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Frequently Asked Questions - DoW:CoP CLUSTER Questions

FAQs - DoW:CoP CLUSTER Questions

Can a Cluster involve 2 sites only?
Yes - That is the simplest Cluster model.
Does the Hub site need to be covered by an Environmental Permit?
Yes.
Given the Hub site has an Environmental Permit can the site be used at the same time to treat hazardous waste to non-hazardous waste?

Yes – provided the Environmental Permit allows for that particular treatment and that the wastes are adequately separated from treated materials associated with the Cluster project.

Any particular activity must not extend beyond what was reasonable for the Cluster project, remembering that Cluster is a temporary activity.

Is the Sheffield pilot Cluster project written up in any form?
No, but the work on it has fed into the DoWCoP and the Cluster Guide.
Does material need to be treated at the Hub site or could it just go in and then out to a site where it is suitable for use?
Yes it could pass through the Hub site without treatment if all in line with the DoWCoP i.e. suitable for use is just one factor that has to be satisfied. The rationale for this is that the Hub site operator becomes the holder of the waste as it is accepted at the Hub site. As the holder of waste the Hub site operator can not allow it to leave the site as non-waste unless he/she is satisfied that the DoWCoP has been followed in relation to the receiving development site.
What happens if out of specification material is received at a Receiver site?

It should be returned to the Hub site (see DoWCoP paragraph A3.13).

It would be prudent to use a registered waste carrier in transporting non-wastes from the Hub site to aid in this scenario i.e. it is easier to raise Duty of Care transfer notes than enter in to a new contract with a registered waste carrier to return the load. (There is no need to use transfer notes for material considered to be non-waste – it is recommended that you do not use transfer notes as Delivery tickets).

Can material with different contaminant concentrations be blended?
Yes to facilitate treatment, but not for disposal. Blending should only be for operational reasons, not to achieve dilution.
Is material waste while in stockpile on the Hub site?
Yes – before and after treatment. It can cease to be waste upon other DoWCoP criteria also being satisfied (see Watch Point 16).
If a Cluster was established and operating, when an opportunist site appeared, should the introduction of the new site be discussed with the Environment Agency?

Yes. The Cluster concept recognises that opportunist sites may appear once the Hub site is established and provides a lower cost opportunity for developing land, this may include Donor and / or Receiver sites.

The defined Cluster project would then have to be re-defined to include the opportunist site (or sites). See Watch Point 17.

The exercise within the CL:AIRE one day training resulted in a surplus of material located at the Hub site. Would the Environment Agency agree to such a proposed Cluster project?

Yes – provided the contingency arrangements and contracts identify who is responsible for it, what will happen to it and that sufficient funds are in place to deal with it satisfactorily.

The mass balance across the sites needs to aim for this surplus amount to be as small as possible in the first instance (see paragraph A3.10).

The Cluster concept recognises that new sites may be subsequently added to a project and this can include an additional Receiver site that has a need for it.

How would the DoWCoP be applied to a phased project where material from one phase may not be returned until a subsequent phase?
This would hinge on the certainty of use and the time scale involved, but does fit within the scope of the DoWCoP. The Materials Management Plan should clearly identify the phased approach.
How do the economics get arranged, i.e. price for treatment at Hub and “value” of material delivered to Receiver?
It is determined on the basis of the local market and contractual arrangements (including risk and profit sharing).
Can I transfer materials which are above hazardous waste thresholds?

No. See Watch Point 15. The process should:

  1. Set your specification for suitability based upon a site specific risk assessment for the receiver site.
  2. Check whether or not the levels of any contaminants in that spec are above hazardous waste thresholds.
  3. If they are then modify the specification to reduce the acceptable level for those contaminants to below the hazardous waste threshold.

CL:AIRE will not be responsible for any loss, however arising, from the use of, or reliance on, the information contained in the responses above, nor do they assume responsibility or liability for errors or omissions in the information provided. Readers are advised to use the information contained herein purely as a guide and to take appropriate professional advice where necessary.