This high level review of NSW Resource Recovery Frameworks covers a broad range of issues regarding the beneficial reuse of wastes. Key issues and recommendations include:
- Expand use of soil conditioners, for specific land areas, such as denuded farmland. All published RROEs can be applied anywhere in NSW, hence the most sensitive land is the trigger. Certain low risk materials have high concentrations of minerals which are currently replaced in farmland by fertilisers. By specifying land zones, such as denuded farmland, and having more specific delivery controls such an approach can help farmers and reduce waste to landfill.
- Specific use of scientific methodologies to set criteria which can vary according to land areas and their local environments. Some extracted materials come from high background areas and may breach their RROs even if going back into the same soil types.
- Publish the scientific methodologies with specific cases used to make RROEs. ASBG provides evidence of ALARA being used rather than good scientific methods and risk weighted approaches.
- Improve environmental protection by increased policing, teaming with landowners etc, use and support of industry based quality control methods and better forewarnings of emerging contaminants.
- Reform environment licensing and planning legislation to remove road blocks and assist emerging, new and innovative processes at pilot plant and small scale commercial demonstration plant scales
- Ensure the RRF is open to all technologies and process that can meet the scientific based environmental conditions and avoids picking ‘winners’.
- Implement the End of Waste provision for wastes, which meet risk criteria, to avoid the need for Waste Storage licences at post producers’ sites. It will also draw the line of when a RRO material is a waste or can be treated as a product, reducing EPA’s oversight.
- NSW EPA to adopt the standard AS 4964 for asbestos measurement.
- All methodologies used to make RROE criteria are transparent and based on good scientific methods, which should be ring-fenced from other influences, such as public or local opinion.
- NSW Waste Classification Guidelines to add in general fill material criteria, but where these limits can be subject to exemptions where specific RROEs are used for lower risk source materials.
- Improved sampling methods which are standardised—to remove sampling from RROs—but also accept demonstrated statistical methods.
Given the scope of the review there are many case studies and other supporting documents, member experiences and other details which are better conveyed on a case by case basis.
