epa (usa) - bat landfill activities (abril 2003)

DRAFT April 2003

BAT GUIDANCE NOTES FOR THE WASTE SECTOR: LANDFILL ACTIVITIES

BAT Guidance Notes for the Waste Sector: Landfill Activities

Environmental Protection Agency ii Draft April 2003

1 INTRODUCTION ............................................................................................................5

1.1 General ......................................................................................................................... 5 1.2 BAT Guidance Note Structure ......................................................................................... 5 1.3 Using this Guidance....................................................................................................... 6 1.4 Relationship to Other Guidance....................................................................................... 7 1.5 Review and Updating ...................................................................................................... 7

2 INTERPRETATION OF BAT ........................................................................................10

2.1 Definition of BAT ...........................................................................................................10 2.2 Environmental Protection Agency Act 1992 .....................................................................11 2.3 Landfill Directive ............................................................................................................11 2.4 Determine Control Techniques ........................................................................................11 2.5 Innovation .....................................................................................................................12 2.6 Identifying Emission Levels against ELVs .......................................................................12 2.7 Site Location Selection..................................................................................................12 2.8 Assessment of BAT ......................................................................................................12 2.9 Application of BAT to New Facilities................................................................................13 2.10 Application to Existing Facilities ...................................................................................13

3 ACTIVITies DESCRIPTION AND KEY ISSUES.........................................................14

3.1 Overview of Landfill Activity.............................................................................................14 3.2 Classes of Landfill .........................................................................................................15 3.3 Landfill Activities Covered by IPPC Directive.....................................................................15 3.4 Other Activities .............................................................................................................16 3.5 Key Issues for Landfill Activities......................................................................................16

4 FACILITY DESIGN........................................................................................................22

4.1 Site Location ................................................................................................................22 4.2 Engineered Liner Systems .............................................................................................23 4.3 Stability and Settlement.................................................................................................24 4.4 Raw Materials Selection ................................................................................................27 4.5 Energy Efficiency ..........................................................................................................27 4.6 Energy Utilisation..........................................................................................................29 4.7 Leachate Management ..................................................................................................29 4.8 Landfill Gas Management...............................................................................................30

5 FACILITY MANAGEMENT ...........................................................................................31

5.1 Experienced and Competent Management.......................................................................31 5.2 Management and Environmental Management Systems (EMS).........................................31 5.3 Accident Prevention.......................................................................................................33

6. WASTE ACCEPTANCE ................................................................................................35

6.1 Classes of Landfill .........................................................................................................35 6.2 Prohibited Wastes.........................................................................................................36 6.3 Pre-treatment of Waste..................................................................................................36 6.4 Waste Checking ...........................................................................................................37


Environmental Protection Agency iii Draft April 2003

7 POTENTIAL EMISSIONS AND THEIR SOURCES....................................................39

8. MONITORING...............................................................................................................40

8.1 Monitoring Guidance......................................................................................................40

9 CLOSURE AND AFTERCARE.....................................................................................41

9.1 Purpose .......................................................................................................................41 9.2 Cessation of Waste Disposal .........................................................................................41 9.3 Restoration and Aftercare...............................................................................................41 9.4 Maintenance of Environmental Pollution Control Systems .................................................41

APPENDIX 1 Prescribed LANDFILL ACTIVITies............................................................43

APPENDIX 2 POTENTIAL EMISSIONS AND THEIR SOURCES ..................................44

Table A2.1: Potential Emissions to Air..................................................................................45 Table A2.2: Potential Emissions to Water.............................................................................46 Table A2.3: Potential Emissions to Land...............................................................................48 Table A2.4: Potential Emissions of Noise & Vibration.............................................................49 Table A2.5: Potential Emissions of Heat ...............................................................................50

APPENDIX 3 Emission ELIMINATION AND CONTROL TECHNIQUES.......................51

Surface & groundwater management ....................................................................................53 Leachate production/ collection............................................................................................55 Leachate treatment .............................................................................................................58 Landfill Lining .....................................................................................................................60 Landfill Capping ..................................................................................................................65 Landfill gas management .....................................................................................................69 Landfill gas utilisation & flaring .............................................................................................71 Fuel/oil storage...................................................................................................................74 Dust/Fine Particulates (PM10)...............................................................................................76 Odour ................................................................................................................................78 Litter..................................................................................................................................80 Noise & vibration.................................................................................................................82 Vehicles ............................................................................................................................84 Birds .................................................................................................................................85 Vermin & insects................................................................................................................87 Mud...................................................................................................................................88 Fires..................................................................................................................................89 Security.............................................................................................................................90

APPENDIX 4 ENVIRONMENTAL QUALITY STANDARDS AND EMISSION LIMIT VALUES .......................................................................................................................92

Environmental Quality Standards (EQS)................................................................................92 Emission Limit Values ........................................................................................................92 Setting the ELVs ................................................................................................................93 Table A4.1 Environmental Quality Standards for Surface Waters relating to SI 294/1989EC and SI 293/1988 EC......................................................................................................................99 Table A4.2 Emissions from Landfill Gas Flares to air............................................................102 Table A4.3 Emissions from Landfill Gas Utilisation Plants to air ............................................103 Table A4.4 Fugitive Emissions to Air ..................................................................................104


Environmental Protection Agency iv Draft April 2003

Table A4.5 Emissions of Noise ..........................................................................................106 Table A4.6 Emissions of Vibration......................................................................................107

APPENDIX 5 SUMMARY OF LANDFILL DIRECTIVE TECHNICAL REQUIREMENTS 108

APPENDIX 6 REFERENCES...........................................................................................109

References cited in this Guidance Note ..............................................................................109 Supplementary References ................................................................................................111

APPENDIX 7 GLOSSARY................................................................................................113

Terms..............................................................................................................................113 Abbreviations....................................................................................................................119


Environmental Protection Agency Draft April 2003

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1 INTRODUCTION

1.1 General

This Guidance Note is one of a series issued by the Environmental Protection Agency (EPA) which provide guidance on the determination of Best Available Techniques (BAT) in relation to applicants seeking licences under:

The Waste Management Act, 1996 (WMA), and associated Regulations; and as due to be amended by the Protection of the Environment Act, 2003

The Environmental Protection Agency Act, 1992, and associated Regulations and as due to be amended by the Protection of the Environment Act, 2003

This Guidance Note serves to assist operators of waste facilities to determine BAT for Landfill Activities. The specific waste disposal activities covered by this Guidance Note are listed in Appendix 1 and explained in Section 3. Other EPA BAT Guidance Notes for the Waste Sector cover the following topics:

Waste Transfer and Waste Treatment Activities.

This Guidance Note does not prejudice the requirements of the Safety, Health and Welfare at Work Act 1989, (No. 7 of 89) and its relevant statutory provisions in relation to waste activities.

1.2 BAT Guidance Note Structure

To ensure a consistent approach to the determination of BAT for landfill activities this Guidance Note has been structured as follows:

Section Details

1 Introduction

2 Interpretation of BAT

3 Landfill Activity Description and Key Issues

4 Facility Design

5 Facility Management

6 Waste Acceptance

7 Potential Emissions and their Sources

8 Monitoring

9 Closure and Aftercare

Appendices



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Where relevant, references are made to other detailed guidance, such as EPA Landfill Manuals,(Appendix 6) and the determination of BAT should be made giving regard to these.

Appendices provide detailed guidance on BAT for the activities associated with landfill as follows:

Appendix Title

1 Prescribed Landfill Activities

2 Potential Emissions and their Sources

3 Emission Elimination and Control Techniques

4 Environmental Quality Standards and Emission Limit Values

5 Summary of Landfill Directive Technical Requirements

6 References

7 Glossary

1.3 Using this Guidance

Figure 1.1 outlines a general approach for identifying BAT relevant to landfill activities. BAT should be identified for all elements of a waste treatment process and for the facility overall in accordance with the steps outlined in Figure 1.1.

Figure 1.1: Approach to identifying BAT

Periodic Review of Process Activities

Identify Potential Emissions to Land, Air,

Water and their Sources (Appendix 2)

Monitoring and

Measurement

Determine Control

Techniques to Prevent, Reduce or Eliminate

Emissions(Appendix 3)

Describe the Landfill Activities

Emissions substances (liquid, solid, gas),noise, vibration or heat

Ensure Emissions Do Not Exceed Limit Values

(Appendix 3 & 4)

Identify Emission Levels against

ELVs (Section 2.3)



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1.4 Relationship to Other Guidance

This Guidance Note forms part of an overall regulatory package for the waste sector. The main elements are outlined below and relevant documents should be referred to in the determination of BAT.

Principal legislative framework for the application of BAT Integrated Pollution Prevention and Control (IPPC) Directive (96/61/EC); Landfill Directive (1999/31/EC); Groundwater Directive (80/68/EEC); and WMA 1996 (plus amendments and regulations) Protection of The Environment Act (expected 2003)

Other legislation, for example the Environmental Protection Agency Act 1992 and the Environmental Impact Assessment (EIA) Regulations should be taken into account as appropriate;

BAT Guidance Notes which should be used in parallel with other guidance on Waste Licence Applications, guidelines on facility selection/location and Environmental Impact Assessment;

Other guidance On Waste Acceptance (EPA Landfill Manuals series); National Environmental Quality Objectives Environmental Quality Standards; Waste Management Plans; Water Management Plans; Environmental Management Systems (eg ISO14001:1996, EMAS); EU Conservation Directives (eg Habitats, Wild Birds); and Financial Instruments. EPA website: www.epa.ie (re. list of publications and current information)

Other documents, such as those on standards and techniques will feed into the determination of BAT as they become published. The key reference documents are listed in Appendix 6.

The relationship between the various regulatory aspects and BAT is shown in Figure 1.2.

1.5 Review and Updating

This Guidance Note will be periodically reviewed and updated as required to reflect any changes in supporting guidance and regulation and in order to incorporate technological



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advances as they arise.



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Figure 1.2: Document Links for BAT Determination2

2 EU Directives include those relating to: groundwater; habitats; wildlife; IPPC; dangerous substances; UWWT; hazardous waste, air quality, etc (See Appendix 6 for full references)

B

A

T

EU Legislation (Appendix 6)

National Legislation (Appendix 6)

Waste Licence Application

Waste Licence Assessment

Waste Licence

BAT Guidance Notes

EU BREF Notes (See Section 2.5)

Waste Licence Application

Waste Management Plans

EPA Landfill Manuals

Water Management Plans

Financial Provisions Fit & Proper

EMS Standards

Groundwater

EIA Guidance

EU Wildlife Directives

Standards and Techniques



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2 INTERPRETATION OF BAT

2.1 Definition of BAT

BAT was introduced as a key principle in the IPPC Directive, 96/61 EC. This Directive is due to be enacted into the Irish Statutes by the Protection of the Environment Act 2003. To meet the requirements of this Directive relevant Sections of the EPA Act 1992 and the Waste Management Act 1996 have been amended to replace BATNEEC (Best Available Technology not Entailing Excessive Costs) with BAT. Thus, for activities falling within the scope of the Directive that are regulated by these Acts, BAT must be applied. For any activities not within the scope of the Directive, but regulated by the relevant Sections of the Acts, BAT will also apply (See 3.3).

BAT is defined in Article 2(11) of the IPPC Directive as follows:

best available techniques shall mean the most effective and advanced stage in the development of activities and their methods of operation which indicate the practical suitability of particular techniques for providing in principle the basis for emission values designed to prevent and, where practicable, generally to reduce emissions and the impact on the environment as a whole:

techniques shall include both the technology used and the way in which the installation is designed, built, maintained, operated and decommissioned.

available techniques shall mean those developed on a scale which allows implementation in the relevant industrial sector, under economically and technically viable conditions, taking into consideration the costs and advantages, whether or not the techniques are used or produced inside the Member State in question, as long as they are reasonably accessible to the operator.

best shall mean the most effective in achieving a high general level of protection of the environment as a whole.

Annex IV of the Directive lists considerations to be taken into account when determining BAT as defined above. Consideration should give regard to the likely costs and benefits of a measure and the principles of precaution and prevention.

The Waste Management Act, 1996 Section 40(4) requires that appropriate controls be identified for specified waste activities in order to prevent emissions and to protect human health and the environment from pollution. The essence of BAT is that the selection of techniques to protect the environment should achieve an appropriate balance between



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realising environmental benefits and the costs incurred by the person carrying on the activity. In the identification of BAT, emphasis is placed on pollution prevention techniques, including cleaner technologies and waste minimisation, rather than end-of-pipe treatment.

In determining BAT, applicants for Waste Management Licences must also demonstrate that due account has been taken of:

the hierarchy for waste management, including waste prevention as the priority, followed by waste recovery and finally safe disposal of any remaining non-recoverable wastes;

relevant waste management plans.

2.2 Environmental Protection Agency Act 1992

Industrial Facilities that are listed in Schedule 1 of the EPA Act 1992 are licensed under the EPA (Licensing (IPC) ) Regulations 1994(SI 85 0f 1994). Where such activities undertake on-site recovery or disposal of waste they must apply BAT for the waste sector to the operation of their waste activities. The Waste Management (Amendment) Act 2001 (WMA) made amendments to the first schedule of the EPA Act 1992 to incorporate the link between the two licensing systems. Details of the relationship between the WMA 1996 and the EPA Act 1992 are provided in Appendix 1.

2.3 Landfill Directive

The provisions in Directive 1999/31/EC on the Landfill of Waste (the Landfill Directive) are also relevant to the deposit of waste on, in or under land, which are covered by this Guidance Note. The Landfill Directive includes specific requirements for the siting, operation, management and monitoring of landfills. The provisions of the Landfill Directive are applied through the waste licensing system under the WMA. The assessment of BAT for landfill activities must therefore be consistent with and comply with these technical requirements which are summarised in Section 3 of this Guidance Note.

2.4 Determine Control Techniques

BAT reference documents (BREF) are produced by the European Commission as an expert opinion of what is considered to be BAT for a specific sector and is intended to be a driver towards improved environmental performance across the European Union. The BREF note on waste treatment is currently in preparation. Progress on its production can be monitored at the following web site location http://eippcb.jrc.es/pages/FActivities.htm. It will be for Waste Treatments and it will offer information to guide the determination of BAT-based permit conditions with respect to the IPPC Directive.



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When BREF documents become available these should be taken into account when determining BAT, although member states have flexibility in their application.

2.5 Innovation

Technologies identified in the Waste Sector BAT Guidance Notes are considered to be current best practice at the time of writing. The EPA encourages the development and introduction of new and innovative technologies which meet BAT criteria and looks for continuous improvement in the overall environmental performance of waste sector activities as part of sustainable development. Operators should therefore continue to keep up to date with the best available technologies relevant to the activity and discuss appropriate innovations with the EPA.

2.6 Identifying Emission Levels against ELVs

In the process of identifying BAT, site-specific emission levels should be determined and compared to ELVs (specified Emission Limit Values). These emissions relate both to direct and indirect release of substances (liquid, solid or gaseous), vibration, heat or noise from individual or diffuse sources within the waste treatment facility into the air, land or water. Details of ELVs for specific media and activities associated with waste treatment are given in Appendix 4.

2.7 Site Location Selection

Site location selection criteria are outlined in Sections 3 and 6 but for definitive guidance on BAT for this activity the Draft EPA Landfill Manuals - Manual on Site Selection (Appendix 5) the EPA, DoELG & GSI guide Ground Protection Responses for Landfills ,and Local Authority Regional Waste Management Plans should be referred to.

2.8 Assessment of BAT

At the facility level, the most appropriate techniques will depend on local factors. A local assessment of the costs and benefits of the available options may be needed to establish the best option. The choice may be justified on:

the technical characteristics of the facility;

its geographical location; and

local environmental considerations.



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Individual company profitability is not a relevant consideration.

2.9 Application of BAT to New Facilities

The technologies and the associated emission limit values (ELVs) identified in this Guidance Note are regarded as representing BAT for a new facility.

To demonstrate that BAT is being applied, consideration must be given to measures that can be taken to reduce or eliminate emissions from the landfill facility.

The applicant should aim for continuous improvement in performance to prevent, eliminate and/or progressively reduce emissions.

The technologies identified in this Guidance Note are representative of a wide range of currently employed techniques appropriate to particular circumstances. However, the guidance issued in this Note in respect of the use of any technology, technique or standard does not preclude the use of any other similar technology, technique or standard that may achieve the required emission standards.

2.10 Application to Existing Facilities

For existing facilities, it is envisaged that they will progress towards attainment of similar ELVs, but specific ELV requirements and associated time frames for attainment will be identified on a case by case basis when the licence review is being processed. In addition to the considerations outlined above for new activities, the following should be taken into account for existing facilities:

the nature, extent and effect of the emission concerned. In particular, regard should be taken of sensitive receptors and local environmental impacts. A risk-based approach should be used to establish the extent of hazards and identify appropriate controls;

the nature and age of the existing facilities connected with the activity and the period during which the facilities are likely to be used or to continue in operation; and

whether a disproportionate cost would be incurred to replace the old plant with the new techniques for only a small reduction in emissions.

the Landfill Directive (Article 14) places a requirement on existing facilities to prepare a conditioning plan. The plan must describe the measures that will be implemented to bring the landfill to the standards required for a new facility.



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3 ACTIVITIES DESCRIPTION AND KEY ISSUES

3.1 Overview of Landfill Activity

Landfilling and associated activities covered by this Guidance Note are summarised in Figure 3.1. The EPA Landfill Manuals provide further details of these (Appendix 6).

Figure 3.1: Summary of a Landfill Activity1

A landfill is essentially an engineered construction activity where waste forms the raw material for the process. Materials entering the facility are delivered to a reception and

1 LFG landfill gas; LTP leachate treatment plant

Emissions Management Systems

BOUNDARY OF LANDFILL ACTIVITIES

Pre-treatment prior to landfill including sorting, recycling, composting etc

Waste Reception

Inspection/ Acceptance

Operational Cell

Cell in Preparation

LFG Collection

Completed Cell

Leachate Collection

LFG Flare Leachate Storage/LTP

LFG Utilisation

Plant

Monitoring Systems



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handling area where other waste management activities may also take place (refer to BAT Notes for Waste Transfer and Waste Treatment as appropriate). Following checking and acceptance, the waste is transported to the disposal point. The landfill development activity is phased and, at any one time, cells can be under preparation, in operation or in the process of restoration. In assessing BAT, consideration must therefore be given to both the spatial and temporal nature of the activity.

In certain classes of landfill, waste may decompose over time and change in nature. Therefore, where relevant the provision of measures to control emissions from the products of decomposition, including leachate and landfill gas, form an integral part of the activity.

3.2 Classes of Landfill

The Landfill Directive defines three classes of landfill:

hazardous

non-hazardous

inert

Only wastes falling within the categories of waste permitted for that class of landfill may be accepted. Definitions of these broad categories of waste are given in Article 2 of the Landfill Directive.

Hazardous waste" means any waste which is covered by Article 1(4) of Council Directive 91/689/EEC

"Non-hazardous waste" means waste, which is not classified as hazardous waste and may include municipal waste.

"Inert waste" means waste that does not undergo any significant physical, chemical or biological transformations. Inert waste will not dissolve, burn or otherwise physically or chemically react, biodegrade or adversely affect other matter with which it comes into contact in a way likely to give rise to environmental pollution or harm human health. The total leachability and pollutant content of the waste and the ecotoxicity of the leachate must be insignificant, and in particular not endanger the quality of surface water and/or groundwater.

The determination of BAT will be dependent on the class of landfill and only guidance that is relevant to the site under consideration should be applied.

3.3 Landfill Activities Covered by IPPC Directive

Annex 1(5) of the IPPC Directive specifies the categories of waste management facilities covered by the Directive. Annex 1(5.4) details the sites covered as:



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Landfills receiving more than 10 tonnes per day or with a total capacity exceeding 25,000 tonnes, excluding landfills of inert waste

In addition to the criteria in the Directive, the Waste Management Act, 1996 Section 40(4), extends the coverage to all landfill activities through limiting licences to those facilities where:

Emissions from the activity comply with relevant standards or emission limits;

The activity will not cause environmental pollution;

BAT is employed to prevent or eliminate or, where that is not practicable, to limit, abate or reduce an emission;

The applicant is a fit and proper person to hold a waste licence (see Section 3.5.2); and

The applicant has made sufficient financial provision for the operation of the facility (see Section 3.5.2).

Therefore all landfill facilities need to demonstrate that they are using BAT, regardless of size or class.

Schedules 3 & 4 of the Waste Management Act, 1996 list Classes of licensed activities. The Classes covered by this guidance are listed in Appendix 1.

3.4 Other Activities

As well as the landfill disposal of waste, other ancillary activities may take place on a landfill facility such as composting, recycling, leachate treatment and landfill gas management. This Guidance Note covers only landfilling and directly connected activities i.e. leachate treatment and landfill gas management. other activities, such as composting, are covered by different BAT notes. Where an application is made that covers more than one activity on the same site, all relevant BAT Guidance Notes applicable to the activities should be considered by the applicant before an application is submitted.

3.5 Key Issues for Landfill Activities

The key issues associated with landfill activities and facility management are summarised here. Where applicable, references for specific and detailed guidance are indicated in each sub-section.



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3.5.1 Waste as the Raw Material

Within the IPPC regime, waste management is unique because the installation is a landfill facility where the majority of the raw material is residual waste. Providing that recovery/pre-treatment has been undertaken prior to delivery to the disposal point, there is little opportunity to further prevent or recover waste once it enters the landfill. Therefore, the requirement to describe the raw materials relates to the quantity and nature of residual waste(s) which will be disposed of and any ancillary materials that will be used on the facility. Prevention measures should be focused on the emissions from the facility e.g. leachate and landfill gas, as opposed to the residual waste that has been deposited at the facility.

3.5.2 Fit and Proper Person

With the exception of Local Authority operated facilities2, waste licence applicants need to demonstrate that they are a fit and proper person (Waste Management Act, 1996 S40 (7)). There are two elements that these applicants need to satisfy:

i) the applicant or other relevant persons shall not have not been convicted of a prescribed offence3, and

ii) the applicant or other relevant persons shall have the appropriate technical knowledge or qualifications to operate the facility in accordance with the licence. This includes successfully completing the FS-Certified Waste Management Training Programme or equivalent.

3.5.3 Financial Provision

The applicant is also required to demonstrate adequate financial provision for the development and operation of the site have been made and that the applicant can meet the requirements of the EC (Amendment of Waste Management (Licensing) Regs 2000), 2002), SI 337 of 2002. In particular the applicant must be able to demonstrate that:

the charges made for treatment of waste at the site cover all activities associated with the development, operation, closure and decommissioning of the site;

he is in a position to meet any financial commitments associated with fulfilling the obligations under the licence, including sufficient financial provision to cover the cost of closure and decommissioning for a period of at least 30 years. Financial aspects may include the provision of financial bonds and the purchase of public liability insurance, and

the applicant may also wish to consider establishing a voluntary environmental fund to develop closer links with the local community. The fund could be under the control of the applicant and other representative bodies such as the local authority, local community groups, or liaison committees. These bodies would consider suitable local community

2 WMA Section 40(4)(d) exempts Local Authorities from this requirement 3 WMA Section 40(8) allows the EPA to decide if a convicted person can still be fit and proper.



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projects within the vicinity of the landfill that could be the beneficiaries of grants from such a fund.

3.5.4 Landfill Directive Requirements

See Appendix 5

The Landfill Directive applies specifically to landfill waste disposal activities and contains three main elements:

specifications for the three generic classes of landfill;

requirements for the design, regulation and management of landfills to ensure the protection of the environment; and

measures aimed at preventing unsuitable wastes going to landfill, reducing the amount of waste going to landfill in general, and biodegradable municipal waste in particular.

3.5.5 Site Location

See Section4.1 and Appendix 6

The Landfill Directive requires the consideration of several factors in the selection of a landfill site location. These are outlined in Section 4.1. Detailed references addressing site location issues are given in Appendix 6, and include:

Landfill Directive

EPA Landfill Manuals Landfill Site Selection (Draft)

EPA Landfill Manuals Investigations for Landfill

Groundwater Protection Responses to Landfills (EPA, DoELG and Geological Survey Ireland 1999)

3.5.6 Design Considerations

See Section 4

Key design issues that need to be addressed when determining BAT are detailed in Table 3.1:



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Table 3.1 Key Site Location and Design issues for Landfill Facilities

Consideration Design Issue Guidance Note

Reference

The nature and quantity of

waste

This directly affects environmental control

measures

Section 4

Water control Rainfall, surface water runoff and groundwater

protection

Section 6

Protection of soil and water Selection of type of liner system Section 6.2

Stability Stability of the site base, liner system, waste

mass and capping

Section 6

Appendix 3 T4; T5

Development aspects Facility design, planning and applied

processes, construction, operation, closure

and aftercare

Sections 6 and 9

Monitoring requirements Provision and installation of monitoring points

within and outside the facility

Section 8

Landfill afteruse Compatibility with the proposed afteruse Section 9

Landfill phasing Operational and restoration requirements,

location of facility infrastructure

Section 9

Leachate management Leachate collection system and

treatment/disposal facility

Appendix 3 T2; T3

Landfill gas control Potential for gas migration, gas collection, gas

burning/utilisation

Appendix 3

T6,T7,T10

Environmental nuisance (a) during construction e.g. noise, dust, mud Appendix 3 T9; T12;

T16

Environmental nuisance (b) during operation, e.g. noise, odours,

dust, litter, birds, vermin and fires

Appendix 3 T9; T10;

T11; T12; T14; T15

Visual appearance During operation and after restoration

When considering facility design, applicants should refer to Section D in the EPA Waste Licensing Waste Disposal Activities (Landfill Sites); Guidance Note for Applicants. This covers facility design issues and the detailed information on landfill design contained within the EPA Landfill Manuals Landfill Site Design.

3.5.7 Facility Management

See Section 5

Facility location and design are not the only factors that influence the potential impacts of a landfill. The manner in which a facility is managed is a critical element in ensuring emissions from a landfill are minimised. Therefore management of facilities must ensure that:



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staff are competent to manage and operate the facility, ie a Fit and Proper Person (see Section 3.5.2)

there are systems in place to ensure standards are maintained, including incident and complaints management procedures, eg. environmental management systems.

3.5.8 Waste Acceptance

See Section 6

The nature of the waste deposited in a landfill and the way in which that waste is handled can have a significant effect on the potential for a landfill facility to cause pollution or harm to health.

Controlling the waste input to the facility is one of the most important operational matters. The deposit of waste for which the facility is designed, and therefore permitted to accept, can have a direct effect upon the pollution/nuisance potential of the facility. It is essential that measures be introduced to ensure that only those wastes for which the facility was designed, and which are permitted by the licence, are deposited. Section 6 provides guidance on waste acceptance.

3.5.9 Potential Emissions and their Sources

See Section 7 and Appendix 3 T9; T10; T11; T14; T15; T16 and Appendix 5

The construction of the landfill and the delivery and disposal of waste and other materials have the potential to cause a range of nuisances and potential risks to the environment and to human health (nuisances and hazards are listed in Appendix 5). While nuisance can be controlled by careful siting, design and engineering, it should also be considered in the operational management on a day-to-day basis

3.5.10 Monitoring

See Section 8 and Appendix 3 All T guidance

Monitoring is required throughout the life of a landfill from the pre-operational phase through to the operational and aftercare phases. The objectives of a monitoring programme are to:

detect adverse environmental impacts from the landfilling of waste; provide information for the assessment of a licence application or surrender of a licence; demonstrate that the environmental control measures are operating as designed; assist in the evaluation of the processes occurring within the waste body; and demonstrate compliance with the licence conditions.



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The scope of the programme is identified from the investigation process, the environmental impact assessment and the nature of the waste to be deposited at the facility. The relevant monitoring criteria for specific emission elimination and control techniques are included in Appendix 3.

Further information is contained in the EPA Landfill Monitoring Guidance Note of which the updated version is currently being finalised and will be published in 2003.

3.5.11 Restoration and Aftercare

See Section 9

Restoration is the process that will return a landfill to a condition suitable for the selected afteruse. Restoration includes design, landscaping works, soil spreading, final landform construction and aftercare.

Aftercare involves any measures that are necessary to be taken in relation to the facility for the purposes of preventing environmental pollution following the cessation of landfill activities at the facility and the capping and restoration of the site.



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4 FACILITY DESIGN

This Section highlights the issues to be considered and addressed when determining BAT for the design of the facility and the materials used on the site. EPA Landfill Manuals on Site Selection (draft) and Investigation for Landfills should be referred to for detailed design guidance (Appendix 6).

4.1 Site Location

In selecting a suitable location for a landfill, the basic requirement is that it will not cause environmental pollution, taking into account the characteristics of the location and the control measures to be employed. To determine the suitability of a location the applicant must:

consider the distance from the boundary of the site to residential and recreational areas, waterways, water bodies and other agricultural or urban sites;

take account of any relevant Regional Waste Management Plans or Development Plans

identify any groundwater, coastal water or nature protection zones in the area.

investigate the geological and hydrological conditions, and identify the corresponding Groundwater Protection Response code for landfills in the area

consider the risk of flooding, subsidence, landslides on site

consider the protection of the nature and cultural heritage in the area

undertake a site investigation (the site investigation will also establish a baseline status for the land to enable closure and aftercare criteria to be set, see Section 9);

identify the potential environmental effects and risks; and

determine if emission control measures can prevent the developed site posing a serious environmental risk during its operation.

These issues would normally be addressed in the Environmental Impact Statement for the site.

Buffer Zones

In assessing the suitability of site location, BAT should consider whether a buffer zone should be included to minimise or prevent adverse impact on local sensitive receptors, such as occupied dwellings. Therefore, the applicant should consider the location of the proposed landfill in relation to its surroundings and in particular its proximity to sensitive receptors.



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Guidance on site selection is given in the Landfill Directive and the EPA Landfill Manuals on Site Selection, which suggest a minimum distance of 250m between the area to be landfilled and sensitive occupied dwellings. Other potentially sensitive receptors may also need consideration. However, as the environmental setting of each potential landfill site is likely to have its own individual characteristics, the need for a buffer zone and the extent of that zone must be considered on a site-specific basis giving regard to available guidance on relevant site issues and risks.

The applicant should consider whether a buffer zone is required between the site with its potentially disturbing activities and the surrounding neighbouring properties. Establishing such a zone off the site on land not in his ownership or under his control may be difficult. The applicant may therefore consider whether attenuation measures such as screening mounds and fences or woodland strips within his site boundary would provide adequate separation. The applicant should also consider locating particularly disruptive activities (e.g. noise generation) away from sensitive receptors and consider appropriate operating times. In this respect, careful consideration should be given to the location of activities that may give rise to wind-blown nuisance, e.g. dust, litter, noise, aerosols.

4.2 Engineered Liner Systems

See Appendix 3 T4 and T5

The stability of liner systems during facility preparation and filling with waste must be assessed with regard to:

subgrade stability, as discussed above;

inter-liner stresses and slip planes in all potential circumstances;

liner systems incorporating geosynthetics/ geotextiles/ geocomposite drainage blankets, and their performance under non-ideal circumstances;

the effects of potentially varying leachate head;

cellular filling and temporary slopes;

the effects of variations in waste types and characteristics.

The applicant should design a liner that as a minimum meets the requirements of the Landfill Directive 4. During construction appropriate QA testing of the liner system must be carried out to ensure design requirements are met. Reference should be made to the EPA Landfill Manuals Landfill Site Design for test criteria. A risk assessment may demonstrate that these values should be increased. These are defined in terms of permeability and thickness and are:

4 Landfill Directive Annex 1 General requirements for all classes of landfills 3.2 Geological barriers



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Landfill for Inert waste K 1.0 x 10 7 m/s thickness 1 m

Landfills for Non Hazardous Waste K 1.0 x 10 9 m/s thickness 1 m

Landfills for Hazardous Waste K 1.0 x 10 9 m/s thickness 5 m

Where the geological barrier does not naturally meet the above conditions it can be completed artificially and reinforced by other means giving equivalent protection.

4.3 Stability and Settlement


The stability of the waste and its foundation is integral to the performance of a landfill containment system. An assessment of slope stability and settlement should be conducted to ensure that during each phase of work the integrity of the liner and capping will not be compromised. The critical issues for BAT relating to stability and settlement occur in three possible modes:

Liner failure during the construction and operational phases

Settlement or slippage of waste during the operational phase

Settlement during the post operational phase

The requirements of the Landfill Directive with respect to stability of the waste and the geological substratum are summarised in Annex I of the Directive. To prevent the risk of emissions from failures, the landfill design should ensure that the landfill is stable under all combinations of loading and extremes of behaviour, during and after construction of the waste landform.

All aspects of geotechnical design must be carried out by appropriately qualified (e.g. CEng) and technically competent person(s). The assessment of all geotechnical elements should be made using conventional calculations as guided by best current practice at the time of the design. Examples are given in Table 4.1.

Table 4.1: Design standards for stability

Aspect Standard Comment

Stability/ general BS 6031 : 1981 Code of practice for earthworks

Earthworks should be designed by a geotechnical engineer based upon facility specific information

Foundation BS 8004 : 1986 Code of practice for foundations

Method specification should be proven by trial testing



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Waste is generally a heterogeneous material subject to decomposition, consolidation, and considerable variation, both spatially and with time. It is therefore likely to be inappropriate and potentially dangerous to analyse waste stability by adhering to conventional geotechnical parameters. However, there are some landfills which are homogeneous, for example industrial monofills containing mine waste tailings. These tailings landfills are sometimes kept flooded to prevent dust and therefore the structural aspects of the tailings dam would also be relevant. A geotechnical designer should therefore consider the current state of relevant knowledge.

The geotechnical designer should include in the assessment the following considerations for any or all of the liner, waste body, or cap:

Settlement or sliding within the foundation (subgrade) beneath the base or side wall liner;

Sliding within the liner system;

Sliding at the waste/liner interface;

Rotational failure within the waste, or through the whole cross-section;

Sliding failure of the cap or of its components.

During infilling and construction of the landform, its stability should be monitored by the establishment of an appropriate programme. In the light of the monitoring results, the design assumptions should then be re-considered and modified if appropriate. An appraisal of the geological, geotechnical, hydrogeological and hydrological conditions at the facility will be necessary.

Settlement or slippage of waste during the operational phase

The overall objective is to emplace the waste into its final position within the landfill in accordance with the design objectives, without compromising safety, the environment or local amenity.

Consideration should be given to the stability of temporary slopes during landfilling. The designer must ensure that any slope adopted for the temporary face will consider the nature of the waste, its moisture content, the height of the slope, the nature of the slope foundations, including the lining system, and the consequences of any possible failure.

The chosen slope should be appraised by a geotechnical engineer according to stability requirements in each case.



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Settlement of waste during the post-operational phase

The stability of the capping and restoration layers is affected by:

Maximum and minimum surface gradients The surface gradients should not compromise the overall stability of the landfilled wastes and the capping layers. They should provide adequate drainage of surface water and be appropriate for the proposed afteruse.

Afteruse considerations may require that a complex landform be produced. However, the fundamental objectives and performance criteria of the engineered cap must not be compromised,

Waste settlement Settlement of the completed waste mass beneath the capping layer will occur as a result of the consolidation and deposition of the emplaced waste. The settlement of the waste must not compromise any of the design features. The effects of settlement need to be considered in quarry landfills or in landfills whose base is non uniform (or stepped). Measures need to be taken to avoid problems due to differential settlement which can lead to stresses and breaks in the engineering cap, and possible releases of emissions. The designer should pay particular attention to engineering cap gradients at the edge of a landform, especially where this overlies an area of significant change in depth. In deep landfills, such as those located in disused quarries, constraints on plan area may require vertically tiered phases in addition to the full height phases described above.

Uniform settlement of the waste can normally be accommodated by the capping materials. However differential settlement can cause cracking of the capping layers and lead to emissions and failure of the surface containment system.

Prevention of Erosion The design gradients will depend on the overall design model determined through the risk assessment process and the requirements of the afteruse. The design will need to ensure that the finished landform is protected from water erosion and that slope stability is maintained. The stability of the various capping layers should be checked using recognised techniques5.

The designer should consider where differential settlement may occur and make provision to accommodate the settlement and the associated stresses. It is important to ensure continuous surface water drainage across areas of differential settlement e.g. using flexible synthetic/membrane channels. In extreme cases, ponding may occur or surface water may flow into the underlying waste through cracks in the cap.

5 Alexiew D, Berkhout H & Kirschner R (1995): On the slope stability of landfill capping seals using

GCLs in Geosynthetic Clay Liners, ed Robert M Koerner, Erwin Gartung & Helmut Zanzinger; published by AA Balkema/Brookfield. ISBN 90 5410 5194.



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4.4 Raw Materials Selection

See Appendix 3 T4; T5

The IPPC Directive requires that permitted installations should be operated in such a way that materials are used efficiently.

Materials and Products

In selecting materials and products, such as engineering materials, cover materials (e.g. soils; composted material, hessian), construction materials, fuel for machinery (e.g. diesel), water (eg for wheel washing), pesticides for fly control etc. the applicant should:

demonstrate the steps which have been, or are being taken to reduce the use of materials;

maintain a detailed inventory of raw materials used on the facility, including:

- the chemical composition of the materials where relevant;

- the quantities used or expected to be used;

- the fate of the materials (the approximate percentages that are released to the environment i.e. that which is not used for its intended purpose);

- environmental impact where known (e.g. degradability, bioaccumulation potential, toxicity to relevant species);

justify the continued use of any substance for which there is a less hazardous alternative;

have quality assurance procedures for the control of the content of raw materials;

provide a materials balance for materials used in facility development;

consider phasing of the development to minimise use of materials.

Material Substitution

The applicant should demonstrate that procedures are in place to determine the most suitable material for use, thus preventing use of materials that may have an unacceptable environmental impact in their manufacture, end-use and ultimate disposal.

4.5 Energy Efficiency

Energy Use

The IPPC Directive requires that permitted installations should be operated in such a way that energy is used efficiently. Landfill facilities use relatively small quantities of energy in comparison to large process industries. However, the applicant still needs to demonstrate that the energy is used efficiently.



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The main uses of energy at a landfill facility are:

heating, lighting and power in facility buildings;

power to facility equipment such as wheel wash, weighbridge, pumps, treatment processes, lighting etc.; and

fuel to power vehicles.

The applicant should quantify the energy consumption at the facility by the source of energy, i.e. electricity, gas, fuel and energy from waste (e.g. landfill gas utilisation). An example breakdown of energy consumption is as follows:

Energy Source Annual Quantity Used (KWh) % of Total

Electricity

Gas

Oil

Energy from waste

Other

Annual Quantity Used (litre)

Vehicle Fuel

The applicant should demonstrate that in the design of the facility, energy efficiency has been considered, including measures such as:

the use of basic, low cost physical energy efficiency techniques, e.g. gravity feed systems; and

the consideration of energy saving opportunities in process buildings, control rooms and offices required for the activity, e.g. insulation.

The applicant should demonstrate that purchasing, operating and maintenance procedures optimise the energy use by the facility by:

ensuring energy efficient equipment is purchased, including lighting, pumps etc;

ensuring equipment is serviced and maintained regularly;

ensuring equipment is switched off when not in use;

ensuring on-site vehicle movements are minimised and engines are switched off when not in use; and

reviewing equipment requirements on a regular basis.

Setting time of operation of igh-energy equipment to off-peak periods, where possible

Setting key performance indicators on an annual basis



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The applicant should review energy consumption on an annual basis and examine options for:

optimisation of energy supply, for example, use of landfill gas generated by waste disposal to generate heat/power; and

optimising/reducing energy consumption.

Many of the aspects of energy efficiency are likely to be delivered through management techniques and operating and maintenance procedures, which overlap and form part of the environmental management system (EMS) for the activity (see Section 5).

4.6 Energy Utilisation

Under the requirements of the Landfill Directive the operator must assess the potential for utilising landfill gas produced on site and if appropriate make outline proposals for its utilisation. The ability of a facility to produce gas that can be utilised is dependent on:

the type of waste accepted at the facility (therefore the requirement for energy utilisation principally applies to landfill accepting biodegradable waste);

the rate and type of degradation within the facility: and

the size of the facility.

The applicant should regularly monitor and determine when suitable levels are available to allow the gas to be utilised.

4.7 Leachate Management


Rain water landing on the waste will percolate into the waste mass, ultimately generating leachate. The design of a site must incorporate measures to minimise and contain the generation of leachate. These measures will reduce the risk of its migration beyond the site boundary, where it could pollute groundwater, and enable its removal and treatment.

Guidance on leachate generation and management is provided in Appendix 3, T2 and T3.



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4.8 Landfill Gas Management

See Appendix 3 T6; T7 and T10

The major components of landfill gas (LFG) are methane and carbon dioxide, which result from the breakdown of biodegradable wastes within the landfill. Both are greenhouse gases and odourless asphyxiants. Methane is flammable and explosive when in mixtures with air at certain concentrations. Other components of landfill gas such as hydrogen sulphide, mercaptans and other trace gases give rise to odour nuisance even at very low concentrations and are responsible for the characteristic smell of landfill gas.

Estimates of gas production can be determined by gas pumping tests or computer modelling. The rate of gas generation within a landfill varies throughout the life of a landfill and is dependent on several factors:

waste type waste depth moisture content degree of compaction landfill pH temperature atmospheric pressure age of waste. The Landfill Directive requires that landfill gas is collected from all landfills and used. As such, a landfill gas management system is essential to:

minimise the risk of migration of LFG beyond the perimeter of the facility; minimise the risk of migration of LFG into services and buildings on the facility; avoid unnecessary ingress of air into the landfill and thereby minimise the risk of

fires/explosions; minimise damage to soils and vegetation; and minimise the impact on air quality and the effect of greenhouse gases on the global

climate.



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5 FACILITY MANAGEMENT

The manner in which a landfill facility is managed is critical to minimising the emissions from the facility. There are three key areas to consider in facility management

Experienced and Competent Management

Management and Environmental Management Systems (EMS)

Accident Prevention

5.1 Experienced and Competent Management

It is a requirement of The Waste Management Act, 1996 that a private sector applicant and other relevant persons associated with the applicants business have the appropriate technical knowledge or qualifications to operate the facility in accordance with the licence. Therefore the applicant needs to ensure that there are staff who have successfully completed the FS-Certified Waste Management Training Programme or an equivalent qualification and that the experience of the staff is commensurate with the level of expertise required. An ongoing assessment of training needs to be provided, to include new areas of development and refresher courses.

5.2 Management and Environmental Management Systems (EMS)

The implementation and operation of an environmental management system (EMS) is a requirement of a waste licence and an effective system of environmental management is fundamental to ensuring that all appropriate pollution prevention and control techniques are delivered reliably and on an integrated basis. The EMS should also be demonstrating that improvements in environmental performance across the range of activities are being planned and achieved. The International Standard ISO14001:1996 is one example of an EMS specification which establishes these aims, which can then be demonstrated to interested parties.

The EMS should be described in sufficient detail to demonstrate:

how it meets the requirements of the management system specification; and

how it is applied to the operational issues in practice.



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5.2.1 Requirements of the EMS:

The minimum requirements for an environmental management system at a waste management facility are:

(a) Schedule of Environmental Objectives and Targets that must include:

identification of the key environmental impacts of the activities;

objectives and measurable goals for environmental performance;

a program of improvements to implement goals and targets;

feedback from the monitoring program to the targets setting procedure to allow the regular improvement of targets where appropriate; and

an Environmental Management Program as detailed in the EPA Landfill Manuals - Landfill Operational Practice.

(b) Corrective Action including:

procedures to be followed in the event of a complaint being made or an incident occurring at the facility; and

procedures to analyse faults and prevent their recurrence.

(c) Awareness and Training including:

a clear statement of the skills and competencies required for each job;

awareness of the regulatory implications of the Licence for the activity and their work activities;

awareness of all potential environmental effects from operation under normal and abnormal circumstances;

prevention of accidental emissions and action to be taken when accidental emissions occur;

implementation and maintenance of training records for operational staff;

methods of ensuring that staff assigned to both technical and managerial posts have sufficient qualifications, training and experience for their roles.

(d) Management Structure: clear allocation of responsibilities for environmental performance, in particular meeting the aspects of the facility licence.

(e) Communications Procedures to ensure that information on the environmental performance of the facility is available to the public.



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(f) Regular reporting of environmental performance (annual or linked to the audit cycle), both for:

submitting the Annual Environmental Report to the EPA; and

ideally submitting a public environmental statement;

(g) Regular audit of the EMS, both internal and independent

The applicant must demonstrate how the EMS applies in practice to the operation of the facility in particular:

the use of materials on the facility including raw materials, water and energy;

the control of emissions; and

? facility monitoring

The functional relationship between an EMS and emission control and emission elimination techniques guidance for landfill activities is outlined in Table 7.1. This makes reference to the guidance details provided in Appendix 3.

5.3 Accident Prevention

The IPPC Directive requires accident prevention to be addressed as part of the assessment of BAT. Many of the aspects of accident prevention are likely to be delivered through the EMS for the activity and the inclusion of appropriate procedures within the Environmental Management Programme (EMP) and incident management procedures. Through these systems and procedures the applicant must demonstrate that:

potential accidents which may occur as a result of facility operations have been identified and assessed;

the risks associated with any accident have been identified along with the probability of the accident occurring and the potential impact of the accident;

measures are in place to prevent accidents occurring;

steps have been taken to minimise the consequence of any accident on the environment; and

there are procedures to prevent accidents recurring.



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Table 5.1 Relationship of an EMS to Emission Control and Elimination Techniques Guidance, Appendix 3

Overview

An EMS is a requirement of a waste licence. The EMS should establish how the operator will implement his environmental policy with regard to the environment. This is generally expressed as:

? a commitment to meet all licence condition emission limits and other legal requirements ? prevent pollution and incidents/accidents, e.g. through appropriate preventive and corrective measures ? introduce operational controls to manage activities or aspects of operation that could have a significant

environmental impact ? establish an environmental management programme with objectives and targets set to manage significant

environmental aspects, and ? provide objective evidence of this commitment through audits and via annual reporting.

The EMS should be incorporated across all operations and as such it will assist the operator in demonstrating a main commitment to continually improve on environmental performance.

Landfill Management

At the design and construction stage, the EMS should be a factor in all stages of the landfill life cycle. Considerations should also be given to:

? Materials selection and sourcing ? Use of natural resources ? Protection of sensitive receptors - containment and management of the products of the landfill degradation

processes, e.g. landfill gas and leachate - spillage prevention and containment - protection of water resources - prevention of construction and operational noise or other nuisances to local community

The operation of the landfill must comply with the requirements of the waste licence. Objectives and Targets should be set to achieve continuous performance improvement in respect of significant environmental aspects, such as groundwater protection, water emission control systems; landfill gas utilisation.

Potential Environmental Aspects

Environmental Aspect Reference (See Appendix 3)

Spillage/ Uncontrolled emission prevention

Surface & groundwater management (See T1); Alarm systems/ emergency shut-down/ diversion; Back-up power supply/ UPS; Back-up pumps; Bunding (See T8); Landfill Liner failure detection (See T4); Spillage Control Materials; Training and Awareness; Risk Assessment; Fuel/oil storage (See T8)

Energy Landfill gas utilisation & flaring (See T7); Vehicles (See T13)

Landfill Management Leachate production collection (See T2); Leachate treatment (See T3); Landfill Lining (See T4); Landfill Capping (See T5); Landfill gas management; (See T6)

Site Management Dust/Fine Particulates (PM10) (See T9); Odour (See T10); Litter (See T11); Noise & vibration (See T12); Birds (See T14); Vermin & insects (See T15); Mud (See T16); Fires (See T17); Security (See T18)

Monitoring



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Periodic system audit of all EMS elements. Minimum of one full system audit per annum in years 1 to 3 post-implementation

Preparation of an Annual Environmental Report

6. WASTE ACCEPTANCE

It is essential for landfill operators to implement measures to ensure that only those wastes for which the facility was designed, and which are permitted by the licence, are deposited. The EPA Landfill Manuals - Waste Acceptance, provides detailed advice on waste acceptance. This document provides an outline of the requirements for waste acceptance in order to assist landfill operators in developing and operating waste acceptance procedures appropriate for their facility. Compliance with this manual is deemed to be BAT for waste acceptance.

Pre-acceptance considerations include:

6.1 Classes of Landfill

Article 4 of the Landfill Directive defines the classes of landfill as:

landfill for hazardous waste landfill for non-hazardous waste landfill for inert waste. Only wastes falling within the categories of waste permitted for that class of landfill should be accepted.

Article 6 of the Landfill Directive details the acceptance criteria for the different classes of waste and for the receiving landfill. Only hazardous waste (i.e. waste listed on the Hazardous Waste List6), that fulfils the criteria set out in Annex II of the Directive may be deposited in a hazardous waste landfill (Article 6(b)). Inert waste landfill facilities may be used only for inert waste (Article 6(d). Suitable material recovered from inert waste may be used for engineering, development and restoration purposes and may also be used for suitable operational purposes, eg. daily cover or bunding.

For non-hazardous waste (Article 6(c)) a landfill may accept:

6 The Hazardous Waste List has been combined with the European Waste Catalogue and the new combined list came into force on 1st January 2002.



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(i) municipal waste;

(ii) non-hazardous waste of any other origin, which fulfils the criteria for the acceptance of waste at a landfill for non-hazardous waste set out in accordance with Annex II;

(iii) stable, non-reactive hazardous waste (e.g. solidified, vitrified), with a leaching behaviour equivalent to that of non-hazardous waste and which fulfils the relevant acceptance criteria set out in accordance with Annex II. Note that hazardous waste must not be deposited in cells destined for biodegradable non-hazardous waste.

6.2 Prohibited Wastes

The Landfill Directive (Article 5) requires a phased reduction in the amount of biodegradable municipal waste going to landfill also prohibits landfilling of certain wastes.

The key measures are:

bans on the landfilling of:

liquids (See Appendix 7)

tyres (initially whole tyres and then shredded);

hazardous waste classified as: Explosive (H1) ( WMA 1996 Section 92) Oxidising (H2) ( WMA 1996 Section 93) Highly flammable and flammable (H3A & H3B) ( WMA 1996 S94&S95) Corrosive (H8) ( WMA 1996 Section 100) Infectious (H9) ( WMA 1996 Section 101)

dilution of waste solely to meet acceptance criteria is also prohibited.

6.3 Pre-treatment of Waste

The Landfill Directive (Article 6) requires that only waste that has been subject to treatment is landfilled. There are exceptions, which address:

inert wastes where such treatment is not technically feasible, and wastes for which treatment will not reduce the quantity of waste or the hazards to human

health or the environment. Treatment is defined in the Landfill Directive as any means of physical, thermal, chemical or biological processes, including sorting, that change the characteristics of the waste in order to reduce its volume or hazardous nature, facilitate its handling or enhance recovery.



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To ensure compliance with the Directive it is therefore essential that procedures are put in place by the operator or applicant to check that the waste delivered to the facility has been pre-treated. Waste that has not been pre-treated in accordance with the site licence should not be admitted to the site.

6.4 Waste Checking

Article 11 and Annex II of the Landfill Directive 1999/31/EC set out the nature of the controls that should be introduced for waste checking. Annex II(3) requires an acceptance procedure to be based on a three-level hierarchy. See also the EU Council Decision 2003/33/EC Establishing Criteria and Procedures for the Acceptance of Waste at Landfills. Annex II(3) of the Landfill Directive comprises:

Level I: Basic Characterisation. Using standard analytical methods, the short and long-term leaching behaviour and/or characteristic properties of waste are determined by or on behalf of the waste producer/contractor. The possible risks involved when handling waste should be identified and included in the waste transfer document.

Level II: Compliance Testing. This consists of periodical testing by standardised analysis methods, to determine whether a waste complies with licence conditions and (/or) specific reference criteria and is carried out by the landfill operator. It focuses on key characteristics identified by the initial characterisation at Level I.

Level III: On-site Verification. Checks to confirm that a waste;

a) is the same as that which has been subjected to compliance testing; and

b) is the same as that which is described in any accompanying documents that may be required.

On-site verification may consist of a visual inspection of a load of waste before and after unloading at the landfill facility. More detailed testing may be required if visual inspection does not enable the facility operator to make a conclusive verification.

The waste licence will clearly state those wastes which may be accepted at the facility and may also detail those which are not permitted (e.g. liquid, tyres etc). Conditions will limit the quantity of waste that may be accepted and will also make requirements for checking, sampling and recording of incoming waste and provisions for dealing with non-permitted wastes that are delivered. The landfill operator must ensure that only those waste types permitted by the waste licence are accepted. For non-hazardous landfills, where a particular waste is suspected as being hazardous, reference should be made to the EPA Hazardous Waste Classification Tool available at www.epa.ie/techinfo/default.htm .

Upon entry into the facility:



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? all loads should be weighed;

? the waste should be checked in the vehicle, as far as this is possible, by a competent person, and

? a record made of the waste type, quantity, source and haulier.



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7 POTENTIAL EMISSIONS AND THEIR SOURCES

Emission is defined in the Environmental Protection Agency (EPA) Act 1992, Section 3, to mean:

an emission into the atmosphere of a pollutant within the meaning of the Air Pollution Act, 1987;

a discharge of polluting matter, sewage effluent or trade effluent within the meaning of the Local Government (Water Pollution) Act, 1977, to waters or sewers within the meaning of that Act;

noise (note that the definition of noise includes vibration).

The definition of emission in the IPPC Directive (96/61/EC) includes the direct or indirect release of substances, vibrations, heat or noise from individual or diffuse sources in the installation into the air, water or land.

The underlying objectives of IPPC are to prevent pollution and achieve a high degree of environmental protection by using BAT to eliminate or reduce emissions from processes. Emissions, and hence environmental pollution, can be eliminated or reduced by:

proper design of the facility (Section 4); effective management of the facility (Section 5); and the selection of appropriate processes, technologies and facility operations (Appendix 3). The potential emissions to the environment from a landfill facility and their sources have been identified in Emissions Inventory Guidance tables (Appendix 2), under the following headings:

Air Water Land Noise & vibration Heat

The guidance tables identify the class of landfill (hazardous, non-hazardous or inert) that the emissions may arise at. The applicant needs to consider which emissions are likely to arise from the facility being developed.


Environmental Protection Agency 40 Draft April 2003

8. MONITORING

8.1 Monitoring Guidance

It is essential that the activity and behaviour of a landfill (i.e. its decomposition and settlement rates) be monitored to an agreed programme throughout the entire life of the facility. These requirements and activities are described in the EPA Landfill Manuals Landfill Monitoring (currently under review and due for re-publication in 2003) and outlined in the BAT Emission Control Guidance in Appendix 3. They include details of monitoring parameters, monitoring frequency, monitoring location etc.

Monitoring scope for landfill may include:

Requirement Examples of Monitoring Parameters (refer to the EPA Landfill Manuals Landfill Monitoring for detailed lists)

Surface Water Chemical parameters; temperature; dissolved oxygen; chemical oxygen demand; ammoniacal nitrogen Biological parameters: aquatic invertebrate populations; aquatic toxicity test

Groundwater Levels See surface water examples Landfill Gas Methane; CO2; O2; atmospheric pressure; temperature (inside

and outside of the site) Point Source Emissions to Air

CO, NOx;SO2

Landfill Leachate Levels See surface water examples Meteorological Data Temperature; humidity; rainfall; atmospheric pressure Noise Noise levels at selected locations Odour Analysis of air samples; olfactory measures Dust Analysis of air samples Flora and Fauna Ecological surveys Landfill Stability and Settlement

Engineer inspections; void space; settlement levels



9 CLOSURE AND AFTERCARE

9.1 Purpose

The Landfill Directive (Article 10) requires operators to ensure there is sufficient financial provision to cover the cost of closure and aftercare for a period of at least 30 years. Details of these activities are provided in the EPA Landfill Manuals Landfill Restoration and Aftercare.

9.2 Cessation of Waste Disposal

The cessation of waste acceptance at a landfill facility initiates a review of the waste licence. This review allows the licence to be amended to reflect the change in activities on site as the facility moves from the operational stage to the restoration and aftercare stage. Licence amendments will reflect the Agencys assessment of the licensees requirements to ensure that the site continues to be properly managed.

9.3 Restoration and Aftercare

Restoration is a process that will return a site to a condition suitable for the selected afteruse. Restoration includes soil spreading, final landform construction, landscaping works and aftercare.

Aftercare involves any measures that are necessary to be taken in relation to the facility for the purposes of preventing environmental pollution following the cessation of landfill activities at the facility and the capping and restoration of the site. The length of this aftercare period will vary from site to site and the licence holder remains responsible for the aftercare until the Agency accepts the surrender of the waste licence (Waste Management Act, 1996, S48).

9.4 Maintenance of Environmental Pollution Control Systems

Until the EPA accepts surrender of the licence, the licence holder/operator is responsible for environmental protection of the site. During aftercare the licence holder/operator must ensure that the following pollution control systems are maintained and remain effective:

the landfill gas control system;

the leachate collection, treatment and disposal system;

the landfill cap;



groundwater monitoring boreholes; and

all above ground components such as gas wellheads, leachate pumping manholes and monitoring boreholes.



APPENDIX 1 PRESCRIBED LANDFILL ACTIVITIES

Waste Management Act 1996: Schedule 3 and 4 Classes covered by this Guidance Note

3rd Schedule

1 Deposit on, in or under land including landfill.

2. Land treatment, including biodegradation of liquid or sludge discards in soils.

3. Deep injection of the soil, including injection of pumpable discards into wells, salt domes or naturally occurring repositories.

4. Surface impoundment, including placement of liquid or sludge discards into pits, ponds or lagoons.

5. Specially engineered landfill, including placement into lined discrete cells that are capped and isolated from one another and the environment.

6. Biological treatment not referred to elsewhere in this Schedule which results in final compounds or mixtures which are disposed of by means of any activity referred to in this Schedule.1

7. Physico-chemical treatment not referred to elsewhere in this Schedule which results in final compounds or mixtures which are disposed

epa (usa) - bat landfill activities (abril 2003)

Documents