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Frequently asked questions - Transfers of NPI substances in waste

Get answers to the most commonly asked questions about transfers in the NPI.

1. How are emissions to the environment (land) different from transfers?

For NPI reporting purposes, emissions to land are defined as the release of an NPI substance - whether in pure form or contained in other matter and/or in solid, liquid or gaseous form. Emissions to land include substance emissions onto a facility's site, such as solid wastes, slurries and sediments, as well as accidental spills and leaks.

Transfers are the transport or movement, on-site or off-site, of NPI substances in waste to a mandatory reporting transfer destination - such as tailings dams or landfill - or a voluntary reporting transfer destination (e.g. for reuse, recycling or reprocessing).

2. Why report transfers?

Substances within waste that are transferred can pose an environmental risk. For example, substances transferred to landfill or tailings, although initially contained, have the potential to enter the environment through leaching or other means.

3. How many new facilities will be captured now transfers are to be reported?

If a threshold is tripped for Category 1, Category 1b or Category 3 substances, then the facility must report emissions and transfers of that substance. Therefore, it is unlikely that many facilities that are not currently reporting to the NPI will be drawn into the program due to the inclusion of transfers.

4. What are the costs associated with reporting transfers?

The costs of reporting transfers to the NPI are highlighted in the study Cost analysis of reporting National Pollutant Inventory transfers: Case studies using the amended NPI NEPM variation. Estimated average costs across the eleven facilities studied in the report are $2,000 in the first year and $740 ongoing/each year per facility.

The costs for industry lie mainly in the determination of the mass of NPI substances contained in the waste streams being transferred.

Further details on this study can be found in the report Cost analysis of reporting NPI transfers .

5. What examples would constitute a transfer (mandatory reporting)?

The mandatory reporting of NPI substances in transfers includes the following destinations:

• landfill
• tailings storage facility
• underground injection, or
• other long term purpose-built waste storage structure,

or to:

• a destination for destruction
• a sewerage system, or
• an off-site treatment facility which leads solely to one or more of the above

Examples of mandatory transfers would include:

• wastewater pumped to another outside facility for treatment
• waste, unsuitable for composting or reuse due to high contamination levels, sent for disposal at a landfill or municipal waste facility
• cyanide deposited in a tailings dam.

6. What examples would constitute a reuse or recycle (voluntary reporting)?

The voluntary reporting of NPI substances in transfers includes the following destinations:

• reuse
• recycling
• reprocessing
• purification
• partial purification
• immobilisation
• remediation or
• energy recovery

Examples of voluntary transfers would include:

• effluent or other material from intensive livestock practices used as a fertiliser
• composting of organic waste (on site)
• reuse of a residue back into the processing system as a fuel source
• substances in waste oils sent to a recycler.

7. How will transfer information be presented on the NPI website?

The information on transfers will be presented separately to the emissions data in order to minimise any misinterpretation between transfers and emissions data. The Australian Government is working hard at making changes to the NPI website and this amendment is included in the change.

The first public released information on NPI substances in transfers will be available from 31 March 2010.

8. How are transfers different to other waste tracking and reporting systems?

Transfers are part of international pollutant release and transfer registers (PRTRs) that bring together data on transfers and releases to the environment of pollutants. The information is made publicly available.

Other waste tracking and reporting systems, run separately by state and territories, only apply to certain types of waste with the requirements monitored and reported through each state/territory environment agency.

9. Estimation methodologies for waste transfers

The same estimation methodologies can be used for transfers that are used for emissions. For example:

• sampling data or direct measurement
• mass balance
• fuel analysis or engineering calculations
• transfer factors, and
• an approved alternative.

The NPI Guide will outline further detailed information on thresholds and identifying emission sources. Some manuals have been updated and the rest will continue to be updated as an ongoing process.

10. What are the thresholds for transfers?

Transfers are required to be reported if a Category 1, Category 1b or Category 3 reporting threshold is exceeded. For example, if the threshold has been exceeded for the Category 1 substance sulfuric acid as a result of use of this substance on site, transfers to final destination, as well as the amount emitted, is reportable.

There is no requirement to report transfers of substances that are exclusively Category 2a and/or 2b in the event that the fuel and energy use threshold has been exceeded (i.e. there is no requirement to report transfers of Oxides of Nitrogen, Particulate Matter ?10 µm, Particulate Matter ? 2.5 µm, Polychlorinated Dioxins and Furans, or Polycyclic Aromatic Hydrocarbons). There is also no requirement to report transfers of substances which are both Category 1 and Category 2 (e.g. Cadmium & compounds) if only the Category 2 threshold has been tripped. Reporting of transfers of the substance is required if the Category 1 threshold has been tripped.

11. If a company disposes some of its waste in a landfill site, which belongs to the company but is in a different location, how is this regarded?

This would be considered an off-site disposal, because the landfill is not adjacent to or contiguous with the facility.

12. If a facility uses town sewage in the process cycle of the facility, will this increase reported transfers. How can double counting be avoided?

The facility would only need to report the transfer of the substances if the residue is going to a mandatory transfer destination (i.e. landfill). There will be scope for reporters to provide contextual information to state if their mandatory transfer data is higher due to this reason and this information will be made publicly available. It is expected that this will mainly be attributed to Category 3 substances (Total Nitrogen and Total Phosphorus).