1.
TASK A3
HAZARDOUS WASTE MANAGEMENT
CONCEPT FOR TURKEY
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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. Figure 1.7 Employees in Turkish Metal Industry
Figure 1.8 Employees in Turkish Chemical Industry
7
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. 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. 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. 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. 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. 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. 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. 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. 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. Figure 2.2 Main duties, responsibilities and jurisdiction in the hazardous waste management
system
18
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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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
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
