Licensing Process Handbook. Environment Agency, Bristol Environment Agency, 2000c. Library of Licence Conditions & Working Plan Specifications, Edition 3. Environment Agency, Bristol Environment Agency, 2000d. Shell Licensing Kits (available for various site categories). Environment Agency, Bristol Environment Agency, 2000e. Waste Management Licensing. Risk Assessment Inspection Frequencies. Operator and Pollution Risk Appraisal for waste OPRA for Waste. Version 2.0. Environment Agency, Bristol. Environment Agency, 2000f. Licensed Waste Management Facility Site Inspection Methodology and Consistent Scoring Guidance. Version 2.0. Environment Agency, Bristol. Environment Agency, 2000g (in preparation). Scoping Guidance on the Environmental Impact Assessment of Projects. National Centre for Risk Analysis and Options Appraisal, Environment Agency, London.

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 Environment Agency, 2000h. Guide to good practice for the development of conceptual models and the selection and application of mathematical models of contaminant transport processes in the subsurface. NGWCLC Report NC/99/38. National Groundwater and Contaminated Land Centre, Environment Agency, Solihull. Environment Agency, 2000j (in preparation). Environment Agency Policy: The location and impact assessment of waste management facilities (with particular emphasis on landfill sites and the protection of controlled waters). Environment Agency, Bristol. Environment Agency, 2000k (in preparation). Guidance on monitoring of landfill eachate, groundwater and surface water. R&D report (R&D project HOCO_232). Environment Agency, Bristol. European Environment Agency, 1998. Environmental Risk Assessment: Approaches, Experiences and Information Sources, Copenhagen. Environment Agency, 1996. LandSim: Landfill performance simulation by Monte Carlo method. LandSim manual, ref CWM 094/96. (prepared by Golder Associates (UK) Ltd). Environment Agency, Bristol. Gronow, JN & Harris, RC, 1996. LandSim: a regulatory tool for the assessment of landfill site design. In: Wastes Management, February 1996.

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9

APPENDICES

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 Appendix 1: Environmental risk assessment questions, stages, tiers and techniques waste management licensing (See Chapter 3, section 3.2.) As indicated in Chapter 1, Table 1, the following risk assessment stages and questions may be addressed at the appropriate level of detail through the relevant Tier 1, 2 or 3 assessments at Phase 1 (Strategic planning), Phase 2 (Individual planning) and/or Phase 3 (Environmental authorisation). This table indicates how: c) the tiered approach to risk assessment and the identification of appropriate risk management measures would be applied at Phase 3 (Environmental authorisation waste management licensing), based on the example of a waste transfer station handling household, industrial and commercial wastes, for the particular hazard of wastes which are likely to produce emissions of dust to atmosphere; d) hazard identification, risk assessment and identification of appropriate risk management measures would be carried out using the tools and techniques appropriate for waste management licensing, using the example of a Shell Risk Assessment approach for this category of site (as explained in this chapter and Chapter 5). This approach would be used either to review an environmental risk assessment provided in support of the relevant planning application, or to identify and assess the relevant hazards where such an environmental risk assessment was not available.

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2

Stage1 Conceptual modelling & scoping the boundaries of the environmental risk assessment

Question A. What is the nature of the site (including the waste management operations) and its environmental setting?

Tier Problem formulation or definition

Tools & techniques - licensing Drawing pictures, plans and diagrams of the site and its environmental setting; and developing a source-pathwayreceptor model; supported by site visit &/or inspection. Source-pathway-receptor table; Agency tool: Shell Risk Assessment; supported by site inspection &/or investigation.

Example - licensing Household, industrial and commercial waste transfer station. (Category A11 site) 4

See Chapter

Environmental risk assessment; (or review of environment al risk assessment provided in support of planning application).

B. Is there a risk to the environment from the waste management operations on this site?

Tier 1: Risk screening

Category A11 Shell Licensing Kit: Shell Risk Assessment pack.

Tier 2 & Tier 3: Quantitative risk assessments Stage 1: Hazard identification


B1. What hazards are present and what are their properties? Tier 1

Generic and tailored quantitative risk assessments

Only where necessary to resolve uncertainty or disagreement over Tier 1 (Shell) risk assessment and/or risk management measures required. (See below.)

Source characterisation: inventory of wastes handled and stored identification of environmentally hazardous properties description of waste

Category A11 typical site: Waste handled and stored - UKCWS first level waste categories: 21: Inert 22: General and biodegradable 24: Contaminated general Environmentally hazardous properties (see

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2
Stage1 Question Tier Tools & techniques - licensing management operations. Example - licensing SRA) - example: Solid wastes which contain significant proportions of dusts, fibres, powders or particulates Waste management operations: receipt handling storage simple physical treatment (e.g. sorting, compaction to reduce volume) despatch See Chapter

Stage 2: Identification of consequences

B2: What are the potential environmental consequences that may arise form the identified hazards?

Tier 1

Identification of potential consequences (harm/damage to potential environmental receptors)

Environmental receptors liable to be adversely affected by releases or emissions of dusts (including fibres, powders and particulates) from the site: People: harm to health by inhalation of dust, etc; Properties: damage to property and loss of amenity caused by deposition of particulates; Ecosystems: environmental damage as a result of fallout causing smothering effects. This is implicit in the Shell Risk Assessment for the identified hazards; e.g. in this example: Consequences of dust emissions: spatial scale: receptors within likely zone of effect; i.e. aerial dispersion plume for aerial dispersion and deposition of dusts, etc people:

Stage 3: Estimation of the magnitude of the consequences

B3. What is the magnitude of the consequences for the identified potential receptors?

Tier 1

Identification of: the spatial scale of the consequences the temporal scale of the consequences the time to onset of the consequences

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Stage1 Question Tier Tools & techniques - licensing Example - licensing temporal scale: exposed receptors (i.e. not intergenerational) time to onset: immediate harmful effects on quality of life - immediate and delayed harmful effects on health properties: temporal scale: exposed receptors time to onset: - immediate and longer term damage ecosystems: temporal scale: exposed receptors time to onset: - immediate harmful effects on ecosystem - longterm damage to ecosystem Tier 2 or 3 Detailed quantified modelling and assessment of consequences. (See Stage 5, question B7 below.) Identification and characterisation of: potential release scenarios during normal operations, abnormal operations and accidents; and consequent pathways between releases and receptors. Estimation of probability of hazard occurring (See Stage 5, question B7 below.) 6 See Chapter

Stage 4: Estimation of the probability of the consequences

B4. How might the receptors become exposed to the hazards?

Tier 1

Release to air of dusts, fibres, powders or particulates, either directly from wastes exhibiting these properties or as a result of the waste handling activities on the site. Aerial dispersion of dusts, etc, beyond the site boundary.

B5. What is the probability of the hazard occurring?

Tier 1

In the Shell Risk Assessments, these probabilities are estimated or characterised as being either high, medium, low or

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2
Stage1 Question Tier Tools & techniques - licensing Example - licensing insignificant/negligible, on the basis of the likelihood of the permitted waste types having the identified hazardous property, and the operations to which those waste types will be submitted. For the example in question: See Chapter

Probability of waste handled and stored containing significant proportions of dusts, fibres, powders or particulates:
Category 21: Inert wastes = High; Category 22: General and biodegradable = Medium Category 24: Contaminated general = Medium

Probability of waste management operations generating dust emissions from these wastes: Receipt = Low Handling = High Storage = Medium Simple physical treatment (e.g. sorting, compaction to reduce volume) = High Despatch = Low

Tier 2 or 3

Detailed quantified modelling and estimation of probability and magnitude of releases during normal and abnormal operations, using fault tree and event tree analysis.

Only where necessary to resolve uncertainty or disagreement over Tier 1 (Shell) risk assessment and/or risk management measures required.

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Stage1 Question B6: What is the probability of the receptors becoming exposed to the hazard? Tier 1 Tier Tools & techniques - licensing Identification of likely or plausible pathways Example - licensing If there is no actual or potential connection between the hazard and the identified receptors, then there is no risk to those receptors from that hazard. In the Shell Risk Assessments, if there is a likely or plausible connection between the hazard source and the identified receptors, then it is assumed that there is a risk to those receptors from that hazard, and that appropriate risk management measures are required (see Risk Management decision, question D, below). 5 See Chapter

Tier 2 or 3

Detailed quantified modelling and estimation of probability and degree of exposure; using, for example, models such as LandSim, Helga, etc.

Modelling required in this example only where necessary: to resolve uncertainty or disagreement over the identification of likely or plausible pathways at the Tier 1 (Shell) risk assessment level; and/or - where highly sensitive receptors are identified as being at high vulnerability or risk of exposure, in order to identify and specify risk management standards other than those generally accepted as best practice or specified as default standards. In this example, this may apply where identified receptors include domestic dwellings, schools, hospitals, SSSIs or designated Habitats which are identified at Tier 1 as being at high risk of exposure to the hazard.

B7: What is the probability of harm resulting from exposure to the hazard?

Tier 1

Estimation of the likelihood of harm resulting from exposure to the hazard

In the Shell Risk Assessments, if there is a likely or plausible connection between the hazard source and the identified receptors, then it is

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Stage1 Question Tier Tools & techniques - licensing Example - licensing assumed that there is a significant likelihood of harm to those receptors (see question B6 above), and that appropriate risk management measures are required (see Risk Management decision, question D, below). Tier 2 or 3 Detailed quantified modelling of exposure-harm relationship. This depends upon likely susceptibility of individual receptors to the hazard and the amount or duration of exposure. This is often simplified in terms of a doseresponse relationship, relating exposure to magnitude of harm for certain receptor types. The uncertainty is high for probabilistic assessments of individual cases, and most assessments take the magnitude of harm to be a direct result of exposure. Risk evaluation and characterisation; i.e. making a value judgement as to the acceptability of the identified and assessed risks and the need for risk management measures. May be necessary where highly sensitive receptors are identified as being at high vulnerability or risk of exposure, in order either: to identify and specify risk management standards other than those generally accepted as best practice or specified as default standards; or (for the Agency) to justify rejection of the application. 6 See Chapter

Examples may include domestic dwellings, schools, hospitals, SSSIs or designated Habitats which are identified at Stage 4 as being at high risk of exposure to the hazard.

Stage 5: Evaluating the significance of a risk

B8. How significant is the risk?

Tier 1

In waste management licensing, the identification of a plausible or likely link between the source of an environmental hazard via a potential pathway to a potential receptor is considered to be sufficient to warrant risk management measures being stipulated in the licence conditions, unless a more detailed technical assessment demonstrates that, for the site in question, the environmental risk is so low that such measures are unnecessary.

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2
Stage1 Question Tier Tier 2 or 3 Tools & techniques - licensing Comparison against or with reference to pre-existing measures, such as toxicological thresholds, environmental quality standards, or other social, ethical or political standards. This may involve the use of formalised quantitative approaches, such as look-up tables or the HSE tolerability of risk (TOR) framework. Example - licensing Where necessary to provide a quantified assessment for: comparison and evaluation against a defined environmental quality standard or equivalent; and/or - to identify and specify risk management standards other than those generally accepted as best practice or specified as default standards; or (for the Agency) to justify rejection of the application. 6 See Chapter

B9. What are the uncertainties? Is a more detailed risk assessment needed?

Tier 1

Review of site and operations against Shell Risk Assessment, to produce site-specific risk assessment.

Tier 2 or 3

Sensitivity analysis and uncertainty assessment. Risk scoring, ranking and prioritisation (see Figure 4).

Use of the Shell Risk Assessment pack to produce a site-specific risk assessment should identify those areas where: a) the site in question and its environmental situation are significantly at variance from the typical site forming the basis of the Shell Risk Assessment; and/or b) there is disagreement or uncertainty over the risk assessed and the risk management measures required; and hence c) a more detailed risk assessment is needed, either by the applicant or by the Agency. May be necessary where a Tier 2 or Tier 3 risk assessment is provided Where more than one risk management system is available to control the identified risks to the assessed standards, then a risk scoring, ranking and prioritisation approach may be useful to identify the preferred risk management option.

Options appraisal

C. What are the options for management of the identified risks?

Tier 1

5.10

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2
Stage1 Question Tier Options appraisal (see Figure 1) Tools & techniques - licensing Options appraisal framework (see DETR, Environment Agency and Institute for Environment & Health, 2000) Example - licensing See Chapter 2.3

In waste management licensing, the major


design options for the site will have been determined at the Phase 1 and 2 planning stages (see Table 1), with reference to the Best Practicable Environmental Option (BPEO). At the Phase 3 stage of environmental authorisation, the types and standards of risk management measures required will usually be determined by reference to generally accepted or defined best practice, except where otherwise defined and justified through either: - a risk scoring, ranking and prioritisation assessment; or - a Tier 2 or Tier 3 quantitative risk assessment. In waste management licensing, the identification of a plausible or likely link between the source of an environmental hazard via a potential pathway to a potential receptor is considered to be sufficient to warrant risk management measures being stipulated in the licence conditions, unless a more detailed technical assessment demonstrates that, for the site in question, the environmental risk is so low that such measures are unnecessary. For the example in question, the generic risk assessment of the hazard is that: The risks of dust emissions are adequately controlled through primary and residual risk management provisions specified in the Shell Risk Assessment and Shell Licence Template. The measures that will typically be required as best practice in managing this risk will be, as

Risk management

D. What needs to be done to minimise the environmental risks? There are 3 main risk management options: 1. reject the proposal altogether because it poses unacceptable risks; 2. accept whatever risk is imposed; 3. reduce the risk in some way, by doing one or more of the following: a) modifying the receiving environment or hazard; b) modifying or avoiding exposure; or c) modifying the effects or consequences of the risk.

Risk managem ent (see Figures 1 & 4)

In waste management licensing: 1. rejection of an application on the basis of unacceptable risk will usually need to be justified by a Tier 2 or Tier 3 risk assessment supported by a demonstration that the assessed risks cannot be adequately reduced by practicable design changes and/or risk management measures; 2. acceptance of whatever risk is imposed will usually need to be justified by a Tier 1, 2 or 3 risk assessment showing that the risk is insignificant and does not require any

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2
Stage1 Question Tier Tools & techniques - licensing specific risk management measures; 3. reducing the risk will usually be achieved through risk management measures which do one or more of the following: i) reduce the source risk through restricting waste types and waste operations; ii) reduce or restrict the exposure pathways, through engineered and operational containment; iii) control and minimise releases and emissions, through monitoring and action plans. Example - licensing specified in the Shell Risk Assessment and the Shell Licence Template: i) Waste acceptance procedures - exclusion of wastes consisting solely or mainly of powders See Chapter

ii) Waste control procedures- wastes which are likely to contain significant proportions of dusts, fibres, powders or particulates are only permitted if they are either: received in sealed containers and stored in sealed containers and in areas provided with impermeable pavement and sealed drainage; or stored in covered buildings providing containment of aerial emissions; or stored in roofed areas provided with a permanent water supply and bowsering equipment, and impermeable pavement and sealed drainage. Storage of these wastes in covered buildings providing aerial containment may be the required option when the identified receptors in the vicinity of the site include domestic dwellings, schools, hospitals, SSSIs or designated Habitats which are identified at Stage 4 as being at high risk of exposure to the hazard. Variation from these standards requires justification by an appropriate Tier 1, 2 or 3 risk assessment.

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2
Stage1 Question Tier Tools & techniques - licensing Example - licensing See Chapter

Risk based review

E. Does the risk assessment need to be reviewed or revised?

Tier 1, 2 or 3, as appropriate.

As appropriate, in accordance with the above.

Risk assessments should be reviewed, and revised as necessary: a) in order to resolve uncertainty in the results of the risk assessment and/or the standards and/or detail of the risk management measures provided; b) when modifications or changes are proposed in the standards, design or operation of the facility or any of the risk management measures provided; c) on a periodic basis, taking into account the environmental performance of the facility and changes in regulatory standards and best practice.

Notes: 1. Stages 1 to 5 are as described in DETR, Environment Agency and Institute for Environment & Health, 2000.

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 Appendix 2: Example of a source-pathway-receptor table for contaminated run-off from a transfer station handling household, industrial and commercial wastes
Source Hazardous events & Pathways Release of contaminated site run-off from Category 21, 22 and 24 wastes to the environment via ground, groundwater and surface water. Potential receptors Generic risk assessment for the waste types handled on typical sites of category Non-special waste types falling within the Category 21: Inert wastes: Insignificant risk of pollution of groundwater. Low/medium risk of pollution of adjacent surface water courses or bodies due to run-off from the site carrying suspended solids; consequent low/medium risk to ecosystems. Low/medium risk of run-off onto adjacent properties. Non-special waste types falling within the Category 22 and 24 waste types: Medium/high risk of pollution of groundwater. Medium/high risk of pollution of adjacent surface water courses or bodies; consequent medium/high risk to ecosystems. Medium/high risk of run-off onto and contamination of adjacent properties. Environmental risk management measures necessary to control assessed risks: default best practice standards for typical sites of this category Primary risk management systems: Provision of engineered site containment and drainage system. Waste control procedures: Inert (Category 21) wastes only permitted if stored in areas with either: hardstanding and drainage that prevents run-off from the waste into adjacent surface water bodies or storm water drains; or an impermeable pavement and sealed drainage. General and biodegradable (Category 22) and contaminated general (Category 24) wastes only permitted if stored in areas with impermeable pavement and sealed drainage and either: received in sealed containers and stored in sealed containers; or stored in covered shelters or roofed areas; or stored in bays. Shell licence template conditions 2.1.

Solid wastes which are likely to produce contaminated or polluting run-off.

Properties. Ecosystems. Surface water. Ground water. (People via above receptors.)

4.6. (supported by engineered containment under 2.1)

Risk phrases: Risk of contaminated run-off.

Example waste types (UKWC categories): 21, 22, 23, 24, 25, 26, 27, 28, 29, 30

4.2

Residual risk management systems: Control and remediation of spillages of waste. Groundwater monitoring systems: Groundwater monitoring should only be given consideration as a necessary requirement when a site-specific risk assessment demonstrates significant risk to groundwater in the vicinity of the site (this risk assessment should be provided by the Agency in the first instance). This should be given consideration where the site is situated within a groundwater protection zone (GPZ) or on a vulnerable major aquifer. It may be indicated by an OPRA Source score which is equal

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2
Source Hazardous events & Pathways Potential receptors Generic risk assessment for the waste types handled on typical sites of category Environmental risk management measures necessary to control assessed risks: default best practice standards for typical sites of this category to or greater than 15, combined with an Environmental Appraisal target-based score for Groundwater which is equal to or greater than 10. Surface water monitoring systems: Surface water monitoring should only be given consideration as a necessary requirement when a site-specific risk assessment demonstrates significant risk to surface water in the vicinity of the site (this risk assessment should be provided by the Agency in the first instance). This should be given consideration where the site is situated in the vicinity of a surface water body which is of high quality. It may be indicated by an OPRA Source score which is equal to or greater than 15, combined with an Environmental Appraisal target-based score for Surface Water which is equal to or greater than 10. Shell licence template conditions

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 Appendix 3: Sources of environmental hazard used in Library and Shell Risk Assessments Special wastes which have any of the following classifications and properties: H1: Explosive. Substances or preparations which may explode under the effect of a flame or which are more sensitive to shock or friction than dinitrobenzine. H2: Oxidising. Substances and preparations which exhibit highly exothermic reactions when in contact with other substances, particularly flammable substances. H3-A: Highly Flammable. i) Liquid substances and preparations having a flash point below 21C (including extremely flammable liquids); ii) substances and preparations which may become hot and finally catch fire in contact with air at ambient temperature without application of energy; iii) solid substances and preparations which may readily catch fire after brief contact with a source of ignition and which continue to burn or to be consumed after the removal of the ignition source; iv) gaseous substances and preparations which are flammable in air at normal pressure; v) substances or preparations which, in contact with water or damp air, evolve highly flammable gases in dangerous quantities. H3-B: Flammable. Liquid substances and preparations having a flash point equal to or greater than 21C and less than or equal to 55C. H4: Irritant. Non-corrosive substances and preparations which, through immediate, prolonged or repeated contact with the skin or mucous membrane, can cause inflammation. H5: Harmful. Substances and preparations which, if they are inhaled or ingested or if they penetrate the skin, may involve limited health risks H6: Toxic. H7: Carcinogenic. Substances and preparations which, if they are ingested or if they penetrate the skin, may induce cancer or increase its incidence. H8: Corrosive. Substances and preparations which may destroy living tissue on contact. H9: Infectious. Substances containing micro-organisms or their toxins which are known or reliably believed to cause disease in man or other living animals. H10: Teratogenic. Substances and preparations which, if they are inhaled or ingested or if they penetrate the skin, may induce non-hereditary congenital malformations or increase their incidence. H11: Mutagenic. Substances and preparations which, if they are inhaled or ingested or if they penetrate the skin, may induce hereditary genetic defects or increase their incidence.

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 H12: Substances or preparations which release toxic or very toxic gases in contact with water, air or an acid. H13: Substances and preparations capable by any means, after disposal, of yielding another substance, e.g. a leachate, which possess any of the characteristics listed above. H14: Ecotoxic. Substances and preparations which present or may present immediate or delayed risks for one or more sectors of the environment. Wastes (special or non-special) which have any of the following properties: Finely divided metal (H15) Dust or powder (H16; i.e. wastes which are in powder form F1). Solid wastes which are likely to give rise to significant amounts of dusts, fibres, powders or particulates, (i.e. wastes which can give rise to H16 hazards, but which are not in form F1: Powdery/powder when delivered). Pressurised gas (H17; including gaseous wastes, form F6). Odorous (H18); including wastes which are likely to give rise to harmful or offensive odours. Sharp (H19) Light (H20), including wastes which are likely to give rise to significant quantities of litter. Solid wastes (F2) which are likely to give rise to contaminated or polluting run-off. Viscous/ paste wastes (F3) or Sludge wastes (F4) or Liquid wastes (F5) which are likely to be contaminated or polluting. Combustible wastes (such as wood, paper, plastic); these are wastes which consist of or contain substances not falling into the Special wastes H3-A Highly flammable or H3-B Flammable classifications as such, but which are capable of self sustained burning in air, once ignited. Wastes which are likely to attract pests. Wastes which are likely to attract scavengers. Wastes or waste operations which are likely to give rise to mud or debris. Waste operations which are likely to give rise to loud and persistent/recurring noise.

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Appendix 4: OPRA Environmental Appraisal criteria referred to in Shell Risk Assessment approach [Note: The following examples have been extracted from Environment Agency, 2000e.] Screening risk assessments of aerial emissions: Human Dwellings. Population Density And Environmental Targets This attempts to categorise the likelihood of an event occurring by reference to the distance from the site and the consequence of an incident by considering sensitivity. The largest score for the site is to be incorporated within the model for the purposes of considering risks to human dwellings and/or environmental targets. In terms of sensitivity the following categories are considered:

(i) (ii) (iii)

High domestic dwellings, schools, hospitals and SSSIs (or equivalent) and beaches; Medium offices, industrial units, footpaths, major highways and local environmental areas; and Low minor roads and public open space.

In this way, the system attempts to categorise not only the sensitivity of a receptor but also the amount each is likely to be used. Distance <50 metres 50<250m 250<500m 500m High 20 15 10 5 Medium 15 10 5 1 Low 10 5 1 1

Screening risk assessments of emissions of contaminated liquids to groundwater: Groundwater It has not been possible to generate a matrix of probability against severity for this section as little site specific data is known. Therefore, it has been decided to use the Groundwater Vulnerability maps which identify the vulnerability of groundwater to contamination across the country in a similar manner. This has been based on the distribution of aquifers, the physico-chemical properties of overlying soils and the characteristics of strata in the unsaturated zone. It provides a consistent means of screening hydrogeological significance. A further group was added as inclusion within a Groundwater Protection Zone (GPZ) highlights actual use of the groundwater in the vicinity of the site (please note that at present not all GPZs have been mapped.) Depending on the size of the licensed abstraction, thought must be given to whether or not it should be included for this purpose as if it were within a GPZ even if the abstraction is too small to be formally quantified as such. Designation Within GPZ Major Minor Non-aquifer National Centre for Risk Analysis and Options Appraisal Rank/points 15 10 5 1 Page 65

A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 Screening risk assessments of emissions of contaminated liquids to surface water: Surface water The following system is based on the River Ecosystem Classification (RE) which has been assigned by the Environment Agency. This classification is based on an identification of what work needs to be undertaken to meet the specified target. This information is available from the relevant Local Environment Action Plan document. The consequence has been subdivided into the following sections based upon the River Ecosystem Classification, High (RE1 and RE2), Medium (RE3 and RE4) and Low (RE5). The consequence should be based on current RE classification. The distance to the surface water target should be calculated from the edge of the site although there should be consideration of site specific factors. Where the pathway to the surface water is direct i.e. via an outfall pipe then it should be assumed that the distance to the pipe is the distance to surface water i.e. adjacent rather than 250m. Also where no RE classification exists then the nearest downstream one should be used. For estuaries the nearest upstream RE classification should be used. where two RE classifications exist in similar proximity to the site then consideration should be given to the most likely route of any discharge and the approariate classification inserted. The general assumptions in this section are that a canal is not generally in hydraulic continuity with the groundwater and unless there is a direct discharge to the canal from the facility then it should have the score halved. All ponds, streams and rivers etc qualify for consideration as surface water.

Distance Adjacent <50 metres 50<250m 250

High 15 10 5 1

Medium 10 7 3 1

Low 7 3 1 1

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 Appendix 5: Risk prioritisation assessment example (See section 5.10 for guidance on the uses and shortcomings of this type of assessment.) In this example, all identified risks are rated and prioritised through a scoring system, with those of most risk to the environment or human health showing a higher score. The risk comprises two elements, the probability and the consequences, which are semi-quantitatively estimated and combined to produce a risk factor. For each estimated risk, appropriate protective measures, controls and action plans are identified, along with an assessment of their mitigating effects. These are combined with the assessed risk factor to produce a mitigated risk factor for each risk.. The scoring system is defined as follows:Probability of hazard occurring: Consequences of hazard to environment or human health: 0 5 10 15 20 25 Harmless Almost harmless Some harm Harmful Very harmful Extremely harmful the Mitigation to risk:

0 1 2 3 4 5

Never Annually or less frequently Monthly or less frequently Weekly or less frequently Daily or less frequently More frequently than daily

1 2 3 4 5

Ineffective or non existent Partly effective Effective Very effective Entirely effective

Risk factor = Probability x Consequence Mitigated Risk Factor = Risk factor Mitigation factor

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Hazard

Pathway and Receptor

Probability of Hazar d 4

Consequence of Hazard

Risk factor (= Probability x Consequence)

Protective Measures / Controls (Mitigation)

Mitigation factor

Mitigated Risk Factor (= Risk factor Mitigation factor)

Contamination of surface waters by runoff from waste storage areas.

Contaminated runoff from rapidly biodegradable wastes, such as paper, cardboard, entering surface water systems or ground water via surface drainage, site ditches.

10

40

Contamination of surface water, or breach of leachate/ surface water discharge consent limits Inhalation of dust

Contaminated runoff from more slowly biodegradable wastes, such as wood, green waste. Contaminated runoff from nonbiodegradable wastes, such as soils, concrete, hardcore. Acceptance of wastes outside site design limits (unacceptable wastes), resulting in storage on inappropriate areas, contamination of surface water resources or leachate quality in excess of consent limits. Generation of dusts by waste discharge, handling and wind. Inhalation by site operatives and humans at site boundary of nuisance dusts only due to restricted range of wastes.

10

20

10

10

15

30

Storage in specified areas on impermeable pavement, with sealed drainage system. Limit on maximum storage times to reduce potential for biodegradation. Storage of unsorted wastes within enclosed building or of segregated wastes in enclosed containers. Storage in specified areas on impermeable pavement, with sealed drainage system. Storage in specified areas on hardstanding. Wastes nonbiodegradable or inert. Implementation of waste acceptance and control systems, including assessment of wastes prior to delivery, on site inspection and waste handling protocols. Undertake operations involving commercial, industrial and unsorted wastes within enclosed building, with ventilation. Implementation of dust suppression measures including water sprays/ sprinkler systems. Use of concrete hardstanding for external materials storage.

10

50

12.5

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Hazard Pathway and Receptor

Probability of Hazar d 5

Consequence of Hazard

Risk factor (= Probability x Consequence)

Protective Measures / Controls (Mitigation)

Mitigation factor

Mitigated Risk Factor (= Risk factor Mitigation factor)

Nuisance odours

Windborne odours from biodegradable wastes, detectable at site boundary by general public. Greater perception of nuisance than actual harm itself.

25

Unacceptable noise levels

Noise generation by use of recycling equipment and plant movement. Impacts upon residential properties and persons in vicinity of site boundary. Greater perception of nuisance than actual harm itself.

25

All operations involving storage of biodegradable wastes (except sorted wood) to be undertaken inside building. Limit on maximum storage time for biodegradable wastes to prevent advanced stage of biodegradation. Wastes sorting and primary activities to be undertaken inside enclosed building, reducing impact at site boundary. Secondary activities (crushing/wood chipping) undertaken outside will only be periodic when sufficient materials are available for activities. Screening around recycling area will attenuate noise. Operations will be restricted to Planning Permission hours, limiting duration of impact. Site not accepting domestic wastes or waste types likely to include large quantities of food wastes. Storage of relevant wastes types within building will deter pests. Use of specialist pest control contractor.

Attraction of pests to site, spread of disease.

Attraction of pests to site due to storage of biodegradable wastes. Small quantities of contamination by food may exist. Spread of disease by rats and flies to persons outside site. Also nuisance to residents near site.

10

30

10

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Hazard Pathway and Receptor

Probability of Hazar d 5

Consequence of Hazard

Risk factor (= Probability x Consequence)

Protective Measures / Controls (Mitigation)

Mitigation factor

Mitigated Risk Factor (= Risk factor Mitigation factor)

Bird nuisance

Litter nuisance

Attraction of birds to site due to storage of biodegradable wastes. Small quantities of contamination by food may exist. Nuisance to residents near to site and possible spread of litter and disease. Greater perception of nuisance than actual harm itself. Spread of windblown litter (paper, cardboard, plastics, etc.) to adjoining parts of the site and beyond site boundary. Visual amenity impact. Hygiene issues. Greater perception of nuisance than actual harm itself.

25

20

Site not accepting domestic wastes or waste types likely to include large quantities of food wastes. Storage of relevant waste types within building will effectively exclude birds from contact with waste and deter presence. Storage of relevant waste types within an enclosed building or of appropriate sorted materials in enclosed containers on site. Site inspections for presence of litter and clearance of any found. Sheeting and netting of delivery vehicles.

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 Appendix 6: Quantitative assessments: Imaginary Landfill, England Imaginary Landfill was constructed to receive industrial waste with limited putrescible content from a nearby town. Completed in the early 1990s, it includes a composite liner and is relatively small in size. An extension to the landfill is now proposed and the Environment Agency requires that as part of the waste management licensing process a Regulation 15 assessment be carried out to predict the likely impact on groundwater and compliance against the requirements of the Groundwater Directive. Separate risk assessments are to be undertaken for other processes including migration of, and exposure to landfill gases, construction and durability of engineered barriers and leachate management systems, and impacts on ecological systems including a nearby site of special scientific interest (SSSI).

Infiltration

Monitoring borehole

Waste

List substance Watertable

Assess impacts for List 1 substances at entry to watertable

Layered aquifer

Assess impacts for List II substances at borehole

The landfill is underlain by strata that are classified as Minor Aquifer by the Environment Agency, and consists of inter-bedded clays, silts and sands. Hydraulic continuity is assumed between the sandstone horizons on the basis of the hydraulic response to local pumping tests, which indicate a (saturated) aquifer hydraulic conductivity between 1.0 E-5 m/s and 3.4 E-6 m/s. Laboratory analysis of samples indicates sediments have a cation exchange capacity of 5-15 meq/100g, and reaction efficiency between 5 and 15%. Faulting is generally absent. The regional hydraulic gradient is 0.05 towards the south-east. On-site permeability testing and laboratory testing of unsaturated cores indicate an hydraulic conductivity of about 1.0E7m/s to 1.0E-9 m/s depending on the lithology tested. Porosity does not exceed 30% and the moisture content of core samples lies between 5 and 7%. The winter watertable lies at an average of 15m below the site and effective rainfall is estimated at approximately 250 mm/a on the basis of MORECS data.

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 Following conceptualisation of the site, surroundings and processes it has been agreed between the Agency and the developer that LandSim is an appropriate assessment tool in this instance. As part of data collection for inclusion in the LandSim assessment, existing leachate chemistry from the previous phase of landfilling was undertaken and compared with published data that relate to the anticipated waste stream. In addition a List I screen was undertaken (as described in the Agencys interpretation on Reg15), and trichloroethene identified as being present in elevated concentrations. Examination of landfill records suggests this originates from the industrial waste received at the site. The operators consultant has carried out a Landsim assessment on the existing site as a first stage and a summary of the input data is given in Table A6.1. The landfill has been modelled assuming a porous medium with no accounting for retardation. It has been agreed that the compliance point for licence conditions shall be shall be a monitoring borehole immediately downgradient of the site, while predictive assessments for List II substances and non-listed substances will be made for a point beneath the site. Assessments of List I substances will be made against the predicted impact on groundwater quality as the leachate enters the watertable directly beneath the landfill. The LandSim assessment models the performance of the landfill under normal conditions, i.e. it assumes that the engineering performs as designed throughout the operational life of the site. An additional assessment of risks associated with catastrophic failure of the site was undertaken using qualitative methods. In this instance, an assessment was made of the likelihood and consequence of the HDPE tearing due to ground instability, and of a large puncture of the basal liner during waste deposit by, for example, a scaffolding pole. Table A6.1: Summary of Imaginary Landfill data for LandSim
Min value Most likely Max Value value 45 50 Justification 55 Capped landfill

INFILTRATION (mm/a) LEACHATE SOURCE: Leachate Inventory (mg/l) ammoniacal_N chloride mercury trichloroethene Drainage System (piped) Specified Head on EBS (m) Engineered Barrier System K of mineral lower liner (m/s) Membrane defects (/hectare) Pin holes Holes Tears Design thickness of liner Variability in liner thickness Width (m) Cell Geometry 100

4 40 0.00004 0 0 1.00E-10 0 0 0 1m 5% Length (m) 120

200 2300 0.00009 0.1

500 Based on Robinson 1995 7800 & on-site leachate data. 0.002 0.2 1 licence requirement

1.00E-09 25 5 0.1

1.00E-08 LandSim default values 25 5 2

Number 1

Top area (m2) 18000

Base area (m2) 12000

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A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 Table A6.1: Summary of Imaginary Landfill data for LandSim (contd)
Min value UNSATURATED PATHWAY PARAMETERS: Length (m): Moisture content (%) K (m/s) Porosity Longitudinal dispersivity Transverse dispersivity CEC (meq/kg) Reaction Efficiency VERTICAL PATHWAY (assumed negligible): Pathway length (m) AQUIFER PATHWAY PARAMETERS: Length (m) Width (m) Mixing Zone (m) Porosity Regional gradient K (m/s) Longitudinal dispersivity Transverse dispersivity CALCULATION SETTINGS: Number of iterations Timeslices at (years): Max Value Justification

14 5 1.00E-09 0.05 0 0 50 0.05

16 Depth to watertable from boreholes 7 Laboratory analysis 1.00E-07 Lab analysis & on-site measurements 0.3 Laboratory analysis 1 Default values (0.1 pathway length) 0.1 Default values (0.01 pathway) 150 Sand/Silt/Clay strata 0.15

0.0001 Unconfined aquifer

0 140 5 0.1 0.01 3.4E-06 0 0

160 Receptor south-east corner of site (List II); receiving GW (List I) 160 Cell width parallel to flow 15 Borehole logs 0.3 Laboratory analyses 0.05 [NB: 0.05 most likely] 1.00E-05 Pumping test results 10 Default values (0.1 pathway length) 1 Default values (0.01 pathway length) Key: CEC: Cation Exchange Capacity K: Hydraulic Conductivity

5000 30, 100, 300, 1000

The results from the LandSim model are summarised in Table A6.2. Although there are small variations in concentrations between each run the results appear acceptable for most compounds. The exceptions are ammoniacal nitrogen and trichloroethene (TCE). Table A6.2: Predicted Contaminant Concentrations in Groundwater, Imaginary Landfill (Selected confidence limits)
Time (years) Concentrations Predicted Ammonical_N (mg/l) Chloride (mg/l) Mercury (mg/l) Trichloroethene (mg/l) 95%-ile 99%-ile 95%-ile 99%-ile 95%-ile 99%-ile 95%-ile 99%-ile 30 1.00E-30 1.00E-30 3.94E+01 1.34E+02 1.00E-30 1.00E-30 6.23E-04 6.66E-03 100 1.00E-30 1.00E-30 5.59E+01 1.51E+02 1.00E-30 1.00E-30 1.13E-03 7.43E-03 300 1.00E-30 5.68E+00 5.75E+01 1.53E+02 1.00E-30 1.00E-30 1.25E-03 7.64E-03 1000 1.00E-30 1.06E-01 5.75E+01 1.53E+02 1.00E-30 1.00E-30 1.25E-03 7.64E-03 Infinity 1.00E-30 1.23E+01 3.94E+01 1.34E+02 1.00E-30 1.00E-30 6.23E-04 6.66E-03

Ammonia exceeds the maximum admissible concentration in groundwater at 300 years and infinity (at a 99 percentile confidence limit). There is a domestic abstraction 200m from the site and the Environment Agency will therefore need to be satisfied that the ammoniacal National Centre for Risk Analysis and Options Appraisal Page 73

A Practical Guide to Environmental Risk Assessment for Waste Management Facilities Guidance Note 25 Version 2 nitrogen concentration will remain below drinking water standards (0.5 mg/l) a short distance down-gradient of the landfill site. An appropriate contaminant transport model would need to be used for this purpose. If drinking water standards are not achieved an improved containment system or a reduction in the putrescible waste would be required before the Agency would accept any extension to the site. Trichloroethene is predicted at a maximum of 1.25E-03 mg/l at the 95%ile confidence limit. This equates to 1.25 g/l, which although below the drinking water standard of 30 g/l, is still discernible against background quality and could represent a discharge of List I substances. Following further discussion between the developer and the Agency, it was agreed that LandSim did not include all the mechanisms that might be expected to affect the fate and transport of TCE in the subsurface. TCE is biodegradable under anaerobic conditions and adsorbs to organic material, and these conditions are known to exist below the landfill where leachate has entered the unsaturated zone. In order to validate the model, the predictions were compared against existing monitoring data collected from the existing cell. Although TCE is found in the leachate within the site, there has never been any TCE recorded in the groundwater monitoring boreholes. As a result, it was agreed that the predicted leakage of TCE though the engineered barrier would be unlikely to cause a discharge of list I substances to groundwater, provided that the engineered barrier performed as modelled. Comprehensive and clear reports were submitted to the Environment Agency as part of the submission for a waste management licence. The conceptual model was clearly described and drawings and cross sections clearly annotated. All input laboratory and literature derived data used in the quantitative modelling process were fully documented and justified.

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