TASK A3 
                   
    ...
IMPROVEMENT OF INDUSTRIAL HAZARDOUS WASTE MANAGEMENT
                      IN TURKEY

               LIFE “HAWAMAN” PROJEC...
TABLE OF CONTENTS

1 INTRODUCTION ...........................................................................................
LIST OF TABLES

Table 1.1: Contribution of basic economic sectors to GDP (based on current prices) 2 ........................
LIST OF FIGURES

Figure 1.1: Chronology of Population Growth, Turkey ........................................................
Figure A. 16 Provincial distribution of halogenated waste oil (ID No:15).....................................................
1       INTRODUCTION

Fundamentals of hazardous waste management are laid down on various policy
and legislative documents...
Figure 1.1: Chronology of Population Growth, Turkey

In Figure 1.2, population pyramid of Turkey is given. The shape of th...
Figure 1.3 below and Table A. 2 in Appendix present the countrywide
distribution of population. The major center of gravit...
Figure 1.4 Chronology of GNP of Turkey




                                      Turkey - Inflation Rate in %
           7...
Table 1.1: Contribution of basic economic sectors to GDP (based on current prices) 3

                                    ...
Đstanbul - about 27 %, followed by Bursa (8.3 %), Đzmir (7.1 %), Kocaeli (5.1 %)
and Ankara (5.0 %). All other districts a...
Figure 1.7 Employees in Turkish Metal Industry




Figure 1.8 Employees in Turkish Chemical Industry




                 ...
Figure 1.9 Employees in Turkish Other Industries




                                                   8
2     LEGISLATIVE FRAMEWORK AND STAKEHOLDERS                                       OF
      HAZARDOUS WASTE MANAGEMENT

2....
Among these regulations listed in Table 2.1, Regulation on General Principles of
Waste Management and RCHW are the core re...
step where hazardous wastes are accumulated before being sent to temporary
storage facilities, treatment or disposal sites...
Mirror entries: wastes that have the potential to be either hazardous or not,
    depending on whether they contain “dange...
Step 4b: Is the waste produced as a result of processes listed in RCHW Annex 3?

RCHW Annex 3 lists activities that can ge...
Step 6a: Does the waste possess hazardous properties of H1,2,9,12-14?

When a waste posses hazardous properties of H1,2,9,...
of in licensed facilities. Throughout these processes, waste generator shall
provide labeling and packaging in a proper an...
Waste Disposal

Liquid wastes suitable for pumping can be disposed of by injection into
geologically and hydrogeologically...
transboundary movement of waste into that country. Neither transit passages nor
transshipments and transfer of wastes are ...
Figure 2.2 Main duties, responsibilities and jurisdiction in the hazardous waste management
system

                      ...
3   DEVELOPMENT OF HAZARDOUS WASTE MANAGEMENT
    SYSTEM IN TURKEY

MoEF has participated in and completed a number of pro...
waste. The regions for which the hazardous waste incineration and disposal
facilities will serve are shown in Figure 3.1.
...
facilities need to be inspected by Ministry of Environment and Forest thoroughly.
In this context, these facilities are ob...
Measures for waste avoidance recommended by Waste Management Twinning
Project were listed as:

   o Cooperation between pr...
o Recycling of the immanent raw materials of waste and material use
                 for other purposes than production
  ...
4   CURRENT  SITUATION                     OF       HAZARDOUS              WASTE
    MANAGEMENT IN TURKEY

Rising environm...
Table 4.1 Number of plants and recycle/recovery activities (June 2007)

         CODE OF                        NUMBER OF ...
in factories. Waste tyres, 1st and 2nd type of waste oils, dye sludge, solvents and
plastic wastes can be disposed in ceme...
Table 4.4 Waste incineration capacity of PETKĐM is 17.500 tones/year. Less than
half of the capacity (7500 tones/year) is ...
Kırtıllı Tepe Mevkii Sandal Beldesi     20.000 tons/yr       Incinerator   in
Kula - Manisa                               ...
5     HAZARDOUS WASTE MANAGEMENT CONCEPT

5.1    HAZARDOUS WASTE QUANTITY ESTIMATION

The Twinning project "TR03/EN/IB-01 ...
quantities and qualities, which will change due economic development or
structural changes in industry etc. Moreover, it d...
But even with a long time existing hazardous waste management system the
Waste Transportation Forms will not give 100% rel...
This method gives a rough estimation about hazardous waste generation in a
country or in a region. Large amount of such da...
While comparing waste factors from other countries following items should be
kept in mind:
   o big waste ratios are mainl...
This result with the distribution of the amounts of the different types of
hazardous waste is exactly the result that is r...
with very big amounts of hazardous waste and to integrate these values in results
obtained from current approach. It's ess...
o EWC 200123/135 Electrical Equipment
are excluded in our waste quantity estimation.

In order to estimate the waste quant...
Step five: Creation of Table A. 3 given in Appendix.

The basic data for capita, vehicles, agricultural employees and GNP ...
economy as given in Introduction section of this report were considered. In Table
5.3, a sample waste sector sheet is pres...
fluorescent tubes and other mercury-containing
  200121                                                                 0,...
As mentioned before, 28 waste groups were identified for reporting purposes.
Table 5.4 lists the amount of hazardous waste...
Table 5.4 Description and amount of hazardous waste groups in tons/yr

  ID                                               ...
Table 5.4 Continued

  ID                                                        SUBSUMES EWC
                            ...
Geographic distribution of hazardous wastes

Table 5.5 below, summarizes the geographic distribution hazardous wastes in
t...
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A3 concept final_version

  1. 1.                                         TASK A3    HAZARDOUS WASTE MANAGEMENT  CONCEPT FOR TURKEY     
  2. 2. IMPROVEMENT OF INDUSTRIAL HAZARDOUS WASTE MANAGEMENT IN TURKEY LIFE “HAWAMAN” PROJECT LIFE06/TCY/TR/000292 TASK A3 HAZARDOUS WASTE MANAGEMENT CONCEPT FOR TURKEY
  3. 3. TABLE OF CONTENTS 1 INTRODUCTION ..................................................................................................... 1 2 LEGISLATIVE FRAMEWORK AND STAKEHOLDERS OF HAZARDOUS WASTE MANAGEMENT ...................................................................................... 9 2.1 LEGISLATIVE FRAMEWORK ................................................................................. 9 2.2 STAKEHOLDERS OF HAZARDOUS WASTE MANAGEMENT ..................... 17 3 DEVELOPMENT OF HAZARDOUS WASTE MANAGEMENT SYSTEM IN TURKEY ................................................................................................................. 19 4 CURRENT SITUATION OF HAZARDOUS WASTE MANAGEMENT IN TURKEY ................................................................................................................. 24 5 HAZARDOUS WASTE MANAGEMENT CONCEPT ....................................... 28 5.1 HAZARDOUS WASTE QUANTITY ESTIMATION ........................................... 28 5.1.1 Methodology ..................................................................................................................... 29 5.1.2 Waste estimation .............................................................................................................. 34 5.1.3 Comparison and validation of results .............................................................................. 45 5.2 ASSIGMENT OF HAZARDOUS WASTE TYPES TO DISPOSAL OPTIONS . 48 5.2.1 Methodology ..................................................................................................................... 48 5.2.2 Allocation to Different Disposal Routes .......................................................................... 53 6 CONCLUSIONS...................................................................................................... 59 7 . RECOMMENDATONS........................................................................................ 62 APPENDIX ................................................................................................................. 65 ii
  4. 4. LIST OF TABLES Table 1.1: Contribution of basic economic sectors to GDP (based on current prices) 2 .............................. 5 Table 2.1 List of Turkish legislation on hazardous wastes .................................................................................... 9 Table 4.1 Number of plants and recycle/recovery activities (June 2007)......................................................25 Table 4.2 Types of recyclable wastes admitted to licensed recycling facilities and their capacities... 25 Table 4.3 Wastes used as alternative fuels in cement factories .........................................................................26 Table 4.4 Current capacities of disposal facilities ...................................................................................................27 Table 4.5 Integrated Waste Disposal Facilities ........................................................................................................27 Table 5.1 Covered and omitted waste types and producers ................................................................................34 Table 5.2 List of industrial sector groups ...................................................................................................................37 Table 5.3 Sample waste sector sheet for metal working industry ....................................................................37 Table 5.4 Description and amount of hazardous waste groups in tons/yr ...................................................40 Table 5.5 Geographic distribution of hazardous wastes (1000 tons/yr) .......................................................42 Table 5.6 Comparison of Turkish and German hazardous waste generation ..............................................45 Table A. 1 List of NUTS codes for Turkey ....................................................................................................................65 Table A. 2 Turkish population (2007) ..........................................................................................................................66 Table A. 3 Number of employees in Turkish industry (2007) ..............................................................................69 Table A. 4 Additional information for provinces ......................................................................................................70 Table A. 5 Hazardous waste in Turkey, from industry and other sources in tons/yr ................................72 Table A. 6 Hazardous waste from main industrial sectors in tons/yr .............................................................74 Table A. 7 Hazardous waste from non-industrial sources in tons/yr ..............................................................76 Table A. 8 Hazardous waste from industrial branches in tons/yr ....................................................................78 Table A. 9 Hazardous waste groups in Turkish provinces in tons/yr ..............................................................88 Table A. 10 Range of disposal market prices (€/ton) - (Germany 2002 and Turkey 2007)................. 107 Table A. 11 Assignment of hazardous waste to disposal options .................................................................. 111 Table A. 12 Structure of the price list for hazardous waste incineration in Turkey (2007) ................ 108 Table A. 13 Structure of disposal prices for CPT treatment from Germany (HIM 2002) ...................... 110 iii
  5. 5. LIST OF FIGURES Figure 1.1: Chronology of Population Growth, Turkey ............................................................................................ 2 Figure 1.2: Population Pyramid, Turkey (2006) ........................................................................................................ 2 Figure 1.3 Distribution of Population in Turkey ....................................................................................................... 3 Figure 1.4 Chronology of GNP of Turkey ....................................................................................................................... 4 Figure 1.5 Chronology of Inflation Rate of Turkey .................................................................................................... 4 Figure 1.6 Employees in Turkish Industry, total ........................................................................................................ 6 Figure 1.7 Employees in Turkish Metal Industry ....................................................................................................... 7 Figure 1.8 Employees in Turkish Chemical Industry ................................................................................................ 7 Figure 1.9 Employees in Turkish Other Industries .................................................................................................... 8 Figure 2.1 Steps to be followed to determine a hazardous waste according to RCHW ............................12 Figure 2.2 Main duties, responsibilities and jurisdiction in the hazardous waste management system .....................................................................................................................................................................................................18 Figure 3.1 Hazardous waste management regions ................................................................................................20 Figure 5.1 Production in 1 or 3 facilities: material balance differs by factor three ...................................30 Figure 5.2 Hazardous waste generation in Turkey, total .....................................................................................43 Figure 5.3 Hazardous Waste Generation in Industry (81 %) .............................................................................43 Figure 5.4 Hazardous Waste Generation from separately collected waste (19 %) ...................................44 Figure 5.5 Hazardous waste amounts in several countries versus GNP “power parity” ..........................47 Figure 5.6 Recommended hazardous waste disposal routes for Turkey – overview .................................54 Figure 5.7 Recommended hazardous waste disposal routes to recycling/recovery ..................................54 Figure 5.8 Recommended hazardous waste disposal routes to CPT ................................................................55 Figure 5.9 Recommended hazardous waste disposal routes to thermal treatment ..................................55 Figure 5.10 Recommended hazardous waste disposal routes to controlled landfill .................................56 Figure 5.11 Scheme of a fully integrated hazardous waste treatment / disposal facility .......................58 Figure 6.1 Five recommended planning areas for integrated hazardous waste treatment facilities 61 Figure 6.2 Locations of 189 mostly private operating hazardous waste treatment facilities in Turkey .....................................................................................................................................................................................................61 Figure 7.1 Locations and numbers of municipal sewage treatment plants in Turkey ..............................63 Figure A. 1 Number of employees in Turkish Industry (2007) ...........................................................................67 Figure A. 2 Provincial distribution of pesticides and agrochemical hazardous wastes (ID No:1) .......94 Figure A. 3 Provincial distribution of wood preservative wastes (ID No:2) ..................................................94 Figure A. 4 Provincial distribution of hazardous tannery wastes (ID No:3) .................................................95 Figure A. 5 Provincial distribution of hazardous petroleum refining wastes (ID No:4) ...........................95 Figure A. 6 Provincial distribution of acidic and alkaline wastes (ID No:5) .................................................96 Figure A. 7 Provincial distribution of hazardous inorganic chemistry wastes (ID No:6) ........................96 Figure A. 8 Provincial distribution of hazardous organic chemistry wastes (ID No:7) ............................97 Figure A. 9 Provincial distribution of hazardous paint and sealant production wastes (ID No:8) ......97 Figure A. 10 Provincial distribution of hazardous printing wastes (ID No:9)..............................................98 Figure A. 11 Provincial distribution of hazardous energy production wastes (ID No:10) ......................98 Figure A. 12 Provincial distribution of hazardous metal production wastes (ID No:11) ........................99 Figure A. 13 Provincial distribution of hazardous mineral and glass production wastes (ID No:12) 99 Figure A. 14 Provincial distribution of hazardous galvanizing wastes (ID No:13) ................................. 100 Figure A. 15 Provincial distribution of non-halogenated waste oil (ID No:14) ........................................ 100 iv
  6. 6. Figure A. 16 Provincial distribution of halogenated waste oil (ID No:15).................................................. 101 Figure A. 17 Provincial distribution of waste oil emulsions (ID No:16) ....................................................... 101 Figure A. 18 Provincial distribution of other oily wastes (ID No:17) ............................................................ 102 Figure A. 19 Provincial distribution of halogenated solvents (ID No:18) ................................................... 102 Figure A. 20 Provincial distribution of non-halogenated solvents (ID No:19) .......................................... 103 Figure A. 21 Provincial distribution of contaminated packagings (ID No:20) ......................................... 103 Figure A. 22 Provincial distribution of spent adsorbents and filter materials (ID No:21) ................... 104 Figure A. 23 Provincial distribution of spent oil filters (ID No:22) ................................................................ 104 Figure A. 24 Provincial distribution of spent brake fluids and antifreeze (ID No:23)............................ 105 Figure A. 25 Provincial distribution of spent batteries (ID No:24) ................................................................ 105 Figure A. 26 Provincial distribution of sludges from CPT (ID No:26) ........................................................... 106 Figure A. 27 Provincial distribution of mercury containing waste (ID No:27) ......................................... 106 Figure A. 28 Provincial distribution of contaminated wood (ID No:28)...................................................... 107 Figure A. 29 Recommended hazardous waste disposal routes to recycling/recovery – amount per province ................................................................................................................................................................................. 119 Figure A. 30 Recommended hazardous waste disposal routes to CPT – amount per province .......... 121 Figure A. 31 Recommended hazardous waste disposal routes to thermal treatment – amount per province ................................................................................................................................................................................. 123 Figure A. 32 Recommended hazardous waste disposal routes to controlled landfill – amount per province ................................................................................................................................................................................. 125 v
  7. 7. 1 INTRODUCTION Fundamentals of hazardous waste management are laid down on various policy and legislative documents. International principles on which hazardous waste management concept is developed include “Precautionary Principle”, “Waste Hierarchy” and “Polluter Pays”. These principles are embedded in legislative documents according to which modern hazardous waste management systems are developed and successfully established. Turkish Regulation on Control of Hazardous Wastes (RCHW)1, harmonized with Directive of European Commission on hazardous wastes (91/689/EEC), being the core regulation on hazardous waste management, also includes these principles of hazardous waste management. Even though baseline of hazardous waste management is presented, it is essential to develop an elaborate hazardous waste management concept for Turkey in order for the waste management system to be realistic and efficient. This concept should especially consider practical aspects unique to Turkey. Hazardous waste management concept presented in this report is developed under Task A and Task C of LIFE HAWAMAN Project by German Experts, Turkish Experts and Ministry of Environment and Forestry (MoEF). In the context of this report, in Chapter 2, legislative framework concerning hazardous wastes, in Chapter 3, current situation of hazardous waste management and stakeholders of the system and in Chapter 4, hazardous waste management concept as developed by LIFE Team are introduced. Before presenting hazardous waste management concept, it is quite useful for the reader to acquire some background information on Turkey. These include demographic and economic information both of which influences hazardous waste generation amounts and distribution. Population of Turkey shows a rapid increase since the 1960s. As seen in Figure 1.1, population increased from about 30 Million in 1960s to about 71 Million in 2007 with a smooth turning range in the 1980s. Simple statistical analysis proves that population growth of Turkey resembles arithmetic growth model with a nice linear fit of r2= 0.997. 1 Official Gazette, 14/3/2005, No. 25755. 1
  8. 8. Figure 1.1: Chronology of Population Growth, Turkey In Figure 1.2, population pyramid of Turkey is given. The shape of the population pyramid looks sustainable at present with a high percentage of younger people compared with a small percentage of older people. This shape of the pyramid suggests high potential for productivity as result of high number of younger people thus high number of work force. Figure 1.2: Population Pyramid, Turkey (2006) 2
  9. 9. Figure 1.3 below and Table A. 2 in Appendix present the countrywide distribution of population. The major center of gravity of the Turkish population by far is Đstanbul, with more than 12 Million people. Very low populated districts are to be found in the eastern part of Turkey, like Tunceli or Bayburt (each much less than 100 000 people). Figure 1.3 Distribution of Population in Turkey 2 As mentioned before another important set of background information is the economic figures. Gross National Product (GNP) is the total monetary value of all final goods and services produced for consumption in society during a particular time period and a very strong parameter indicating economic activity. Within the last decade there is a remarkable increase in GNP (Figure 1.4), along with a strong decrease of the inflation rate (consumer prices) (Figure 1.5). Apparent from Figure 1.4 and Figure 1.5, Turkish economy between the years 2002-2007 has shown significant improvement. Average growth of economy reached up to 7% and increase in export reached 23% 3. 2 List of NUTS codes used throughout the report is given in Table A. 1 in Appendix. 3 The Union of Chambers and Commodity Exchanges of Turkey (TOBB), Economy Report 2008, Available from http://www.tobb.org.tr/yayinlar/64gk/ekonomik%20rapor.pdf , Data retrieved May 22, 2009 3
  10. 10. Figure 1.4 Chronology of GNP of Turkey Turkey - Inflation Rate in % 70 60 50 40 30 20 10 8.5% Source: Index Mundi (2008) 0 2000 2002 2004 2006 2008 Figure 1.5 Chronology of Inflation Rate of Turkey This rapid development in economy has ceased in 2007 due to the effects of global economic crisis. As a result, the average growth in the economy was 4.7% in 2007, 3.6% in the first nine months of 2008, and 1.1% in whole year of 2008 3. In Table 1.1, contribution of economic sectors to gross domestic product (GDP) is given. 4
  11. 11. Table 1.1: Contribution of basic economic sectors to GDP (based on current prices) 3 CONTRIBUTION TO GDP SECTOR (%) 2006 2007 2008 Agriculture, hunting and forestry 8.0 7.4 7.6 Fishing 0.2 0.2 0.2 Mining and quarrying 1.2 1.2 1.4 Manufacturing Industry 17.2 16.8 16.1 Electricity, gas, steam and hot water generation and 1.8 1.9 2.1 distribution Construction 4.7 4.9 4.7 Wholesale and retail commerce 12.5 12.2 12.2 Hotels and restaurants 2.2 2.3 2.3 Transportation, storage and communication 13.7 13.9 14.2 Activities of financial factors 2.9 3.2 3.5 Residence ownership 9.8 10.8 11.2 Real estate renting and other activities 3.7 4.1 4.3 Public administration, defense and mandatory social 3.9 3.9 3.8 security Education 2.8 2.9 2.9 Health and social services 1.6 1.6 1.6 Other social, public and individual services 1.7 1.7 1.7 Domestic employment 0.2 0.2 0.2 Indirect factoring and taxes 14.6 13.6 13.3 TOTAL 100 100 100 Among the manufacturing industry, food and beverage sector and textile sector have the highest share in Turkey. According to Turkish Prime Ministry State Planning Organization (SPO) food industry has a share of 18 – 20% in the overall manufacturing industry in terms of production value4. Whereas the textile industry occupies 10% of the GNP of Turkey that is 319 billions US $ 5. With regard to population, the quota of employees in the Turkish industry is overall about 3 % which is about 4.6 % in Đstanbul. Relating to the total number of employees in Turkey, the biggest number of employees can be ascertained in 4 T.R. Prime Ministry State Planning Organization (SPO). IXth Development Plan Food Industry Special Commission Report. Ankara: 2007 5 T.R. Prime Ministry State Planning Organization (SPO). IXth Development Plan Textile, Leather and Clothing Industry Special Commission Report. Ankara: 2007 5
  12. 12. Đstanbul - about 27 %, followed by Bursa (8.3 %), Đzmir (7.1 %), Kocaeli (5.1 %) and Ankara (5.0 %). All other districts are below 5 %. From Figure 1.6 to Figure 1.9, the distribution of employees according to provinces (NUTS3 level) is given. Moreover, in Table A. 3 and Figure A. 1 in Appendix exact numbers of employees in every province and according to major industrial braches can be found. The number of employees is a measure of industrial activity – and is therefore a rough measure of hazardous waste generation. Hence it is most likely to find the hazardous waste centers in the high-industrialized districts – especially in the Metal Industry and the Chemical Industry. Figure 1.6 Employees in Turkish Industry, total 6
  13. 13. Figure 1.7 Employees in Turkish Metal Industry Figure 1.8 Employees in Turkish Chemical Industry 7
  14. 14. Figure 1.9 Employees in Turkish Other Industries 8
  15. 15. 2 LEGISLATIVE FRAMEWORK AND STAKEHOLDERS OF HAZARDOUS WASTE MANAGEMENT 2.1 LEGISLATIVE FRAMEWORK International framework for hazardous wastes is shaped by Basel Convention on Control and Supervision of the Transboundary Shipment of Hazardous Waste that has been ratified by Turkey. National legislative framework regarding hazardous wastes is comprised of legislations regarding general rules for waste management and hazardous wastes and legislations regarding management of specific types of wastes. Legislations on specific types of wastes are in compliance with the fundamental rules laid down in legislations handling general management concepts. In Table 2.1, a list of legislations related to hazardous wastes and their counterparts in European Union (EU) Acquis is provided Table 2.1 List of Turkish legislation on hazardous wastes TURKISH LEGISLATION EU COUNTERPART Regulation on General Principles of Waste Directive 2006/12/EC on waste Management Regulation on Control of Hazardous Directive 91/689/EEC on hazardous waste Wastes Directive 75/439/EEC on the disposal of Regulation on Control of Waste Oils waste oils Regulation on Control of Waste Vegetable Oils Directive 2006/66/EC on batteries and Regulation on the Control of Used accumulators and waste batteries and Batteries and Accumulators accumulators Regulation on the Control of Packaging Directive 94/62/EC on packaging and and Packaging Waste packaging waste Regulation for Control of the Tyres Which Have Completed Their Life-Cycles (TCL) Regulation on the Restriction of the use of Directive 2002/95/EC on the restriction of the Certain Hazardous Substances in use of certain hazardous substances in Electrical and Electronic Equipment electrical and electronic equipment Regulation for Control of Medical Waste Regulation on Control of Polychlorinated Directive 96/59/EC on the disposal of Biphenyls and Polychlorinated polychlorinated biphenyls and Terphenyls polychlorinated terphenyls (PCB/PCT) Regulation on Control of End-Of-Life Directive 2000/53/EC on End-Of-Life Vehicles (Draft) Vehicles Regulation on Landfill of Waste (Draft) Directive 1999/31/EC on the landfill of waste Regulation on Incineration of Waste Directive 2000/76/EC on the incineration of (Draft) waste. 9
  16. 16. Among these regulations listed in Table 2.1, Regulation on General Principles of Waste Management and RCHW are the core regulations covering main aspects of waste management practices while the rest deals with specific types of waste. Last two regulations that are on landfilling and incineration lays down general measures for these two disposal activities. According to RCHW, main principles of waste management is as follows: o Except for the cases in which hazardous wastes present an economic value to the importer and import of the hazardous waste is allowed by the edicts of MoEF, import of all types of hazardous wastes are forbidden. o In accordance with waste hierarchy, waste prevention and waste minimization is the most desired option. Reuse, recovery or recycling (especially waste oils, organic solvents, accumulators) and whenever prior options are not applicable, treatment options follow prevention and minimization respectively. The least desired option is final disposal. Whenever feasible, energy recovery during disposal should be evaluated and applied. o Waste generators, transporters and disposers are held responsible for the dangers created by hazardous wastes and “polluter pays” principle is adopted. o Companies that store, sell and dispose hazardous wastes are obliged to have a license from MoEF and companies without proper licenses are prohibited to operate and mix hazardous wastes with other fuels. o Segregation of hazardous wastes is mentioned and mixing of hazardous wastes with non-hazardous wastes is forbidden in all cases. This rule also holds for the commingled wastes arriving at disposal facilities. o In case of interim storage, priority should be given to storage at the point of generation. Main components of the hazardous waste management system consists of generation, storage, collection, transportation, treatment (whenever possible) and disposal of hazardous wastes. Generation of hazardous wastes should involve the waste prevention and waste minimization activities aside from the hazardous waste generating processes. Storage involves temporary storage of hazardous wastes either in the location of generation or specially designed temporary storage facilities suitable for hazardous wastes. Storage should not be confused with landfilling of hazardous wastes. Collection by definition means to gather objects together which in the context of hazardous waste management refer to the 10
  17. 17. step where hazardous wastes are accumulated before being sent to temporary storage facilities, treatment or disposal sites. Transportation part of hazardous waste management system is the one where the wastes are conveyed to temporary storage, treatment or disposal facilities following collection of wastes. Treatment also involves the recycling processes. It is important to note that not all the hazardous wastes are suitable for treatment or recycle. Disposal is the ultimate fate of most of the hazardous wastes. Rules outlined by RCHW regarding the abovementioned components are as follows: Determination and classification of hazardous wastes Steps that should be followed by waste generator in order to determine whether a waste is hazardous or not is given in Figure 2.1. Step 1: Is the substance described as waste in RCHW? For a substance to be “waste” it should have waste properties given in RCHW Annex 1. If the substance does not have those properties it cannot be described as hazardous waste. Step 2: Are there any specific provisions in RCHW for the waste in question? Step 3: Does the waste listed in Annex 7? RCHW Annex 7 is adopted from Commission Decision as regards the list of wastes (2001/118/EC) and contains the marked entries as hazardous wastes. Complete list of waste is presented in Regulation on General Principles of Waste Management. Annex 7 contains 20 chapters that relate to the process that generated the waste or to specific waste types. If the waste is listed in Annex 7, Step 4a should be followed. If not Step 4b should be followed. Step 4a: How is the waste coded and classified in Annex 7? The chapters are given a two-digit number. Each Chapter contains sub-chapters that are identified by four-digits. Within each sub-chapter is a list of unique six digit codes for each waste. Annex 7 contains two types of wastes: Absolute entries: hazardous regardless of their composition or concentration of any dangerous substance within the waste. 11
  18. 18. Mirror entries: wastes that have the potential to be either hazardous or not, depending on whether they contain “dangerous substances” at or above certain thresholds. For the mirror entries Annex 3b should be considered and Step 4b should be followed. Figure 2.1 Steps to be followed to determine a hazardous waste according to RCHW 12
  19. 19. Step 4b: Is the waste produced as a result of processes listed in RCHW Annex 3? RCHW Annex 3 lists activities that can generate hazardous wastes. Annex 3 is comprised of two sections; Annexes 3a and 3b. If no specific entry could be found in Annex 7 regarding the waste or if the waste is a mirror entry, Annexes should be checked whether Annex 3a or Annex 3b applies based on the process from which the waste is generated. For the wastes that are in context of Annex 3a, Step 5 should be followed. If the waste generating process is not listed in Annex 3a, Annex 3b should be checked. This section lists the waste that can be hazardous only if certain components are present within the waste. Step 4c: Is the waste listed in Annex 3b contains the constituents listed in Annex 4? The constituents that can render a waste hazardous are listed in Annex 4 and if the waste listed in Annex 3b contains any of the constituents given in Annex 4; Step 5 should be applied. If the waste listed in Annex 3b does not contain any of the constituents of Annex 4, it cannot be classified as hazardous waste. Step 5: Does the waste have the properties listed in Annex 5? For the following classes of wastes to be hazardous, they must have at least one property given in Annex 5: o Wastes classified as mirror waste in Annex 7 o Wastes generated as a result of processes given in Annex 3a o Wastes listed in Annex 3b and contain at least one component of Annex 4. For these types of wastes there are two methods to determine whether they are hazardous or not: o Estimation of presence of hazardous properties by checking threshold concentrations associated with certain risk phrases o Testing for hazardous properties For mirror entries, as long as the composition of the waste is known, presence of “dangerous materials” can be confirmed. If none of the constituents of the waste are “dangerous” and if the waste itself does not show any hazardous properties from H1 to H14, this waste cannot be classified as hazardous. If a mirror waste possess a property from H1 to H14 due to its “dangerous” constituent concentrations exceeding the threshold concentrations specified for any hazardous property, this waste should be classified as hazardous and should be given code accordingly. 13
  20. 20. Step 6a: Does the waste possess hazardous properties of H1,2,9,12-14? When a waste posses hazardous properties of H1,2,9,12-14, this waste must be classified as hazardous For these properties no threshold concentrations are specified. Step 6b: Does the waste possess hazardous properties of H3-8, H10,11? For some hazardous properties listed in RCHW Annex 5, threshold concentrations are specified. If any of the constituents of the waste show hazardous properties of H3-8, H10, 11 Step 7 should be followed. Step 7: Does the constituents or waste itself above the threshold concentrations specified in Annex 6? The hazardous properties for which threshold concentrations are specified are H3-8, H10, 11. For this reason, concentrations of constituents that render a waste hazardous should be checked whether they are above these threshold concentrations. If a waste contains dangerous constituents below these threshold concentrations, this waste cannot be classified as hazardous and waste codes should be given accordingly. Waste Generation As mentioned before, priority should be given to prevention and minimization of wastes at the location of generation. Hazardous waste generators should prepare a waste management plan and have this plan approved by governorship. Moreover, if the wastes are going to be stored temporarily within the facility premises, a permit is required to be taken from governorship. The most important aspect of temporary storage is to achieve proper and safe conditions for storage. Waste generator is obliged to take records of the amounts and types of wastes generated within the facility and to report these records annually to MoEF through waste declaration forms. If the generated waste is a mirror entry according to the abovementioned procedures hazardous nature of wastes should be confirmed by generator. Another important responsibility of the waste generator is to ensure that hazardous wastes generated are transported by licensed companies and disposed 14
  21. 21. of in licensed facilities. Throughout these processes, waste generator shall provide labeling and packaging in a proper and safe manner. Waste generator is held responsible for submitting a detailed report (on types, amounts etc.) to governorship in case of an accidental or deliberate illegal spill and remediation of the contaminated site no later than one month based on the type of the waste. Moreover, all the expenses related to remediation must be paid by the waste generator. Transportation of the wastes Transportation companies are obliged to obtain a license from MoEF for transportation of the wastes to recycling, recovery and disposal facilities. Licensed waste transporters must use vehicles suitable for the types of wastes they are carrying. Another important aspect is that the wastes that are being carried in a vehicle must have the same waste codes. Waste transportation is followed up via various transportation forms. These forms are categorized as national and international transportation forms and the required ones need to be present in the vehicle during transportation. Interim storage Main objective of interim storage is to collect wastes so that the amount of wastes reaches sufficient capacity for transportation before they are sent to recovery or disposal facilities. Such interim storage facilities are again subject to a license obtained from MoEF. However, for all types of wastes temporary storage duration cannot exceed one year that means interim storage facilities cannot act as final disposal sites. In order to get a license, interim storage facilities need to show presence of contingency equipments and necessary systems to control hazardous wastes in case of an accident. Waste recovery In order to obtain economic income and to decrease the amount of waste destined for final disposal, recovery of wastes is promoted. Possible recovery processes are listed in RCHW (Annex 2b). The most important aspect of recovery is that an accredited laboratory must confirm that waste becomes a product as a result of recovery processes. In the same manner, when chemical, physical and biological treatment is applied on a waste; there is a necessity to confirm that waste is no longer hazardous according to Annex 11a. 15
  22. 22. Waste Disposal Liquid wastes suitable for pumping can be disposed of by injection into geologically and hydrogeologically suitable wells, salt rocks and natural cavities. Moreover, in abandoned mining sites wastes can be disposed of inside containers. For these two methods to be applied a feasibility report should be prepared and a permit should be obtained from MoEF. In Annex 2a of RCHW, some other possible final disposal methods are listed. When incineration is used as a disposal method, complete combustion should be achieved as much as possible. RCHW lists operation requirements for incinerators. Incineration plants should be designed, equipped and operated so that the flue gas composition does not violate the emission limits specified in RCHW. Combustion gases are discharged to atmosphere via the stack in a controlled manner. Stack height should be designed and applied according to Industrial Air Pollution Control Regulation. Incineration facilities perform trial burns before they acquire their permits from MoEF and take license according to the results of these trial burns. Second mostly used final disposal method after combustion is landfilling. Proven that there exist enough precautions or there are no negative impacts on environment due to the nature of the waste, hazardous wastes can be landfilled and permit can be taken from MoEF for establishment of landfills. Criteria for landfilling are presented in Annex 11a of RCHW. Aside from this Annex, the most important criterion for landfilling is that the water content of the waste to be landfilled should not exceed 65%. Site selection for landfills is also very important. According to RCHW, possible sites for establishment of landfills are listed. In RCHW, there are specifications about landfill liners, drainage systems, embankments and top cover that will be applied when the landfill site can no longer accept waste. Hazardous waste landfill must have an operational plan and submit it to MoEF. Transboundary movement of wastes Transboundary movement of wastes into the country is allowed if and only if the imported wastes have an economically significant value and this is subject to a permit taken from MoEF. Export of wastes is allowed if and only if there is no established facility that has sufficient technical waste disposal capacity in Turkey and the responsible authority of the importing country permits the 16
  23. 23. transboundary movement of waste into that country. Neither transit passages nor transshipments and transfer of wastes are allowed within the area of national jurisdiction without the consent of MoEF. 2.2 STAKEHOLDERS OF HAZARDOUS WASTE MANAGEMENT Parties involved in hazardous waste management system are MoEF, administrative chiefs (governors), local administrations (municipalities in smaller provinces and greater municipalities in bigger provinces), hazardous waste generators, and companies that are responsible for transportation, treatment, recovery and disposal of hazardous wastes. Among these parties, rules valid for companies responsible for transportation, treatment, recovery and disposal of hazardous wastes are given in RCHW. Duties, responsibilities and jurisdiction of MoEF, administrative chiefs, local administrations and waste generators are shown in Figure 2.2. In the hazardous waste management system, main duties of MoEF are policy setting, giving permits to disposal, transportation, recovery companies that have the obligation to have license and inspect them. Application of hazardous waste management system according to the plans and programs of MoEF on province-scale is achieved by administrative chiefs and local administrations. However, the biggest responsibilities on hazardous waste management systems lie upon hazardous waste generators. From classification to disposal of hazardous wastes in the context of “polluter pays” principle, the generator is held financially responsible. Proper transportation, recovery and disposal of the hazardous waste generated through licensed companies are also the responsibilities of waste generator. Waste declaration, that has great importance in inspection mechanisms of MoEF should be carried out by waste generator with accuracy. It can be seen that for the hazardous waste management system to function properly waste generators have great responsibility. 17
  24. 24. Figure 2.2 Main duties, responsibilities and jurisdiction in the hazardous waste management system 18
  25. 25. 3 DEVELOPMENT OF HAZARDOUS WASTE MANAGEMENT SYSTEM IN TURKEY MoEF has participated in and completed a number of projects towards development of hazardous waste management practices in Turkey. First one of these major projects is the In Hazardous Waste Management Project 6 carried out by TÇT-Zinerji Consortium in 2001. In this project, hazardous waste generation and disposal practices, institutional structure and legal framework are covered and possible sources of problems are investigated. Suggestions were made on legal framework related to management of hazardous wastes and harmonization with EU directives. In Hazardous Waste Management Project, the hazardous waste generation in Turkey was evaluated based on the total number of employees working in hazardous waste generating industries adopting a method from Germany. MoEF’s approach for locating new hazardous waste facilities is towards concerning with both cost and effectiveness of the system shaped as a result of the “Technical Assistance for Environmental Heavy-Cost Investment Planning” Project 7. According to “economy of scale” principle, building large scale and regional hazardous waste processing and disposal facilities reduce disposal costs (per ton). On the other hand, establishing fewer but large-scale plants increases transportation distances and hence transportation costs. However, transportation costs can be reduced by establishing interim storage network where hazardous wastes originating from small sized companies will be stored safely until reaching necessary amount for transportation by larger vehicles or railway. In this EU project carried out by an international consortium in coordination with MoEF, three scenarios were evaluated. First scenario includes establishment of a number of large scale incineration and disposal facilities along with collection network and transfer stations at the locations where industrial activity is high. According to this scenario transfer stations should be able to perform basic physical and chemical treatment processes in order to decrease the volume of 6 Management o Hazardous Wastes, Ministry of Environment and Forestry General Directorate of Waste Management, Department of Waste Management, 2001, Ankara 7 Technical Assistance for Environmental Heavy-Cost Investment Planning, Turkey Directive-Specific Investment Plan for Council Directive on Hazardous Waste (91/689/EEC), Ministry of Environment and Forestry, 2005, Ankara 19
  26. 26. waste. The regions for which the hazardous waste incineration and disposal facilities will serve are shown in Figure 3.1. Figure 3.1 Hazardous waste management regions Second scenario is similar to the first one however, in this one instead of low number of large scale facilities to serve for regions, high number of smaller scale facilities serving for smaller areas is considered. This scenario also includes the network and transfer station but again in smaller number and scale. Third scenario involves implementation of first or second scenario along with co- incineration practices in cement kilns. Among these three scenarios first one was chosen by technical working group involved in the project, which will be referred as regional hazardous waste management plan from now on. In the first phase, regional hazardous waste management systems will be realized in highly industrialized regions; o Thrace Region o Eastern Marmara Region o Aegean Region o Central Anatolia Region o Mediterranean Region Number and capacities of facilities planned to be constructed according to regional planning may increase as a result of rate of industrialization. In addition to that, it should be kept in mind that as the awareness of waste producers increase; technological developments will be installed for waste minimization purposes at the source. Construction, installation and operation of hazardous waste disposal facilities require special technology and training. Moreover, these 20
  27. 27. facilities need to be inspected by Ministry of Environment and Forest thoroughly. In this context, these facilities are obliged to use BAT (Best available Techniques) specified in Reference documents on BAT (BREFs). These facilities are expected to be constructed by private sector on “built-operate” basis. In the second phase, interim storage facilities including physical-chemical pretreatment units are planned to be installed at less industrialized regions. Also, transfer network to integrated facilities will be developed. There is already an incineration plant in Marmara Region, which is Đzaydaş having 35.000 t/yr of waste incineration capacity. A capacity increase of 70.000 t/yr was foreseen for Đzaydaş. Other newly established facilities is planned to be as given below: o Thrace Region: an incinerator (60.000 t/yr) and a landfill (90.000 t/yr) to be installed in 2013 – for the orange region shown in Figure 3.1. o Đzmir: an incinerator (40.000 + 30.000 t/yr) to be installed at 2015 and 2020 in two phase and a landfill (120.000 t/yr) to be installed in 2014 – for the blue region shown in Figure 3.1. o Adana/Mersin: an incinerator (45.000 + 40.000 t/yr) to be installed at 2016 and 2021 in two phase and a landfill (140.000 t/yr) to be installed in 2015 – for the purple region shown in Figure 3.1. “Technical Assistance for Environmental Heavy-Cost Investment Planning” Project was followed by two Twinning Projects namely Waste Management Twinning Project, (TR/2003/EN/01)8 and Special Waste Twinning Project (TR/2004/IB/EN/01) 9. In Waste Management Twinning Project, hazardous waste management concept was developed aiming to determine mid-term and long-term measures and ways to establish a sufficient hazardous waste management structure all over Turkey. Emphasis was given to waste minimization and recovery operations. Requirement for self-sufficiency of disposal and recovery operations in terms of capacity was underlined. Moreover, waste specific handling of hazardous wastes was covered under establishment of dedicated waste recovery and disposal facilities towards handling of specific wastes. In addition, branch-specific measures were listed management of wastes originating from selected sectors. 8 Waste Management Twinning Project, (TR/2003/EN/01 9 Special Waste Twinning Project (TR/2004/IB/EN/01) 21
  28. 28. Measures for waste avoidance recommended by Waste Management Twinning Project were listed as: o Cooperation between production plants and research institutions for development of new equipments o Construction of a network to spread the relevant technical information between good’s producers, chambers and associations, responsible environmental authorities as well as institutions o Promotion of public relations on hazardous waste management as well as education and training programs o Establishment of a special working unit (task force) subordinated the governmental level or subordinated the level of the environmental agencies which is responsible as an advisory board to give advices for suited measures to the private enterprises in terms of waste avoidance and waste recycling/recovery Highlights for waste recovery and recycling are: o Supporting establishment of waste recycling exchange to manage and broke with valuable goods and secondary raw material o Promotion of recycling-friendly designs o Promotion of high-level and emission-free recovery by o Immediate reuse of waste, devices and parts out of waste for the further production without any treatment o Recycling of the immanent raw materials and material use of hazardous components out of waste immediately or after treatment as secondary raw material for the same or for other production purposes o Recycling of the immanent raw material and material use (for the same or for other production purposes) of all non-hazardous waste parts after separation, elimination and disposal of hazardous components and compartments 22
  29. 29. o Recycling of the immanent raw materials of waste and material use for other purposes than production o Energy recovery of hazardous waste in production plants In order to realize abovementioned measures creation of a special tax /fee /levy for waste generation and tax privileges given to the enterprises for investments in waste minimized production processes are suggested. In the light of outcomes of these projects and following the rules laid down by legislative framework, current hazardous waste management system in Turkey is shaped. However, in terms of practical aspects, hazardous waste management system should be further studied and improved. Following this motivation LIFE HAWAMAN Project on Improvement of Industrial Hazardous Waste Management in Turkey (LIFE06/TCY/TR/000292) was started. The project’s objective is to improve the management of industrial hazardous waste in Turkey and to tackle the increase in hazardous waste generation and environmental risks that such waste may cause. In order to reach this goal, the following items were worked out: 1. Estimation of the amount of industrial hazardous waste in Turkey 2. Allocation of hazardous waste to disposal routes according to the state of the art 3. Recommendations concerning a hazardous waste management concept for Turkey . 23
  30. 30. 4 CURRENT SITUATION OF HAZARDOUS WASTE MANAGEMENT IN TURKEY Rising environmental awareness, legislative obligations, increasing costs because of capacity constraints of waste disposal operations and increasing importance of environmental protection measures especially in foreign trade lead to an increase in implementation of pollution prevention technologies and waste minimization activities. In implementation of recycle/recovery and reuse activities the priority is given to the wastes easy to collect, manage and require simpler technologies. Wastes of packing materials such as IBC, barrels and other packing wastes is a good example for easy to handle type of wastes as those wastes pose lower risk for the environment. Another example can be recovery of silver, which is simple in terms of technology to be used. Furthermore, waste exchange system implemented within the scope of chamber of industries by Turkish Union of Chambers and Commodity Exchanges supported by Ministry of Environment and Forestry (MoEF). Waste exchange is an intermediary system aiming recovery and reuse of production wastes from the industries to be used as a secondary raw material in other industries. With the implementation of waste exchange, amount of wastes to be ultimately disposed of is reduced. However, effective implementation and operation of this system is predicted to take some time. According to the data of November 2007, number of recycle plants with ad-hoc working permit and license reached up to 89. Currently, 52 of those plants are operating with the license. The classification of those plants according to recycling methods indicated in Annex 2 of Turkish RCHW can be seen in Table 4.1. As can be seen, metals are recycled as priority in 33% of recycling plants. Metals are of priority as installed capacity for recycling of metals consists half of the overall recycling capacity in Turkey. Waste oils follow metals in terms of number of plants (21%) and installed capacity (35%). The distribution and amount of recovered materials can be seen in Table 4.2. 24
  31. 31. Table 4.1 Number of plants and recycle/recovery activities (June 2007) CODE OF NUMBER OF PLANTS TOTAL CAPACITY RECYCLE/RECOVERY WITH LICENSE (TON/YEAR) R2 (Recovery of solvents) 3 9,350 R3 (Reclaim of organics other than 7 17,477 solvents) R4 (Reclaim of metals and metal 17 113,442 compounds) R5(Reclaim of inorganic materials) 4 1,955 R9 (Refinement of waste oils) 11 82,452 R11 (Use of wastes from R1-R10 3 14,570 operations) R12 (Change of one of R1-R11 7 24,415 operations) TOTAL 52 263,661 Table 4.2 Types of recyclable wastes admitted to licensed recycling facilities and their capacities ANNUAL CONSUMPTION SHARE IN OVERALL WASTE TYPE CAPACITY (TONE/YEAR) CAPACITY (%) Dye sludge 4,503 1.01 Oily waste (wastes 86,618 19.48 including heavy metals) Chemical wastes 21,106 4.75 Contaminated cloth and 7,978 1.80 cotton waste Waste solvent 1,990 0.44 Waste barrel 656,400 -- Battery accumulator 192,439 43.30 Industrial sludge 7,360 1.65 Waste tyres 51,979 11.70 Waste oil (1st Category) 33,762 7.60 Waste oil (2nd Category) 36,735 8.27 TOTAL 445,000 (+656,400 barrels) 100 Recently, a pilot scale hazardous waste recovery plant with gasification has come into operation in Istanbul Kemerburgaz with 29,000 tons/year capacity. The facility was established by Ecological Energy Limited Company (Ekolojik Enerji Ltd. Şti.). Energy recovery indicated in Annex 2 of RCHW is another method for waste recovery. This type of recovery can be implemented in cement industry. Wastes from cement industry are utilized as alternative fuels for energy recovery 25
  32. 32. in factories. Waste tyres, 1st and 2nd type of waste oils, dye sludge, solvents and plastic wastes can be disposed in cement factories. Additionally, two cement factories got permission for utilization of grit and domestic sludge as alternative raw material. Currently, 22 cement plants have license in R1 category. In Table 4.3, amount of waste types used as fuel in licensed cement factories are given. Table 4.3 Wastes used as alternative fuels in cement factories WASTE TYPES AMOUNT LICENSED (TONE/YEAR) 1st and 2nd type Waste oils 214,226 Waste tyres 106,458 Contaminated waste 61,884 Waste plastic 51,866 Petroleum refinery waste 24,120 Petroleum bottom mud 18,902 Dye sludge 16,964 Liquid fuel sludge 4,020 Total 498,440 Currently, there are three landfills and three incinerators licensed by MoEF for disposal of industrial wastes in Turkey. TÜPRAŞ has established a rotary kiln for their own wastes while Erdemir and Đsken have build disposal facilities for their own wastes. Information related to current waste disposal facilities is provided in Table 4.4. Capacities given in Table 4.4 are the installed capacities and almost 80% of the total capacity is utilized currently. Following the regional waste management plan developed in “Technical Assistance for Environmental Heavy-Cost Investment Planning” Project, establishment of certain hazardous waste facilities are underway. List of these facilities along with their location and capacities are given in Table 4.5. 26
  33. 33. Table 4.4 Waste incineration capacity of PETKĐM is 17.500 tones/year. Less than half of the capacity (7500 tones/year) is utilized by PETKĐM, while the rest is for other industries. Following the regional waste management plan developed in “Technical Assistance for Environmental Heavy-Cost Investment Planning” Project, establishment of certain hazardous waste facilities are underway. List of these facilities along with their location and capacities are given in Table 4.5. Table 4.4 Current capacities of disposal facilities COMPANY NAME CAPACITY ∗ ĐZAYDAS(storage) 790.000 m3 (occupancy ratio %20) ĐZAYDAS (incineration) 35.000 tons/year PETKĐM (incineration) 17.500 tons/year TÜPRAŞ (incineration) (for the facilities own wastes) 7.750 tons/year ERDEMĐR (storage) (for the facilities own wastes) 6.084 tons/year ISKEN (storage)∗ (for the facilities own wastes) 115.000 m3 Table 4.5 Integrated Waste Disposal Facilities PRESENT NAME OF THE PROJECT AND LOCATION CAPACITY SITUATION Kiplasma Sanayi ve Ticaret A.Ş. – Integrated Industrial Waste Disposal Facility Incineration: EIA Phase 48.000 tons/yr Gebze Organized Industry Zone Kocaeli Aegean Region Industrial Waste Disposal Landfilling: Landfill brought in line Complex 3.230.000 m3 on March 2009. Incineration: ∗ Total capacity 27
  34. 34. Kırtıllı Tepe Mevkii Sandal Beldesi 20.000 tons/yr Incinerator in Kula - Manisa planning stage. ITC Invest Trading & Consulting AG – Gasification: Feasibility Integrated Waste Disposal Facility 20-30 thousand ton/yr study Çadırtepe Mevkii (100 thousand ton/yr completed Sincan - Ankara with expansion) Türkiye Metal Sanayiciler Sendikası Planning Bursa phase 28
  35. 35. 5 HAZARDOUS WASTE MANAGEMENT CONCEPT 5.1 HAZARDOUS WASTE QUANTITY ESTIMATION The Twinning project "TR03/EN/IB-01 Waste" activities on hazardous waste regarded the lack of reliable data as one obstacle to base any kind of concept on. Due to this the estimation of quantities and types of waste for certain industrial activities was a basic task of the HAWAMAN-Project to base the hazardous waste management concept on. This section gives the outline of hazardous waste generation estimation methodology and its basic findings. The realistic estimation of kind, amount and geographic origin of the currently produced hazardous waste is the most important basis for the introduction of a waste management system that includes the implementation of waste transportation, interim storage and treatment facilities and the optimal organization of waste transportation – where appropriate via interim storage facilities - to treatment facilities. A too imprecise evaluation of the amount of waste could either lead to expensive bad investments in oversized waste treatment plants or to insufficient capacities for a proper and environmental sound waste treatment. The following work steps for the estimation of quantities and types of waste were planned: o Definition of industry sectors generating hazardous waste o Compilation of basic data for estimation of hazardous waste amounts o Population per province o GNP per province o Industry structure with list of enterprises with employees, sector and province o Number of motor vehicles etc. o Estimation of amount of hazardous industrial waste for selected industry sectors based on international experiences and the above mentioned basic data from Turkey o Report on the methodology, used experiences/data, results and compilation/development of maps The estimation is using a heuristic method based on long year international experiences. It does not include any prognosis for future hazardous waste 29
  36. 36. quantities and qualities, which will change due economic development or structural changes in industry etc. Moreover, it does not cover all waste streams. The hazardous waste generation estimation outlined in this section with its data amount per type of waste per province gives the basis for the following project tasks on waste logistics and waste management treatment concept. 5.1.1 Methodology There are several methods in order to estimate the types, amounts and regional distribution of the hazardous waste in a country in which exists no working hazardous waste management system so far. Data from waste generators a) Direct information from waste generators: This approach will lead to no reliable data with very high aberration from real situation, because waste types and waste amounts often are unknown, especially in countries with no hazardous waste management system; participation << 100 %; this method is labor and time intensive. Even in countries with long-time existing hazardous waste management system the data given by the companies are not very reliable; they just can give a qualitative, but not quantitative statement, if the waste amounts will in- or decrease. b) Material balances from companies: Input/output balances from companies or processes are not existing normally, this method is not practicable and very labor and time intensive. c) Internal notification / waste declaration forms: Because waste types and waste amounts often are unknown in the companies at present, the waste types and amounts given in the Internal Notification often are wrong resp. consciously bigger or smaller than in reality. Even with a long-time existing hazardous waste management system Internal Notification will not give reliable data. Data from waste transportation Because a hazardous waste management system is not covering the whole country the current situation needs to be improved, only partial data about waste transportation exist. An extrapolation of this data is not possible, because only a part of the waste types are transported to treatment facilities, for the other part no treatment facilities exist. 30
  37. 37. But even with a long time existing hazardous waste management system the Waste Transportation Forms will not give 100% reliable data: There is always a gap between the waste mounts from waste generators to waste transportation service and from waste transportation service to waste facilities. Possible reasons for the situation are thought as mistakes in m³ to ton conversion, partly filled transportation units and loss of some part of water evaporation of water. Data based on material and product amounts Material input and product output data and the associated waste ratios are not available for all industrial sectors, so only a part of the waste amounts can be estimated by this approach. Even if these data were known; the following points will remain as possible problems: o the material efficiency = waste ratios can differ by magnitudes o statistical problems can falsify the data: o production of product in one or more companies (Figure 5.1)? o waste per produced item, e.g. vehicle: truck or compact car? o complete production at facility or import of parts? Production in 1 facility Production in 3 facilities input output input output input output input output 1 Material/Product 3 1 Employees/Sales 3*1/3=1 Figure 5.1 Production in 1 or 3 facilities: material balance differs by factor three Data based on inhabitants/employees and GNP/sales per region 31
  38. 38. This method gives a rough estimation about hazardous waste generation in a country or in a region. Large amount of such data is available from many different countries with long-time existing hazardous waste management systems. This is a very cheap and simple method. Problem of this approach is that some of the industrial sectors are waste intensive, others not. Without considering the employees per sector, the aberration from the real data may be high. For instance, the main industry in Turkey are the textile and food industry (with only small amounts of hazardous waste) plus metal industry; in Germany are the metal and chemical sector, which are very waste relevant, are the two main industrial sectors. Data based on employees/sales per sector and region Data based on employees/sales per industrial sector and per region gives a good estimation about waste situation per region, not very labor and time intensive, but the waste ratios are not available in studies/literature up to now and have to be developed with experience from a lot of waste management projects in a lot of countries knowing the situation in the waste generating industries. The development of waste amounts in regions without a long time existing hazardous waste management system depends on: o the presence of waste facilities o the possibility of waste recycling o the costs for waste treatment (disposal and recycling) o the authorities (surveillance, penalties) o the laws and regulations, judgement o the limits for gas emissions (filter dust and sludges from flue gas cleaning) and sewage (waste water sludges) and their implementation o achievements in waste minimisation / material efficiency o development of industry However, the „Delinking“ between GNP/employees and waste amounts should be considered in a way that a higher production will not lead to similar higher waste amounts. Therefore, every hazardous waste management system has to be built up in a manner, that it can react flexible on changes in waste types and amounts. 32
  39. 39. While comparing waste factors from other countries following items should be kept in mind: o big waste ratios are mainly caused by mineral wastes (e.g. Luxemburg > 50% contaminated soils!) o hazardous waste, which is recycled, sometimes is included and sometimes excluded o sometimes hazardous waste, which is treated by the waste generator, is in/excluded o some regional waste balances are worked out by consultants, who are interested in big waste amounts, so there is more work for planning more and bigger treatment facilities o waste factors for countries with no (long time) existing hazardous waste management system are often copied one by one without being proofed and are based on inhabitants/employee and GNP/sales. As a conclusion; waste balances based on o regional data (employees/GNP per province) and o employees or sales per industrial sector will give as a kind of best available technique not exceeding cost (BATNEC)- method the best estimation for a hazardous waste investment planning. It is based on long time and multi-region experience. Following the discussion presented above; for the HAWAMAN-Project a method should be used that gives a waste quantities estimation with low effort that is sufficiently accurate to plan kinds, capacities and locations of waste treatment facilities. Heuristic method used for HAWAMAN Project is based upon waste ratios per employee and sector. For this purpose the industrial sectors were merged to 21 sector groups whose companies have a similar spectrum of waste types. For each of those 21 sector groups a waste sector sheet was created that contains the typical waste types of this sector group and their waste ratios per employee. The waste ratios used in the waste sector sheets have not yet been published. They mainly base on data from countries with long-time existing hazardous waste management systems. The result of calculations gives an estimation of the waste situation in Turkey how it would be if there were already waste surveillance institutions and waste treatment facilities existing for several years. 33
  40. 40. This result with the distribution of the amounts of the different types of hazardous waste is exactly the result that is required in order to plan kinds, capacities and locations of the needed waste treatment facilities. This approach covers some of the factors of influence on the waste amounts listed previously. It is obvious, that in the years of the launch phase of a hazardous waste management system significant fluctuations and variations from the estimated values will occur. Waste ratios were developed based upon our long-year experiences in various institutions and countries and also from consideration of studies and balances like o numerous waste inventories of EU-countries and regions o data from world-bank and other institutions o BREF-documents (Sevilla process) Due to this information and experience it is possible to create waste sector sheets and to calculate the amount of waste per industrial sector and per province with the waste sector sheets and the basic data (employees per sector and province). By summating these results the waste amounts for Turkey can be calculated. This heuristic method has already been utilized successfully in other countries and verified with data from regions with long-time existing hazardous waste management systems. The accuracy of the approach is estimated as the final result to plus/minus 25%. This is sufficiently exact in order to base a hazardous waste management system on. It is believed that this uncertainty will be incorporated into design of hazardous waste management system since the system itself should be flexible in order to cover deviations due to unpredictable developments. It should be noted that on analysing and discussing the data it has to be considered that this method is a statistic approach that is only able to achieve realistic results for a great number of companies. The smaller the number of the regarded companies is, the greater the differences from reality can be. This applies for example to the consideration on the level of provinces with few employees or even single or few companies per group. The waste situation in single companies can deviate significantly from the used statistic waste ratios. Thus it can be reasonable to analyse the waste situation of individual exceptionally waste relevant companies respectively of companies 34
  41. 41. with very big amounts of hazardous waste and to integrate these values in results obtained from current approach. It's essential to make sure that these additional data are real data, that means data from wastes, which are occurring and are treated in reality, and not estimated data. 5.1.2 Waste estimation According to the assignment only certain sources and types of waste were to be considered at our waste quantity estimation. The focus is on the hazardous waste produced in the industry. List of considered and disregarded waste producers and waste types are given in Table 5.1. Disregarded waste producers are the ones either covered by special directives or the ones that produce “mirror” type hazardous wastes. Table 5.1 Covered and omitted waste types and producers COVERED OMITTED (TOBB-Codes 3000 to 4101) Food, beverage and tobacco Mining Textile and leather Construction Wood products and furniture Contaminated soils / sites Paper production and paper products End-of-live-vehicles Printing Service sector like hotels, commerce and Chemistry, chemical products offices (partly included in sep. collected Petroleum refineries fractions) Rubber and plastic products Logistics/Transportation (but car repair Mineral products (e.g. cement, glass) service as a.m.) Metal production Health care Metal working PCBs and PCTs Electrical machines and equipment Waste electrical and electronic equipment Electricity Public services (e.g. sewage sludge or and in addition: wastes from waste management o Separately collected fractions facilities, but power-plants) o Car repair service o Agriculture That means the wastes and waste groups o EWC 01 Mining o EWC 17 Construction / Demolition o EWC 18 Health Care o EWC 19 Waste + Waste Water Treatment o EWC 160104 End-of-live-vehicles 35
  42. 42. o EWC 200123/135 Electrical Equipment are excluded in our waste quantity estimation. In order to estimate the waste quantities per province on the basis of statistic ratios certain basic data from a as current as possible year are needed: o For the waste quantity estimation from the considered TOBB industrial sectors the number of employees per industrial sector per province is required as basic data. o For the waste quantity estimation of the separately collected fractions the capita per province are required as basic data. o For the waste quantity estimation of the car repair services the quantity of vehicles per province is required as basic data. o For the waste quantity estimation of the agricultural sector the agricultural employees per province are required as basic data. o For a comparison with general waste ratios on basis of the GNP information about the GNP of Turkey is required. Basic data for employee number was received from TOBB industrial sectors from TOBB via the Turkish MoEF. The data have been surveyed in 2007 and thus are very up-to-date. The TOBB database contains information of about approximately 66,000 companies, 38,000 of which have 10 or more employees. 35,800 of those companies are among the industrial sectors covered in this study and contain altogether 2.17 million employees. The other basic data like capita, vehicles, agricultural employees and GNP are taken from current publications of TurkStat 10. They were surveyed in years 2004 and 2005. As the basic data was obtained following procedure was followed: Step one: Deletion of all data sets with companies that come from other TOBB- sectors than No. 3000-4101. Step two: Deletion of all data sets with companies with less than 10 employees. Step three: Approximately 13,000 companies had assignments to more than one TOBB-code. Their employees were prorated on the different sectors. Step four: Addition of the numbers of employees per province of those TOBB- codes that are assigned to a waste sector sheet for every waste sector sheet. 10 Turkish Statistical Institute (TurkStat), statistics available from www.turkstat.gov.tr . 36
  43. 43. Step five: Creation of Table A. 3 given in Appendix. The basic data for capita, vehicles, agricultural employees and GNP per province were available at TurkStat in the required form. They were summarized in Table A. 4 in Appendix. Waste sector sheets As mentioned before 21 industrial sector groups, whose allocated companies each have a similar waste situation and differ relevantly from other groups, were selected (Table 5.2). For these sectors waste sector sheets were generated. The sector 39 “not otherwise specified products” is split to plastics, metalworking and wood. These 21 sector groups were supplemented by the following three non-industrial groups: o Agriculture o Separately collected fractions o Car repair services For each of these sector groups, a list of hazardous waste that can occur in this sector group has been created according to European Waste Catalogue (EWC). Because it's not always possible to give the waste ratios in every sector for each single waste type, some waste types were partly united to groups with similar waste composition: acids, waste oil, halogenated solvents, non-halogenated solvents etc. The waste sector sheets contain from a few to over 30 different waste types and waste type groups depending on the waste situation of this sector group. The waste sector sheets cover 200 hazardous waste types of the EWC. The other missing about 200 hazardous waste types originate from the disregarded sectors like mining, construction/demolition, health care and waste water/waste treatment or are related to waste types that only occur in a few companies or just in small amounts. For each of these waste types and for each sector group specific waste amounts in tons per 1.000 employees and year are given. Depending on the stage of development of the industry and the foci within a sector group the ratios of the situation in the country were adjusted specifically. Thereto data for the Turkish 37
  44. 44. economy as given in Introduction section of this report were considered. In Table 5.3, a sample waste sector sheet is presented for metal working industry. Table 5.2 List of industrial sector groups WASTE SECTOR SHEET TOBB-CODES Batteries production 383902 Cement 3692 Inorganic chemistry 351112-351131 Fertilizer manufacture 3512 Organic chemistry. 351101-11, 351140-50, 3513 Other chemical industries 351155, 3522-3529 Paint Industry 3521 Electrical equipment + machines 383 except 383902 Energy (power plants) 4101 Food-beverage-tobacco 31 Leather 322-324 Metal production (Iron and steel) 371 Metal production (Others) 372 Metal working 381, 382, 384,385 Mineral production (e.g. cement, 36 except 3692 glass) Paper production and products 341 Petrol refineries 354 Plastics and rubber 355, 356 Printing 342 Textile 321 Wood and furniture 33 Table 5.3 Sample waste sector sheet for metal working industry SHAPING AND PHYSICAL AND MECHANICAL SECTOR: "METWORK" SURFACE TREATMENT OF METALS t per EWC Waste type 1.000 empl. ... waste paint and paint sludges containing organic 080111and13 10 solvents or other dangerous substances ... 110105to07 pickling acids and basis and other acids 30 110108 phosphatising sludges 10 ... 120107and10 machining oils free of halogens 40 120109 machining emulsions and solutions free of halogens 150 ... 38
  45. 45. fluorescent tubes and other mercury-containing 200121 0,2 waste ... A single waste sector sheet only gives the statistically averaged data for this sector. The waste situation in single companies can differ significantly. Thus a waste sector sheet is not at all suitable to compare the included data with the waste types and amounts of single companies. For example in metal working some companies conduct galvanization while others don't (no 1101xx-wastes), some apply lacquering whereas some don't (no 0801-wastes). Results By entering the number of employees per sector and province into a waste sector sheet one receives the amount of waste that is produced in a sector and a province. By adding all waste sector sheets together the amount of waste in a province is received, and by adding these values from all provinces together amount of waste for Turkey is received. Because some of the 100 wastes and waste groups that are included in the waste sector sheets partly overlap, 28 waste groups were formed for displaying the result. Total hazardous waste generation under covered industrial and non-industrial sources turned out to be 1.35 million tons/yr. This amount of hazardous waste comes from the Turkish Industry – but it is only a part of the total hazardous waste amount in Turkey. Hazardous waste generation from industrial sectors Distribution of hazardous waste generation in general economic sectors are o Metal industry: 548,800 tons/yr o Chemical industry: 396,900 tons/yr o Other industrial sectors: 151,300 tons/yr o Non-industrial groups: 253,400 tons/yr These figures indicate that wastes from the industrial sectors add up to 1,1 million tons. In Appendix, from Table A. 5 to Table A. 8 more detailed information on distribution hazardous wastes among main sectors, industrial branches and provinces can be found. Hazardous waste generation according to waste types 39
  46. 46. As mentioned before, 28 waste groups were identified for reporting purposes. Table 5.4 lists the amount of hazardous waste generation according to these waste groups. In Appendix, Table A. 9 gives information distribution of waste types to provinces in more detail. 40
  47. 47. Table 5.4 Description and amount of hazardous waste groups in tons/yr ID SUBSUMES EWC GROUPS AMOUNT NUMBER CODES 1 Pesticides and agrochemical waste 020108, 200119 5,926 030201, 030202, 030303, 2 Wood preservatives 1,780 030204 040103, 040214, 040216, 3 Hazardous waste from tanneries 31,739 040219 050102, 050103, 050104, 4 Hazardous waste from petroleum refining 050105, 050106, 050107, 65,631 050108, 050109, 050115 060101, 060102, 060103, 060104, 060105, 060106, 5 Acidic and alkaline hazardous wastes 62,477 060201, 060203, 060204, 060205, 200114, 200115 060404, 060405, 060502, 6 Hazardous waste from inorganic processes 48,646 061002 070101, 070103, 070104, 070107, 070108, 070109, 070110, 070111, 070201, 070203, 070204, 070207, 070208, 070209, 070210, 070211, 070301, 070303, 070304, 070307, 070308, 070309, 070310, 070311, 070401, 070403, 070404, 070407, 070408, 070409, 7 Hazardous waste from organic processes 212,870 070410, 070411, 070501, 070503, 070504, 070507, 070508, 070509, 070510, 070511, 070601, 070603, 070604, 070607, 070608, 070609, 070610, 070611, 070701, 070703, 070704, 070707, 070708, 070709, 070710, 070711, 160506, 200129, 200131 080111, 080113, 080115, 080117, 080119, 080121, Hazardous waste from paint and sealant 8 080312, 080314, 080409, 54,719 production 080411, 080413, 080415, 200127 090101, 090102, 090103, 9 Hazardous waste from printing processes 090104, 090105, 090106, 4,908 200117 100104, 100109, 100114, 10 Hazardous waste from energy production 100116, 100118, 100120, 32,531 100122 41
  48. 48. Table 5.4 Continued ID SUBSUMES EWC GROUPS AMOUNT NUMBER CODES 100207, 100211, 100213, 100304, 100308, 100309, 100319, 100321, 100323, 100325, 100329, 100401, 100402, 100403, 100404, 100405, 100406, 100407, 11 Hazardous waste from metal production 114,586 100503, 100505, 100506, 100603, 100606, 100607, 100808, 100815, 100817, 100905, 100907, 100909, 100911, 101005, 101007, 101009, 101011 101109, 101111, 101113, Hazardous waste from mineral and glass 101115, 101117, 101119, 12 18,983 production 101209, 101211, 101309, 101312 110105, 110106, 110107, Hazardous waste from galvanizing 110108, 110109, 110115, 13 44,763 processes 110116, 110198, 110202, 110205, 110301 120107, 120109, 120110, 14 Non-halogenated waste oils 130205, 130206, 130307, 208,344 130208 15 Halogenated waste oils 120106, 120108, 130204 2,466 120109, 130502, 130503, 16 Waste oil emulsions 80,075 130802 120112, 120114, 120301, 17 Other oily waste 53,266 120302, 130501, 200126 18 Halogenated solvents 140601, 140602, 140604 12,228 19 Non-halogenated solvents 140601, 140605 36,059 20 Contaminated packaging’s 150110 48,235 21 Spent adsorbents and filtering material 150202 32,859 22 Spent oil filters 160107 2,507 23 Spent brake fluids and antifreeze 160113, 160114 3,971 24 Spent batteries 160601, 160606, 210133 47,613 25 Spent catalysts 160802 180 26 Sludges from CPT of wastes 190813 99,433 27 Mercury contaminated waste 200121 2,398 28 Contaminated wood 200137 21,176 42
  49. 49. Geographic distribution of hazardous wastes Table 5.5 below, summarizes the geographic distribution hazardous wastes in terms of regions. According to this table, Đstanbul itself generates highest amount of hazardous wastes. Figure 5.2 gives a survey of the overall hazardous waste situation in Turkey. It shows the waste generation centres and the waste amount, aggregated on the 81 provinces of Turkey. The map shows three main gravity centres of hazardous waste generation – all located in the western part of Turkey: o Đstanbul o Kocaeli o Izmir, followed by Bursa and Ankara. Table 5.5 Geographic distribution of hazardous wastes (1000 tons/yr) NUTS1-REGION AMOUNT TR1 314.2 TR2 83.6 TR3 207.2 TR4 303.6 TR5 125.4 TR6 123.0 TR7 54.2 TR8 73.5 TR9 13.9 TRA 6.7 TRB 11.6 TRC 33.5 Total 1,350 As expected, Figure 5.2 shows a distinct west-east divide of hazardous waste generation in Turkey, with white spots in the eastern regions. Since the waste generation factors used are based on employee numbers, these findings correspond with the employee map (Figure 1.6), which looks similar to the hazardous waste map (Figure 5.2). 43

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