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Page 1: SECTION 3 MANAGEMENT AND DISPOSAL OF CLASSIFIED … · 4. Disposing waste ( if the first three are not possible ) Source: EPA 1 AVOID 2 RE-USE 3 RECYCLE / REPROCESS 4 DISPOSE 1.2
Page 2: SECTION 3 MANAGEMENT AND DISPOSAL OF CLASSIFIED … · 4. Disposing waste ( if the first three are not possible ) Source: EPA 1 AVOID 2 RE-USE 3 RECYCLE / REPROCESS 4 DISPOSE 1.2

This document is an addendum to the current EPA guidelines Environmental Guidelines: SolidWaste Landfills (1996) and is being released for community consultation.

Published by:

Environment Protection Authority59-61 Goulburn Street, SydneyPO Box A290Sydney South 1232Phone: (02) 9995 5000 (switchboard)Phone: 131 555 (publications & information requests)Fax: (02) 9995 5999TTY: (02) 9211 4723Email: [email protected]: www.epa.nsw.gov.au

The EPA is pleased to allow this material to be reproduced in whole or in part, provided themeaning is unchanged and its source, publisher and authorship are acknowledged.

ISBN 0 7313 0161 7EPA 98/36

April 1998

Printed on recycled paper

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CONTENTS

SECTION 1 INTRODUCTION 1

1.1 Background 1

1.2 Introduction 1

1.3 Purpose of this Document 2

SECTION 2 THE LICENSING SCHEME 2

2.1 Which Landfills Need a Licence? 2

2.2 Performance Reporting for Licensed Landfills 2

SECTION 3 MANAGEMENT AND DISPOSAL OF CLASSIFIED WASTE 3

3.1 Disposal of Classified Wastes 33.1.1 Classification of landfills 33.1.2 Types of landfill containment for industrial wastes 4

SECTION 4 MANAGEMENT OF INDUSTRIAL WASTE LANDFILLING 4

4.1 Environmental Issues and Goals in Landfilling 5

4.2 Landfill Environmental Management Plans 5

4.3 Benchmark Techniques for Industrial Waste Landfilling 7

4.4 Using the Appendixes to the Landfill Guidelines 8

TECHNICAL APPENDIX 1 BENCHMARK TECHNIQUES FOR INDUSTRIAL WASTELANDFILLING 9

1A. LEACHATE BARRIER SYSTEM 10

2A. LEACHATE MANAGEMENT SYSTEM 11

4A. GROUNDWATER MONITORING NETWORK 13

8A. LEACHATE MONITORING PROGRAM 14

10A. LANDFILL GAS CONTAINMENT SYSTEM 15

14A. SITE CLOSURE 16

21A. SCREENING OF WASTES RECEIVED 16

22A. MEASUREMENT OF QUANTITIES OF WASTES RECEIVED 17

23A. RECORDING OF THE QUANTITIES, TYPES AND SOURCES OF WASTES RECEIVED 18

24A. COMPACTION OF WASTE 18

28A. SITE CAPPING AND REVEGETATION 18

30A. SECURITY OF SITE 19

TECHNICAL APPENDIX 2 COVERING STATEMENT 21

DEFINITIONS AND GLOSSARY 23

BIBLIOGRAPHY 26

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Draft Environmental Management of Industrial Waste Landfilling– 1 –

SECTION 1INTRODUCTION

1.1 Background

The Waste Minimisation and Management Act1995 introduces a State-wide scheme forlicensing waste activities. According to thisscheme, wastes posing the most significantthreat to the environment need a licence, andthe purpose of the licence is to ensure thatappropriate controls apply to the handling,storage, treatment and disposal of the waste.There must also be a clear public record ofwhat wastes are going where. Sometimes thisis needed even where a licence is notrequired so that the community can beconfident that our wastes are well managed,and so that there is a way of tracing illegallydumped waste.

The Waste Minimisation and ManagementRegulation 1996 (the Regulation) details theState-wide licensing and reporting scheme.

The waste regulations are only a small part ofa much larger scheme. They essentially dealwith ensuring responsible environmentalmanagement of wastes that we cannot avoid,and create opportunities for promoting re-use or reprocessing of these wastes throughappropriate incentives and disincentives.

Key parts of the Government’s waste reformpackage include:

• a 60% target for reducing waste going todisposal by 2000

• a waste management hierarchy (depictedopposite) within which waste avoidanceis a priority, followed by re-use andrecycling/reprocessing, with disposal asa last resort

• industry waste reduction plans to ensurethat nominated industries make tangibleand effective waste reductioncommitments

• establishment of Regional Waste Boardsto initiate comprehensive wastemanagement plans on a workable level

• a Waste Planning and Management Fundfor which the Government hasguaranteed funding support for wastereduction initiatives, with a priority forfunding regional waste boards

• development of comprehensive plans ofaction for key waste streams (such asgreen waste and building and demolitionwaste)

• ongoing State-wide communityeducation targeting waste avoidance andreduction options.

MAXIMUM CONSERVATION OF RESOURCES

THE WASTE MANAGEMENT HIERARCHY

1. Avoiding waste 2. Re-using materials 3. Recycling and reprocessing materials 4. Disposing waste ( if the first three are not possible )

Source: EPA

1AVOID

2RE-USE

3RECYCLE / REPROCESS

4DISPOSE

1.2 Introduction

The assessment and classification of wastefor landfill disposal is addressed in theEnvironmental Guidelines: Assessment,Classification and Management of Non-LiquidWastes 1997 (Waste Guidelines). In shortNSW classifies wastes as inert, solid, industrialor hazardous.

In 1996, the EPA published guidelines forsolid waste landfills, entitled EnvironmentalGuidelines: Solid Waste Landfills (LandfillGuidelines).

The Landfill Guidelines outline theenvironmental performance requirementsand provide benchmark techniques for theoperation of solid waste landfills. TheGuidelines did not cover hazardous orindustrial wastes, which need to be manageddifferently.

Industrial waste is a type of waste that can bedisposed of to landfill because it contains

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Draft Environmental Management of Industrial Waste Landfilling– 2 –

only slightly higher levels (up to 4 timeshigher) of chemical contaminants than wastethat is permitted to be disposed of toordinary solid (municipal) waste landfills (class1 and class 2).

Hazardous waste is a type of waste that mustbe treated before it would be suitable fordisposal to landfill or which needs to be storeduntil a suitable treatment technologybecomes commercially available.

1.3 Purpose of this Document

This document is a companion document tothe Environmental Guidelines: Solid WasteLandfills and must be read in conjunctionwith it. Reference must also be made to theEnvironmental Guidelines: Assessment,Classification and Management of Non-LiquidWastes when reading this document.

Landfills receiving waste assessed asindustrial waste must be capable of securelycontaining them. The environmentalperformance requirements for industrial wastelandfilling are therefore more stringent thanthose for other landfilling.

This draft addendum to the LandfillGuidelines sets out the additionalmanagement requirements for industrialwaste landfilling. It provides specialrequirements in addition to those of theLandfill Guidelines to ensure that landfillsreceiving industrial waste are designed,operated and managed in anenvironmentally sustainable way.

SECTION 2THE LICENSING SCHEME

2.1 Which Landfills Need aLicence?

Clause 5 of the Waste Regulation sets outwhich landfill sites require a licence. Alllandfills receiving industrial waste will requirea licence irrespective of the quantities ofwaste they receive or their location.

2.2 Performance Reporting forLicensed Landfills

The performance reporting requirements forindustrial waste landfills include:

• Incident reports concerning any situationor incident that represents a threat to theenvironment and that may lead to abreach of licence conditions

• Monthly or quarterly reports to besubmitted to the EPA:

- Landfill occupiers who are required topay contributions under section 72 of theAct must provide data to the EPA eachmonth on the amount, type and sourceof all waste received. Official reportingforms must be used and these may beobtained from the EPA.

- Occupiers who are not required to paycontributions will be required to providesuch information on a quarterly basis.

• Annual report to be submitted to theEPA in support of the annual licencerenewal application. This reportshould/must include:

- a summary report of the total wastereceived during the past 12 months,its composition, and its eventual fate

- the volume of landfill spaceconsumed

- an estimate of remaining landfillcapacity and life

- a hydrogeological section thatassesses the groundwatermonitoring results and discussesany significant changes detected inthe groundwater quality

- a section which reviews leachatecollection and treatment

- a section assessing landfill gasemissions, if gas generation isoccurring

- a section summarising records ofodour, litter or other complaints

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Draft Environmental Management of Industrial Waste Landfilling– 3 –

received by the facility and comments

- a summary and interpretation ofsurface water monitoring results

- a summary and interpretation of alldust monitoring results

- a summary of any incidents

- any other specific informationrequested by the EPA.

These requirements also apply to inert andsolid waste landfills. Readers should refer toSection 3.4 of the Landfill Guidelines.

SECTION 3MANAGEMENT ANDDISPOSAL OFCLASSIFIED WASTEAfter waste is disposed of to land, it canundergo physical, chemical or biologicalchanges (called environmentally significanttransformations in this document). This mayhave the following undesirableconsequences:

(i) the release of greenhouse gases suchas methane and carbon dioxide andother toxic gases

(ii) the release of nutrient rich liquid(leachate) that if allowed tocontaminate groundwater or surfacewaters may result in the formation ofenvironmentally harmful algalblooms

(iii) the release of liquids (leachates)containing chemical contaminantssuch as heavy metals and human-made chemicals, that if allowed tocontaminate soil, groundwater orsurface waters can result inundesirable effects on the health ofhumans, animals, plants or otherliving organisms.

Waste is classified in the following order,ranging from the least harmful to the mostharmful to the environment:

• Inert waste is the least likely to undergoenvironmentally significant transformationsand, therefore, should not releasesignificant quantities of greenhousegases or leachates contaminated withnutrients and/or chemicals

• Solid waste can include putrescible waste,is likely to release higher quantities ofthe contaminants listed under (i) to (iii)above than inert waste and consequentlyneeds to be managed with greater care

• Industrial waste contains somewhathigher (up to four times) levels of thecontaminants listed under (iii) abovethan solid waste and needs to be managedwith more stringent environmentalcontrols than solid waste.

• Hazardous waste contains contaminantslisted under (iii) above at levels highenough to require treatment to renderthem safe before disposal.

3.1 Disposal of Classified Wastes

3.1.1 Classification of landfills

All licensed landfill facilities will be in one ofthe six classes or subclasses as follows:

Inert: Class 2

Class 1

Solid: Class 2

Class 1

Industrial

Hazardous

Each class or subclass will have licenceconditions setting out which wastes may ormay not be received.

Occupiers of existing landfills proposing toaccept industrial waste should also review anydevelopment approval conditions applyingto the site to determine whether there is aneed to seek a variation of the conditions toenable receipt of this waste.

In general the licence conditions for industrialwaste landfills, cells, monocells and monofills

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Draft Environmental Management of Industrial Waste Landfilling– 4 –

will not permit the disposal of putresciblewastes in them in order:

• to avoid undesirable chemical reactionsand physical interactions either directlywith putrescible wastes or leachategenerated by the contact of water withthem,

• to keep the quantity of leachate generatedas low as possible since the treatment ofsuch leachate is costly,

• to keep the amount of landfill gasgenerated as low as possible sincereleases of landfill gas may purge themore volatile chemical contaminantspresent in industrial waste into theatmosphere,

• to enable the precise position in thelandfill of different types of industrialwaste to be recorded in case it is desired ata later date to recover such wastes forreprocessing, and

• to avoid using up capacity in these morehighly engineered and more carefullymanaged landfills for the landfilling ofputrescible wastes which may bedisposed of in landfills with lowerconstruction and management costs.

3.1.2 Types of landfill containment forindustrial wastes

The management of industrial waste offersopportunities for the use of monofills andmonocells for disposal. These are specialtypes of landfill design which are suitable forthe disposal of special waste types whichrequire to be kept separate from other typesof waste to avoid undesirable chemicalreactions and physical interactions eitherdirectly with other types of waste or leachategenerated by contact of water with them.Their design will need to specially cater forthe properties of the particular type of wastewhich is being placed into them.

Wastes classified as industrial waste cantherefore be disposed of to landfills or partlandfills as follows:

1. An industrial waste landfill - a landfilldedicated to the disposal of all wastetypes classified as industrial waste.

2. An industrial waste cell - could belocated at a solid waste landfill and must beisolated from the rest of the landfill bymeans of a leachate/gas barrier of lowpermeability. Such a cell may be suitablefor the disposal of more than one wastetype classified as industrial waste. Such acell must be at an edge of the landfill andmay not have other types of waste eitherabove or below it.

3. An industrial waste monocell - a part ofa cell at an industrial or a solid wastelandfill which is isolated from the rest ofthe cell by means of a leachate/gasbarrier of low permeability for thedisposal of one specific industrial wastetype. A monocell, one side of which mustbe at an edge of the landfill cell, may nothave other types of waste either above orbelow it.

4. An industrial waste monofill - anisolated landfill unit for disposal of onespecific industrial waste type.

Industrial waste landfills, cells, monocellsand monofills are usually designed as doublelined landfills with a separate leachatemanagement system for each liner in order toafford additional protection from potentialcontamination to the surroundingenvironment (see Section 4.3).

SECTION 4MANAGEMENT OFINDUSTRIAL WASTELANDFILLINGThe Landfill Guidelines adopt aperformance-based approach to themanagement and regulation of landfills. Itdefines the Environmental Goals to beachieved for the environmentally safedisposal of non-liquid waste. These samegoals apply to industrial waste landfilling inthis addendum.

There are five principal environmentalmanagement techniques for landfills whichmust be considered and adopted as

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Draft Environmental Management of Industrial Waste Landfilling– 5 –

applicable, in order to achieve the desirableEnvironmental Goals:

Site selection - an appropriate location willhave natural barriers and buffer distances tohelp reduce environmental risk.

Design and construction - including allengineering and environmental aspects of thedesign and construction of the landfill andassociated infrastructure.

Monitoring - including all environmentalmonitoring and reporting of air, water, noiseand waste.

Site operations management - including alloperational procedures, quality assurancescheme and site control measures requiredfor managing a landfill in anenvironmentally acceptable manner.

Remediation and post closure management- including the provision of environmentalcontrols needed to keep the impact of closedlandfills to a minimum and ensure thebeneficial use of landfill sites after closure.

Environment protection is achieved througha combination of good planning and anintegrated and thorough approach to thedesign, operation and management of thewaste facility. Landfill applicants oroccupiers need to place strong emphasis onthese issues throughout the entiredevelopment.

There is no substitute for selecting anenvironmentally sound site, nor the adoptionof effective environmental management andcontrol measures to protect the integrity ofthe landfill environment.

The EIS Practice Guideline: Landfilling 1996developed by the Department of UrbanAffairs and Planning (DUAP) is thecompanion guideline to the LandfillGuidelines and this addendum. Thisdocument provides advice about thedevelopment of landfills, including siteselection and environmental assessment ofnew landfill proposals.

4.1 Environmental Issues andGoals in Landfilling

The environmental issues and goals inlandfilling described in the LandfillGuidelines are also applicable to industrialwaste landfilling. These environmental goals,which may be found in Section 2 of theLandfill Guidelines, are summarised below:

2.1 Water Pollution

2.1.1 Preventing pollution of water byleachate

2.1.2 Detecting water pollution

2.1.3 Remediating water pollution

2.2 Air Pollution

2.2.1 Preventing landfill gas emissions

2.2.2 Detecting landfill gas emissions

2.2.3 Remediating landfill gas emissions

2.3 Land Management and Conservation

2.3.1 Assuring quality of design,construction and operation

2.3.2 Assuring quality of incoming waste

2.3.3 Recording of wastes received

2.3.4 Minimising landfill space used

2.3.5 Maximisation of recycling

2.3.6 Remediating landfill after closure

2.4 Hazards and Loss of Amenity

2.4.1 Preventing unauthorised entry

2.4.2 Preventing degradation of localamenity

2.4.3 Preventing noise pollution

2.4.4 Adequate fire-fighting capacity

2.4.5 Adequate staffing and training

4.2 Landfill EnvironmentalManagement Plans

A Landfill Environmental Management Plan(LEMP) relates to the operation of an existingor a proposed landfill. Under the WasteMinimisation and Management Act 1995, theEPA may require the landfill licence

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Draft Environmental Management of Industrial Waste Landfilling– 6 –

applicant to submit a LEMP. All newindustrial waste landfill and monofill licenceapplications will need to be accompanied bya LEMP.

If a LEMP being prepared for a solid wastelandfill proposes the construction of anindustrial waste cell or monocell, it would needto contain a special section that specificallydeals with the Environmental Managementof this cell or monocell and the handling ofindustrial wastes. In the case of an existingLEMP an Annex would need to be addedwhich covers the same issues. The EPAwould then insert additional conditions,which are appropriate for the landfilling ofindustrial wastes, into the solid waste landfill’slicence.

A LEMP outlines a robust regime ofenvironmental management, based on thelocation of the landfill and the types andquantities of waste received.

The LEMP is expected to demonstrate howthe landfill occupier will satisfy the outcomesspecified in the Landfill Guidelines and thisAddendum (and subsequently the conditionsof the licence) by proposing an integratedenvironmental management planappropriate for the proposed site fromcommencement of operations.

Section 3.3.1 of the Landfill Guidelinesincludes guidelines for the preparation of aLEMP. Landfill occupiers preparing LEMPsfor industrial waste landfilling should refer tothe Landfill Guidelines, however, insummary, the LEMP must systematicallycover the following points:

Site overview - covering the broad locationaland environmental characteristics of the site.

Landfill structure and operations overview -outlining the landfill design and constructionconcepts, engineering specifications andstandards, general operating philosophy, andthe nature and quantity of wastes to bereceived, recycling activities to be conducted,the intended life of the landfill and projectedfinancial guarantees over the life of thelandfill.

Discharges of pollutants to waters -describing in detail mechanisms and controlmeasures in place or to be adopted for

preventing contamination of groundwaterand surface water, to meet the EnvironmentalGoals described in section 4.1 of thisaddendum.

Emission of pollutants to the atmosphere -describing in detail mechanisms and controlmeasures in place or to be adopted forcontrolling emissions, to meet theEnvironmental Goals described in section 4.1of this addendum

Land management and conservation -describing in detail the measures to beadopted to help meet waste reduction goals,the degree of quality control over wastetaken into the site, and the proposedapproach to site closure and remediation tomeet the Environmental Goals described insection 4.1 of this addendum

Prevention of hazard and loss of amenity -identifying mechanisms for managing dust,birds, litter, noise, pests, vermin, odour,traffic and fire to meet the EnvironmentalGoals described in section 4.1 of thisaddendum.

Each LEMP must be accompanied by acovering statement that will be used by theEPA to streamline the licensing of landfills,and to develop, where appropriate, what theEPA refers to as ‘non-standard’ licenceconditions.

The covering statement must outlineproposed alternative landfill managementtechniques and other information as detailedin Technical Appendix 2 of this addendum.Alternative techniques that are identified inthe covering statement must be fullydocumented in the LEMP, with the occupierdemonstrating that the proposed departurefrom the benchmark technique, ifimplemented, will not pose an increased riskto environment.

After the EPA processes the CoveringStatement and LEMP a licence may be issuedwith conditions derived as follows:

• where the landfill occupier does nothighlight alternative techniques in thecovering statement, the applicable‘standard licence conditions’ reflectingthe benchmark technique will beattached, and

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Draft Environmental Management of Industrial Waste Landfilling– 7 –

• where the landfill occupier highlights theuse of alternative techniques in thecovering statement, the EPA will developnon-standard licence conditions derivedfrom the LEMP. (The use of alterativetechniques must be appropriatelydemonstrated as detailed in Section 4.3.)

The EPA’s licensing of landfills will beconsistent with the performance basedapproach, which is promoted in the LandfillGuidelines.

4.3 Benchmark Techniques forIndustrial Waste Landfilling

The main changes from the solid wastelandfills benchmark techniques are:

• leachate barrier system: double liner andleachate management system,

• leachate management: more robustdesigns and management techniques,

• groundwater monitoring: more frequentmonitoring of groundwater and theaddition of continuous conductivitymonitoring to serve as an early warning ofa pollution incident,

• leachate monitoring: more frequentmonitoring and procedures to use if thereare signs of changes in leachatecharacteristics in the outer liner due toleakage from the inner liner,

• screening of wastes received: stricterprocedures than for solid wastes,

• recording of wastes received: includes aprovision to use a grid system to describethe location of each load of wastereceived,

• site capping and revegetation: thechanges to the capping include acomposite liner system and a middledrainage layer,

• security of site: a surveillance camera atthe entrance of the site is recommended.

Industrial waste landfills, cells, monocellsand monofills are usually designed as doublelined landfills with a separate leachatemanagement system for each liner in order to

afford additional protection from potentialcontamination to the surroundingenvironment. This will ensure that if theintegrity of the inner liner (which providesthe almost impermeable barrier required forthe containment of industrial waste) iscompromised, the leachate cannot escapeinto the environment, and is caught in theouter leachate collection system which isisolated from the substratum by the outerimpermeable liner.

A change in the characteristics of the leachatein the outer system will give an earlywarning of any problems with the inner linerand trigger action to remedy the situation(see Benchmark Techniques 1A and 2A inTechnical Appendix 1).

Table A1 in Technical Appendix 1 of thisaddendum lists the benchmark techniquesthat could be applied to the landfilling ofindustrial waste. The EPA will use thesebenchmark techniques as a point of referencewhen reviewing LEMPs and licenceapplications.

The benchmark techniques are applicable toall industrial waste landfilling unless the EPAis satisfied that the proposed alternativeenvironmental protection techniques provideenvironmental performance at least equal tothose of the benchmark techniques and willenable the occupier to meet the particularenvironmental goal(s). This performancemust be able to be demonstrated to the EPA.

Where alternative benchmark techniques areproposed, the applicant will need to providedocumentation that does either one of thefollowing:

1. Identifies the extent to which the system isused successfully elsewhere and certifiesthat:

- the field/operating conditions of thereference site and proposed site arecomparable

- the system has been operating longenough with sufficient data beinggenerated to be sure of the possibleconsequences and environmentaloutcomes

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Draft Environmental Management of Industrial Waste Landfilling– 8 –

- the prospective occupier can duplicatethe system

- it can be demonstrated why the systemwill works effectively at the proposedsite

- there is no countervailing evidence, and

- the proposal is compatible with otheraspects of the proposed landfilloperation.

OR

2. Demonstrates the soundness of theproposal in field tests/trials or withappropriate supporting laboratory testdata and:

- the test conditions simulate the properoperating conditions

- it is demonstrated why the system willwork effectively at the proposed site

- there is little or no countervailingevidence

- the EPA can, if need be, replicate thetest results produced by the applicant,and

- the proposal is compatible with otheraspects of the proposed landfilloperation.

If the EPA considers that the proposeddepartures from the benchmark techniquesrepresent an increased risk of harm to theenvironment, it may require the applicant toprovide a risk assessment.

The risk assessment will need to follow aprofessional and recognised ecological,health or operational hazard risk assessmenttechnique. The assessment shouldsystematically analyse site conditions,contaminant sources, exposure pathways,and receptor characteristics related to theproposed or established site in order toestimate the risks to the natural environment.

The risk assessment should be conducted bya competent risk assessor and demonstratethat the alternative technique(s) will achievethe Environmental Goal(s) and provide atleast equivalent environmental performanceto the combination of benchmark techniquesin the Landfill Guidelines and this

Addendum. The uncertainty in thisassessment should be characterised, and theperson performing this analysis must presenta clear and explicit explanation of theirfindings.

4.4 Using the Appendixes to theLandfill Guidelines

In preparing an LEMP it will be necessary torefer to both Appendix A of theEnvironmental Guidelines: Solid Waste Landfills(Landfill Guidelines) and TechnicalAppendix 1 of this addendum. Table A1 ofTechnical Appendix 1 indicates those areaswhere there is a need to use the benchmarktechniques provided in this documentinstead of those in the Landfill Guidelines toensure the safe disposal of industrial wastes.

It should also be noted that:

• With the exception of those benchmarktechniques redesigned in this addendum,reference should be made to all otherbenchmark techniques in Appendix A ofthe Landfill Guidelines.

• The definition of hazardous waste asprovided in Appendix B of the LandfillGuidelines has been superseded by thatin the Waste Guidelines.

• Appendix C of the Landfill Guidelines,regarding groundwater monitoring,assessment and remediation is alsoapplicable to industrial waste landfilling.

• Appendix D of the Landfill Guidelinesshows a reporting form that has nowbeen replaced. Current forms areavailable at EPA offices.

• Appendix E of the Landfill Guidelines isnot relevant for landfills receivingindustrial wastes, since all such landfills arerequired to be licensed irrespective of theirlocation.

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Draft Environmental Management of Industrial Waste Landfilling– 9 –

TECHNICAL APPENDIX 1BENCHMARKTECHNIQUES FORINDUSTRIAL WASTELANDFILLINGThese benchmark techniques provideguidance on possible means for achieving theenvironmental goals for landfilling.

Table A1 identifies those areas where thebenchmark techniques provided in thisdocument to be considered by occupiers oroperators of facilities to receive industrialwaste differ from those that apply to inert andsolid waste landfills. Each benchmarktechnique targets a primary EnvironmentalGoal and a set of related goals.

There is no impediment to rejecting sometechniques in relation to a given facility. Theoccupier should select those techniques thatare applicable to meeting the goals, identifythose that are not, and should justify theomissions or alternatives put forward.

The selection of the mix of techniques formeeting the Environmental Goals in relationto any given site should be considered in thelight of four key points:

• The best environmental result will beachieved via ‘up front’ decisions on the

location of a facility, and the types ofwastes to be received.

• A combination of design andconstruction, operations management,monitoring, remediation and post-closuremanagement measures will generally berequired to deal with the range ofpotential environmental impacts posedby industrial waste.

• The specific techniques outlined in thisTechnical Appendix and Appendix A ofthe Landfill Guidelines form part of anintegrated environment protectionsystem. Hence a change in one of thetechniques could adversely affect otherrelated Environmental Goals. If occupierswish to adopt an alternative technique orto substantially vary a benchmarktechnique, they will be expected to clearlydemonstrate the ability of the alternativemethod to meet both the primary andrelated Environmental Goals under theconditions applying at their site.

• The EPA’s concern will be to ensure thatif there is a move away from thebenchmark technique, there should be noreduction in certainty with regard to theprotection of the environment. The use ofalternative techniques may necessitateother requirements such as additionalmonitoring or higher financialassurances.

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TABLE A1:SPECIAL BENCHMARK TECHNIQUESPROVIDED IN THIS TECHNICAL APPENDIXFOR THE LANDFILLING OF INDUSTRIALWASTE

(Other benchmark techniques to be used arethose provided in theEnvironmental Guidelines: Solid WasteLandfills)

Benchmark Technique

1A. Leachate barrier system

2A. Leachate management system

4A. Groundwater monitoring network

8A. Leachate monitoring program

10A. Landfill gas containment system

14A. Site closure

21A. Screening of wastes received

22A. Measurement of quantities of wastesreceived

23A. Recording of the quantities, types andsources of wastes received

24A. Compaction of waste

28A. Site capping and revegetation

30A. Security of site

1A. LEACHATE BARRIERSYSTEM

Primary Environmental Goal

2.1.1 Preventing pollution of water byleachate

Related Environmental Goals

2.1.2 Detecting water pollution2.1.3 Remediating water pollution2.2.1 Preventing landfill gas emissions2.3.1 Assuring quality of design, constructionand operation2.3.6 Remediating landfill after closure2.4.2 Preventing degradation of local amenity

Not all waste will break down or transforminto relatively stable and immobilecompounds. Until the waste is stable, thechemical contaminants buried in the landfillwill have the potential to generate significantquantities of environmentally harmfulleachate and may pose a threat to the nearbyenvironment.

The leachate barrier system should beproperly designed to provide totalcontainment and flow control of leachateover the entire life of the landfill, beyond theclosure of the landfill until the waste hasceased to pose potential environmentalthreats.

Because of the long life span required of suchengineered facilities, the leachate barriersystem should be designed, constructed andoperated in accordance with the qualityrequirements specified in an approvedDesign, Construction and ManagementQuality Assurance Program.

The benchmark technique for a leachatebarrier system for landfills receivingindustrial waste is the provision of anengineered liner system that forms animpervious barrier between thesoil/groundwater/substrata and the waste.Characteristics of a suitable liner systeminclude the following points.

There should be a combination of a flexiblemembrane liner (FML) of a minimumthickness 1.5 millimetres with a permeabilityto water of less than 10-14 ms-1 and a fibre-reinforced geosynthetic clay liner (GCL) of apermeability to water of less than 10-11 ms-1,laid over a foundation layer of recompactedclay or modified soil of at least 90 centimetresin true thickness and with an in-situpermeability to water of less than 10-9 ms-1.

The FML and GCL should have materialcomposition and properties that will ensurethat they maintain the specified performancecriteria until the waste has ceased to behazardous in nature. All liners should haveappropriate shear and/or tensile strengthsappropriate to the specific site conditions.The landfill occupier should ensure thatguarantees for the liner materials areprovided by the supplier.

The FML and GCL should be laid followingspecific working procedures, including anapproved construction quality assuranceprogram. All joins and repairs should befully tested to ensure liner integrity is notbreached at these locations. The FML andGCL should be bedded in layers of soil withlow abrasive properties or synthetic non-woven geotextile able to protect the liners

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against construction and other load-induceddamage, such as puncturing or tearing.

The construction and compaction of therecompacted clay or modified soil should bedone in layers, each of a maximum thicknessof 30 centimetres. Each successive lift shouldbe of the same material, and the surface ofeach underlying layer should be scoured toprevent extreme permeability due tolaminations between layers. Duringcompaction all slopes should have a gradientnot exceeding one vertical to threehorizontal, in order to achieve suitablecompaction.

Where the natural soil material of the site isproposed to be included in leachate barriersystem design, an extensive geotechnicalinvestigation is to be conducted by acompetent independent entity to prove theefficacy of the barrier system to be adopted.This assessment should include, but not belimited to, the following:

• the area covered by and the depth of thenatural soil material

• the permeability of the natural soilmaterial to leachate and gas, at any depthup to at least 10 metres beneath thelandfill

• the integrity of the natural soil material,and the presence of any imperfectionsthat may compromise its effectiveness(e.g. root holes, weak zones, or gravellayers)

• any possible chemical reactions betweenthe natural soil material and the leachate

• the specification and integrity of otherliner materials to be used, and

• the specification and integrity of othermaterials used in the construction of theliner system.

The surface of the liner should be formed sothat once settling has finished, the uppersurface of the liner must exhibit a transversegradient of greater than three per cent and alongitudinal gradient of greater than two percent.

Surface gradients should be designed andmaintained so that ponding will not occur atany location.

2A. LEACHATE MANAGEMENTSYSTEM

Primary Environmental Goal

2.1.1 Preventing pollution of water byleachate

Related Environmental Goals

2.1.2 Detecting water pollution2.1.3 Remediating water pollution2.2.1 Preventing landfill gas emissions2.3.1 Assuring quality of design, constructionand operation2.3.6 Remediating landfill after closure2.4.2 Preventing degradation of local amenity

Treatment of leachate from industrial wastecan be costly and complicated. Therefore,every effort should be made to reduce theamount of leachate that is generated.

All leachate from industrial waste should becollected via engineered leachate collectionand conveyance systems (LCCS) andprevented from escaping from the landfillinto the nearby environment, e.g.groundwater, surface water or subsoil.

The leachate collected can either be:

• treated by an on-site treatment plant, or

• transported to a licensed liquid wastetreatment facility for treatment.

Because the majority of contaminantspresent in industrial waste are not readilybiodegradable, especially under theconditions that exist in industrial wastelandfilling, leachate should not as a generalrule be recirculated into the landfill.

Leachate Collection and Conveyance Systems(LCCS) and any on-site leachate treatmentplants:

• must be kept operational for a period atleast up to the end of the post-closurecare period of the landfill,

• be chemically resistant to the chemicals insolution,

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• be able to be readily cleaned andmaintained, and

• be designed and installed in accordancewith the quality requirements specified inan approved Design and ConstructionQuality Assurance Program.

Acceptable designs include the following:

Leachate Collection and ConveyanceSystem

Double lined industrial waste landfills, cells,monocells or monofills should have bothprimary and secondary LCCS. The primaryLCCS lies over the upper liner, and thesecondary LCCS is situated between the FMLand GCL. The purpose of the secondaryLCCS is to detect and collect any leachatethat infiltrates through the upper liner.

The primary and secondary LCCS shouldconsist of a drainage layer at least 30centimetres thick and be designed to preventthe build-up of more than a 300 millimetreshead of leachate at any location in the liner.The design of such a system should havesufficient redundancy to cope with anylocalised reduction in permeability. Theprimary LCCS should exhibit a permeabilityof K > 10-4 ms-1, and the secondary LCCS apermeability of K > 10-2 ms-1.

The drainage media should be selected tocreate a sufficiently large void space to drainthe leachate effectively and efficiently, and toprevent encrustation during the operatinglife of the landfill. Gravel of suitable gradesor a combination of such gravel and a geonetmay be used. The gravel selected should be:

• rounded

• of nominal size greater than 20millimetres

• smooth-surfaced

• robust and non-reactive in mildly acidicconditions

• relatively uniform in grain size

• free of carbonates that could formencrustations around the collector pipes,and

• covered with a non-woven filter fabric.

Geotextiles should not be used where theirlow porosity coupled with consequentencrustation could result in blockage of theleachate drainage system.

Perforated collector pipes should be placedwithin each drainage layer at intervals of notmore than 50 metres to facilitate theconveyance under gravity, collection andtransfer of leachate. These pipes shouldgenerally:

• have a minimum diameter of 150millimetres

• be strong enough to support the wasteand not to collapse or deform under suchforces

• have a minimum longitudinal gradient oftwo per cent, and

• be laid out in a manner to permit cleaningand monitoring.

In order to facilitate the movement ofleachate and prevent the creation of perchedwater tables, the occupier should puncture orremove previously applied daily orintermediate cover prior to further filling, ina way that prevents the formation of perchedwater tables.

Leachate should be collected and stored ineither a dam that is lined to a similarstandard to the landfill liner, or in above-ground tanks surrounded by a bund with acapacity of 110% or greater than the tankswithin the bund. The dam or tanks shouldhave high level alarms that are interlocked tothe discharge pump or line, so that theycannot be overfilled. If the leachate dam ortanks are open at the top, they shouldgenerally be capable of accepting a 1 in 25year storm event without overflowing.Overflow or high flow storage dams shouldbe designed to the same standards as thelandfill. They should be designed tominimise run-on ingress.

Leachate Treatment Plant

The treatment plant, if employed, should belocated within the landfill facility.

The process design of the treatment plantshould be such that the plant is capable ofdestroying, reducing and/or removing the

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inorganic and/or organic contaminants inthe raw leachate and/or other pollutants thatmay be present in the leachate.

The hydraulic capacity of the treatment plantshould be designed to handle the projectedmaximum quantity of leachate with adequatestand-by capacity.

The construction of treatment plants shouldmeet the health and safety requirements ofthe WorkCover.

Disposal of Liquid Wastes

The treated leachate may be disposed of onlyby one or more of the following methods:

• discharge to sewer in accordance with thewater authority requirements, or

• discharge to open waters or land inaccordance with the conditions of alicence issued under the Pollution ControlAct 1970, or

• assessment and classification inaccordance with the requirements of theWaste Minimisation and ManagementRegulation 1996, followed bytransportation to a licensed liquid wastetreatment facility or to a facility whichmay otherwise lawfully receive it.

Untreated leachate should be assessed andclassified in accordance with therequirements of the Waste Minimisation andManagement Regulation 1996, followed bytransportation to a licensed liquid wastetreatment facility for treatment.

Untreated leachate, treated leachate and anyliquids intended to be discharged should betested before release for disposal or sendingoff-site for further treatment. Refer to ‘8A.Leachate Monitoring Program’ below forfurther details.

4A. GROUNDWATERMONITORING NETWORK

Primary Environmental Goal

2.1.2 Detecting water pollution

Related Environmental Goals

2.1.1 Preventing pollution of water byleachate

2.1.3 Remediating water pollution2.3.1 Assuring quality of design, constructionand operation

The design, number and location of wells orlysimeters in the groundwater monitoringnetwork should be able to demonstrate thatgroundwater or subsoil is not contaminatedand ensure early detection of anycontamination by means of regularrepresentative samples of groundwater andwater vapour from the vadose zone.

The groundwater monitoring programshould consider the testing of analytesadditional to those listed in Table 2(Benchmark Technique ‘5. GroundwaterMonitoring Program’) of the LandfillGuidelines in situations in which:

• leachate monitoring indicates thepresence of such chemical species insignificantly high concentrations in theleachate, and/or

• it is known that significant quantities ofsuch chemical species are present inwaste disposed of at the landfill.

The requirements for establishing agroundwater and subsoil monitoringnetwork should include the following:

• If only one thin (less than five metresthick) aquifer is identified on-site, single,fully-slotted bores are regarded assufficiently reliable indicator bores forcontaminants. If multiple aquifers areidentified on-site, or an aquifer greaterthan five metres thick is identified, themonitoring bores should be:

- a nest of bores, slotted over differentintervals,

- a multi-port bore, or

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- an appropriate combination of both.

• Monitoring bores should generally have aminimum internal diameter of50 millimetres in order to allow adequatesampling.

• The selected monitoring bore designshould include suitable strength pipemade from materials exhibitingappropriate chemical resistance, withslotted sections gravel-packed andadequate cement/bentonite sealsbetween these sections. The standpipeshould be adequately sealed near groundlevel using cement-based grout, with thetop of the standpipe covered by a securitycover. Additionally, the standpipe shouldbe constructed to prevent the entry ofsurface water and to prevent extraneousmaterial such as insects from getting intothe well.

• The porous media surrounding themonitoring bores and the lysimeter cupshould be selected to ensure that they donot affect the sample’s accuracy.

• Installation and well maintenance shouldbe undertaken following standardreferences on this subject such as:

- the USEPA’s Handbook: Groundwater.Volume II: Methodology (1991)

- Hirschberg’s Guidelines forGroundwater Monitoring at MunicipalLandfill Sites (1993).

• The LEMP should clearly identify thenumber of wells, drilling method,material used in well construction,procedures used for well developmentand well security. The quality standardsestablished in the approved constructionquality control program (see benchmarktechnique 20 Assurance of quality in theLandfill Guidelines) should be applied tothe establishment and operation of thegroundwater monitoring system.

• The Groundwater Monitoring Programmay include installation of suctionlysimeters to monitor the vadose zonebeneath the landfill and at suitablelocations surrounding the landfill linerwhen there is no evidence of

groundwater. A suction lysimeter is usedto extract pore water when groundwateris absent. These devices should indicatethe presence and quality of leachate inthe geological formation.

• Electrodes should be installed beneaththe leachate collection sump and in atleast one in both the upgradient anddowngradient groundwater monitoringwells in order to monitor automatically(continuously) the electrical conductivityof the groundwater at landfills receivingindustrial waste. The frequency andsensitivity of these measurements mustbe governed by the rainfall patterns andbe able to give an early indication of thepossible contamination of groundwaterby any leachate seeping through the linersystem.

8A. LEACHATE MONITORINGPROGRAM

Primary Environmental Goal

2.1.1 Preventing pollution of water byleachate

Related Environmental Goals

2.1.2 Detecting water pollution2.1.3 Remediating water pollution2.3.1 Assuring quality of design, constructionand operation2.4.2 Preventing degradation of local amenity2.4.5 Adequate staffing and training

A leachate monitoring program isrecommended to assess:

• the leachate inflow rates from theprimary LCCS to measure/estimate thequantity of leachate generated

• the leachate inflow rates from thesecondary LCCS in order to detect anymalfunction of the upper liner or thesecondary LCCS, and

• the effluent quality from any on-siteleachate treatment plant in order toensure that it is acceptable for dischargeto sewer, open waters or land.

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Monitoring of treated leachate for dischargeto sewer, open waters or land should beundertaken in accordance with the dischargeagreement or licence as determined by thewater authority or the EPA. The frequencyand locations of sampling, and themonitoring parameters must be as specifiedin the discharge agreement or licence.

Any disposal method for leachate should beapproved by the EPA and outlined in theLEMP. Off-site disposal of untreated leachateshould be limited to discharge to anapproved treatment facility.

Initial characterisation testing is to beconducted for aromatics, heavy-metalsvolatiles, halocarbons and the base, neutraland acid extractable organic contaminantsthat could be detected by Methods 8260 and8270 (USEPA, 1992). Additional quarterly orbatch testing of a representative sample forall contaminants should be required asagreed in the groundwater monitoringprogram.

The inflow rates of leachate from thesecondary LCCS should be monitored dailyin the range of the Action Leakage Rate(ALR) and the Rapid and Large Leakage Rate(RLLR).

The EPA should be notified in accordancewith section 3.4.1 of the Landfill Guidelineswhen the ALR or RLLR is determined to beexceeded.

Action Leakage Rate

The ALR is a low level leak rate that wouldindicate the presence of a small hole or defectin the top liner.

A site-specific ALR value should bedeveloped based on the liner design,meteorological and hydrogeologicalconditions of the site.

If the daily leak rate (averaged over a 3 daysperiod) exceeds the ALR, the Leak ResponseAction Plan (LRAP) should be implemented.

Rapid and Large Leakage Rate

The RLLR is a high-level danger trigger thatwould indicate a serious malfunction ofsystem components in the double lined unit,and therefore warrant immediate action.

The RLLR is the maximum design leakagerate that the secondary LCCS can accept. Asite-specific RLLR value should be developedbased on the design of the secondary LCCSdrainage layer.

The LRAP should be implemented if theRLLR is exceeded.

Leak Response Action Plan

The landfill occupier should prepare andsubmit a LRAP to the EPA for approval priorto the operation of industrial waste landfills,cells, monocells or monofills. The plan shoulddescribe all measures to be taken for mostlikely leakage scenarios. It can only bemodified with the approval by the EPA asspecific leak incidents occur.

The LRAP should identify the factorsaffecting the amounts of leakage entering thesecondary LCCS, assess the most likelyevents that may cause leakage, and describethe design and operational mechanisms toprevent escape of hazardous constituentsinto the environment.

The LRAP should be developed for two basicsituations:

• leakage rates that equal or exceed theRLLR; and

• leakage rates that exceed the ALR but lessthan the RLLR.

10A. LANDFILL GASCONTAINMENT SYSTEM

Primary Environmental Goal

2.2.1 Preventing landfill gas emissions

Related Environmental Goals

2.2.2 Detecting landfill gas emissions2.2.3 Remediating landfill gas emissions2.3.1 Assuring quality of design, constructionand operation2.4.5 Adequate staffing and training

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In certain circumstances gas may begenerated in a landfill receiving industrialwaste due to the decomposition of organicmaterials in the wastes placed in the facility.The nature and variability of industrial wastesmakes it difficult to predict whether gasgeneration is likely. Gas may be produced incertain areas of the fill and not in others.

A landfill gas model, predicting gascomposition and generation rates, should bedeveloped. Where possible, wastes that areliable to generate gases should be landfilledseparately.

If significant gas production is expected, thelandfill gas generated in the landfill shouldbe contained. For help refer to otherbenchmark techniques, for example:

1A. Leachate barrier system28A. Site capping and revegetation33. Covering of waste.

The design of the above must take intoconsideration containment of landfill gas.

If landfill gas is generated it should bemonitored and extracted in ways that areequivalent to the following benchmarktechniques:

11. Extraction and disposal of landfill gas15. Subsurface gas monitoring devices16. Subsurface gas monitoring program17. Surface gas emission monitoring18. Gas accumulation monitoring19. Remediation of uncontrolled gasemissions.

14A. SITE CLOSURE

Primary Environmental Goal

2.1.1 Preventing pollution of water byleachate

Related Environmental Goals

2.2.1 Preventing landfill gas emissions2.2.2 Detecting landfill gas emissions2.2.3 Remediating landfill gas emissions2.3.1 Assuring quality of design, constructionand operation2.4.5 Adequate staffing and training

A landfill site should be closed in a mannerthat minimises the generation of leachate.This may involve capping and revegetationdesigned to contain the waste within thelandfill and to drain surface runoff falling onthe landfill site. Closure and capping arecovered in detail in ‘28A. Site capping andrevegetation’ below and ‘29. Landfill closureand post-closure monitoring and maintenance’given in Appendix A of the LandfillGuidelines.

21A. SCREENING OF WASTESRECEIVED

Primary Environmental Goal

2.3.2 Assuring quality of incoming waste

Related Environmental Goals

2.1.1 Preventing pollution of water byleachate2.2.1 Preventing landfill gas emissions2.3.1 Assuring quality of design, constructionand operation2.3.3 Recording of wastes received2.3.4 Minimising landfill space used2.3.5 Maximisation of recycling2.3.6 Remediating landfill after closure2.4.2 Preventing degradation of local amenity2.4.5 Adequate staffing and training

The landfill occupier should put in placewaste acceptance, inspection, sampling, andanalysis procedures that ensure thatprohibited waste does not enter the site, toverify the waste generator’s description ofthe waste regarding its physical and chemicalnature, and to ensure the health and safety ofpersonnel handling such waste.

Generally, the following practices apply:

• The occupier should ensure that theassessment and classification of the wastereceived for disposal has been made bythe generator/owner of the waste inaccordance with the Waste Guidelines.

• The landfill occupier should ensure thatsigns clearly indicating the types of wastethat are to be accepted and those that arenot to be accepted are prominentlydisplayed at the point of entry.

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• The landfill occupier should put intopractice a program of inspection andanalysis of incoming waste loads thatproduces statistically reliable data. Thismay involve directing selected loads to aseparate area to dump the load, thensampling waste loads for verificationtesting on site, and if necessary sendingsamples for more detailed analysis to anindependent accredited laboratory.

• The landfill occupier should check that allindustrial waste has appropriatedocumentation prior to acceptance at thesite.

• The landfill occupier should ensure thatrecords of all inspections are maintainedfor the operating life (including post-closure) of the landfill.

• The EPA’s Regional Office should benotified if any unauthorised hazardouswastes have been found on site, and ofthe identity of any party responsible fordumping such wastes according toincident reporting requirements insection 3.4.1 of the Landfill Guidelines.

• Maintain close supervision of tippingactivities at the tip face to ensure theaccountability of those attempting todeposit wastes that are not permitted tobe landfilled at the facility.

• All landfill occupiers should train landfillstaff adequately, especially to be able torecognise and handle hazardous wastes.

Emergency Disposal

In case of emergency, the EPA might givespecial consideration and grant consent forlandfill disposal of hazardous wastes such aschemical spill waste. The landfill occupiershould ensure that the necessary approvaldocumentation is obtained prior to receivingsuch waste.

Until the waste of concern has beenidentified to be compatible with other wastein the landfill, it should be stored in aseparate area so that the potential hazardsarising from the mixing of wastes areavoided. The waste stored will need to beable to be retrieved:

• for subsequent monofilling if it isconfirmed as reacting with other waste

• for treatment if a technology emerges thatis capable of treating the waste, or

• for recovery if the waste becomes a usefulresource.

22A. MEASUREMENT OFQUANTITIES OF WASTESRECEIVED

Primary Environmental Goal

2.3.3 Recording of wastes received

Related Environmental Goals

2.3.1 Assuring quality of design, constructionand operation2.3.6 Remediating landfill after closure2.4.1 Preventing unauthorised entry2.4.5 Adequate staffing and training

Clause 25 of the Waste Minimisation andManagement Regulation 1996, subject tosubclause (3), requires the occupier of alandfill site who is required to paycontributions under section 72 of the WasteMinimisation and Management Act to install aweighbridge if the waste facility receivesover 20,000 tonnes of waste per year.

Those who are required to pay contributionsunder section 72 of the Act are also requiredto:

• lodge a monthly return to the EPAdetailing types and tonnages of wastereceived at the weighbridge, forcalculation of the Section 72 contribution,and

• lodge a report on the total quantity ofwaste received every 12 months,compiled by a registered surveyor or byan alternative method approved by theEPA.

Any weighbridge used should have a validCalibration Certificate from the Departmentof Consumer Affairs at all times.

Any weighbridge used should be operationalat all times of landfill activity. Should theweighbridge be inoperative, the occupier will

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notify the EPA immediately and ensure thatit is repaired as soon as practicable. While theweighbridge is inoperable, the occupiershould provide a portable weighbridge toreplace the inoperable one until it is repaired.

23A. RECORDING OF THEQUANTITIES, TYPES ANDSOURCES OF WASTESRECEIVED

Primary Environmental Goal

2.3.3 Recording of wastes received

Related Environmental Goals

2.3.1 Assuring quality of design, constructionand operation2.3.6 Remediating landfill after closure2.4.1 Preventing unauthorised entry2.4.2 Preventing degradation of local amenity2.4.5 Adequate staffing and training

Each month landfill occupiers who arerequired to pay contributions under section72 of the Act must provide data to the EPAon the amount, type and source of all wastereceived. Official reporting forms must beused, and these may be obtained from theEPA. Occupiers who are not required to paycontributions will be required to providesuch information on a quarterly basis.

The landfill occupier must have a survey ofthe site compiled by a registered surveyor orestimate the amount of waste deposited byan alternative method approved by the EPAon an annual basis to quantify the volume oflandfill space consumed in the past 12months. The landfill survey specified abovewill form part of the landfill's annual reportto the EPA.

The landfill occupier must maintain detailedrecords of the quantity, composition, source,disposal location on site in Australian MapGrid (AMG) and altitude in metres abovePrincipal Datum (mPD) of each incomingwaste load. This is to ensure that any wastedisposed of at the landfill can be accuratelylocated on site for future retrieval if it isidentified as causing a problem, or if atechnology emerges that is capable of

treating the waste, or if the waste becomes auseful resource. The landfill occupier shouldprovide a positioning system that is capableof locating any waste load on site to thenearest 5 metres.

The landfill occupier should establish therecording system so that the EPA can accessthe information at any time.

Controls should be established to preventany vehicles or personnel from entering andleaving the site without generating apermanent record.

24A. COMPACTION OF WASTE

Primary Environmental Goal

2.3.4 Minimising landfill space used

Related Environmental Goals

2.1.1 Preventing pollution of water byleachate2.2.1 Preventing landfill gas emissions2.3.1 Assuring quality of design, constructionand operation2.3.6 Remediating landfill after closure2.4.5 Adequate staffing and training

Wastes should be deposited in a manner thatminimises the amount of landfill space usedto dispose of the wastes, and does not createvoid spaces in the waste that wouldencourage the presence of vermin or lead tofires or the excess generation of leachate.

28A. SITE CAPPING ANDREVEGETATION

Primary Environmental Goal

2.3.6 Remediating landfill after closure

Related Environmental Goals

2.1.1 Preventing pollution of water byleachate2.2.1 Preventing landfill gas emissions2.3.1 Assuring quality of design, constructionand operation2.3.4 Minimising landfill space used2.4.2 Preventing degradation of local amenity2.4.5 Adequate staffing and training

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Site capping and revegetation should ensurethat the final surface provides a barrier to themigration of water into the waste, controlsemissions to water and atmosphere,promotes sound land management andconservation, and prevents hazards andprotects amenity. In addition, the cappingmust be designed to function with minimummaintenance and to accommodate settlementand subsidence of the underlying waste. Thiswould include the following points:

The occupier will commence capping thecompleted filling areas within 30 days ofcompletion of landfilling in that area,weather permitting.

The landfill should have a final cappingcomprising three parts:

• the composite liner system

• the middle drainage layer, and

• a vegetated top cover.

A composite liner system should consist of aGCL of a permeability to water of less than10-11 ms-1 laid over a foundation layer ofrecompacted clay or modified soil of at least60 centimetres in thickness and with apermeability to water of less than 10-9 ms-1.The construction of recompacted clay ormodified soil elements should be done inlayers, each of a maximum thickness of 30centimetres. Each successive lift should be ofthe same material and the surface of eachunderlying layer should be scoured toprevent extreme permeability due tolaminations between layers. The final topslope of the composite liner system must benot less than 2 per cent at any point ofmeasurement.

A middle drainage layer with a permeabilityto water of K > 10-4 ms-1 should be placedover the composite liner system. Thedrainage layer will be not less than 30centimetres deep. The drainage media shouldbe selected to have a sufficiently large voidspace to drain the runoff effectively andefficiently, and to prevent encrustationduring the operating life of the landfill.Gravel of suitable grade or a combination ofsuch gravel and a geonet may be used. Thegravel selected should be:

• rounded

• of nominal size greater than 20millimetres

• smooth-surfaced

• robust and non-reactive in mildly acidicconditions

• relatively uniform in grain size

• free of carbonates that could formencrustations around the collector pipes,and

• covered with a non-woven filter fabric.

A revegetation layer of depth of not lessthan 1 metre should be placed over thedrainage layer. Plants selected forrevegetation shall have root systems that willnot penetrate beyond the revegetation layeror block the drainage layer. The final topslope of the vegetative layer should bebetween 3 and 5 per cent.

The landfill occupier should implement, aspart of the post-closure care program, a sitesettlement monitoring program. The siteshould be surveyed regularly for anysettlement. If inspections of the cappingshow that its integrity is breached or can nolonger be guaranteed, then the occupiershould replace the capping when it is shownthat the total settlement and subsidence ofthe waste in that cell has ceased.

30A. SECURITY OF SITE

Primary Environmental Goal

2.4.1 Preventing unauthorised entry

Related Environmental Goals

2.2.1 Preventing landfill gas emissions2.3.3 Recording of wastes received2.4.2 Preventing degradation of local amenity2.4.5 Adequate staffing and training

Unauthorised entry to landfills receivingindustrial waste can lead to waste dumping,fires, vandalism of pollution control devices,as well as loss of amenity. The occupiershould ensure that the following measuresare installed and maintained at all landfillsites receiving industrial waste:

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• lockable security gates

• wire mesh fence (1.8 metre high) aroundthe perimeter of the site. The fence shouldbe posted with signs to identify the siteand warn trespassers to stay away, and

• a telephone number to contact in case ofemergency should also be posted.

Clause 26 of the Waste Minimisation andManagement Regulation 1996 states that theEPA may, by notice in writing, require theoccupier of a landfill site who is required topay contributions under section 72 of theWaste Minimisation and Management Act 1995to install an approved video monitoringsystem in the manner and location specifiedin the notice, if it is of the opinion that theoccupier has failed to pay the requiredcontributions under the Act.

Occupiers of landfills accepting wasteclassified as industrial waste may wish toconsider the voluntary installation of a videomonitoring system as a potential componentof their site security system.

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TECHNICAL APPENDIX 2COVERING STATEMENTA covering statement must be attached toall landfill environmental managementplans

It should cover the following issues:

Section 1 - Landfill Details (to be completedby ALL occupiers)

Landfill Name

Landfill Street Location

Landfill Lot Details (lot and DP #)

Owner of Landfill

Occupier of Landfill

EPA Licence number(s) if licensed

Types and quantities of wastes to bereceived

Total waste capacity of the site

Projected rate of filling

Expected life of the landfill

Names of the local government areasfrom which the waste will be sourced

Section 2 - Landfill Environment

(To be completed by ALL occupiers byreferring to the relevant section and pagenumber in the attached LEMP)

Section 2.1 - Human Environment

Zoning details of the landfill andsurrounding area

Details of applicable environmentalplanning instruments

All heritage, environmentalprotection or other restrictionsapplying to the site

The location of the landfill relative toresidences or other sensitivedevelopments

Section 2.2 - Natural Environment

Local geology and hydrogeology

Groundwater and surface water flowsin and around the site

Local meteorological conditions.

Section 3 - Proposed or Existing AlternativeTechniques

Is the occupier immediately adopting all thebenchmark techniques in the EPAEnvironmental Guidelines: Solid WasteLandfills in their entirety? (Yes or No)

If Yes, the Covering Statement is complete.

If No and an alternative technique isproposed, please provide the followinginformation in an attachment to the coveringstatement on each alternative technique:

• The number and name of the benchmarktechnique(s) in the EPA’s EnvironmentalGuidelines: Solid Waste Landfills(Landfill Guidelines) that the alternativetechnique will replace.

• A description of the alternative techniquewith page references to the LEMP.

• A brief outline of how the techniqueadequately addresses the primary andrelated environmental goals in theLandfill Guideline for that benchmarktechnique with page references to theLEMP.

• A time line for implementation of thealternative technique and identification ofthe possible environmental consequencesof not immediately implementing thealternative technique, with pagereferences to the LEMP.

• List any benchmark techniques that youpropose to omit without replacement inan alternative technique and the reasonsfor their omission.

If No and it is proposed to implement abenchmark technique in the future:

• The number and name of the benchmarktechnique in the EPA’s EnvironmentalGuidelines: Solid Waste Landfills (LandfillGuidelines).

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Draft Environmental Management of Industrial Waste Landfilling– 22 –

• The proposed timing for implementingthe benchmark technique.

• The technique proposed to be used beforeimplementing the benchmark technique.

• Any possible environmental consequencesof not immediately implementing thebenchmark technique.

Notes:

1. The ‘covering statement’ requiresidentification of any departures from thebenchmark techniques contained in theGuidelines and the provision of a timetablefor the implementation of benchmarktechniques and/or proposed alternativetechniques.

2. Unless the licensee specifies in the ‘coveringstatement’ that it is proposed to adoptalternative techniques, the EPA will attachconditions to the licence that reflect thebenchmark techniques specified in theGuidelines in their entirety.

3. Unless the licensee specifies in the ‘coveringstatement’ that future implementation oftechniques is proposed to meet certainenvironmental goals, the EPA will attachconditions to the licence that require theimmediate implementation of relevantbenchmark techniques.

4. The EPA will negotiate with the licensee theapplication of alternative techniques and/orthe future implementation of techniqueswhere these are appropriately documented inthe ‘covering statement’ and LEMP. Ifapproved by the EPA, these will be specifiedas licence conditions

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Draft Environmental Management of Industrial Waste Landfilling– 23 –

DEFINITIONS ANDGLOSSARYAction Leakage Rate: a low level leak ratethat would indicate the presence of a smallhole or defect in the top liner.

Approved: Approved by the EPA from timeto time.

Commercial and industrial waste: wastesclassified as inert, solid, industrial or hazardousgenerated by businesses and industries(including shopping centres, restaurants andoffices) and institutions (such as schools,hospitals and government offices), excludingbuilding and demolition waste andmunicipal waste.

Controlled waste activity: A wastegenerating or storage activity specified in theWaste Minimisation and ManagementRegulation 1996 as requiring a licence.

Controlled waste facility: A waste facility ofa type specified in the Waste Minimisationand Management Regulation 1996 asrequiring a licence.

Decomposition: The breakdown of organicwaste materials by micro-organisms.

EPA: New South Wales EnvironmentProtection Authority

Groundwater: water saturating the voids insoil and rock; water in the zone of saturationin the Earth’ crust.

Hazardous waste: Any waste that isclassified or assessed as hazardous inaccordance with Section 3 or TechnicalAppendix 1 of the Waste Guidelines.

Industrial waste: Any waste that is classifiedor assessed as industrial in accordance withSection 3 and Technical Appendix 1 of theWaste Guidelines.

Industrial waste cell: may be located at asolid waste landfill and must be isolated fromthe rest of the landfill by means of aleachate/gas barrier of low permeability.Such a cell may be suitable for the disposal ofmore than one waste type classified asindustrial waste. Such a cell must be at an

edge of the landfill and may not have othertypes of waste either above or below it.

Industrial waste landfill: A landfill licensedunder the Waste Minimisation andManagement Regulation 1996 to accept fordisposal more than one waste type that isclassified or assessed as industrial waste inaccordance with Section 3 or TechnicalAppendix 1 of the Waste Guidelines, or isotherwise specified in Table 5 (see alsoSection 4).

Industrial waste monocell: is a part of a cellat an industrial or a solid waste landfill which isisolated from the rest of the cell by means ofa leachate/gas barrier of low permeability forthe disposal of one specific industrial wastetype. A monocell, one side of which must beat an edge of the landfill cell, may not haveother types of waste either above or below it.

Industrial waste monofill: an isolatedlandfill unit licensed under the WasteMinimisation and Management Regulation1996 to accept for disposal of one specificindustrial waste type.

Inert waste: Any waste that is classified orassessed as inert in accordance with Section 3and Technical Appendix 1 of the WasteGuidelines.

Landfill gas: gaseous emissions from thedecomposition of organic waste materialsplaced in a landfill.

Landfill Guidelines: EnvironmentalGuidelines: Solid Waste Landfills (EPA 1996).

Landfill site: a waste facility used for thepurposes of disposing of waste to land.

Leachate: Liquid released by, or water thathas percolated through, waste, and thatcontains dissolved and/or suspended liquidsand/or solids and/or gases.

Leachate collection and conveyance system:an engineered collection and conveyancesystem for leachate generated at a landfillsite.

Leachate treatment plant: a facility used fordestroying, reducing and/or removing thetoxic inorganic or organic contaminants inthe raw leachate and/or other hazardous

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Draft Environmental Management of Industrial Waste Landfilling– 24 –

pollutants by physical, chemical or biologicalmeans.

Leak response action plan: an action planthat describes all measures to be taken forevery probable leakage scenario in the linersystem.

Liquid: Any substance that does not meet allof the criteria of physically solid, and that isnot a gas.

Mineralise: Turning contaminatingsubstances that are deposited in theenvironment (such as chemicals or organicwastes) into harmless substances (e.g.minerals) by means of the physical, chemicalor biological processes occurring in nature.

Monocell: A part of a landfill cell isolatedfrom the rest of the cell by means of aleachate/gas barrier of low permeability forthe disposal of one specific waste type. Amonocell, one side of which must be at anedge of the landfill cell, may not have othertypes of waste either above or below it.

Monofill: An isolated landfill unit fordisposal of one specific waste type.

Non-liquid: Any material that satisfies allthe requirements of physically solid.

Occupier: a person who has the managementor control of the landfill (other than as anemployee).

Physically solid: Material that:

(i) has an angle of repose of greater thanfive degrees (5°)

(ii) has no free liquids

(iii) liberates no free liquids whentransported

(iv) does not become free flowing at orbelow 60°C or when transported

(v) is spadeable.

Processing: Subjecting a substance to aphysical, chemical or biological treatment ora combination of treatments.

Putrescible waste: Food or animal matter(including dead animals or animal parts), orunstable or untreated biosolids.

Rapid and large leakage rate: a high leveltrigger that would indicate a serious

malfunction of system components in thedouble liner system.

Recycling: The processing of waste into asimilar non-waste product.

Reprocessing: The processing of waste into adifferent non-waste product.

Re-use: Waste re-used with or withoutcleaning and/or repairing.

Runoff: the portion of precipitation thatdrains from an area as surface flow.

Sludge: Semi-liquid waste produced as aby-product of an industrial process.

Solid waste: Any waste that is classified orassessed as solid in accordance with Section 3or Technical Appendix 1 of the WasteGuidelines.

Spadeable: A physical state of a materialwhere the material behaves sufficiently like asolid to be moved by a spade at normaloutdoor temperatures.

Treatment: Physical, chemical or biologicalprocessing of a waste for disposal.

Waste: As defined in the Waste Minimisationand Management Act 1995:

‘waste includes:

(a) any substance (whether solid, liquid orgaseous) that is discharged, emitted ordeposited in the environment in suchvolume, constituency or manner as tocause an alteration in the environment, or

(b) any discarded, rejected, unwanted,surplus or abandoned substance, or

(c) any otherwise discarded, rejected,unwanted, surplus or abandonedsubstance intended for sale or forrecycling, reprocessing, recovery orpurification by a separate operation fromthat which produced the substance, or

(d) any substance prescribed by theregulations to be waste for the purposesof this Act.

A substance is not precluded from beingwaste for the purposes of this Act merelybecause it can be reprocessed, re-used orrecycled.’

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Draft Environmental Management of Industrial Waste Landfilling– 25 –

Waste facility: As defined in the WasteMinimisation and Management Act 1995,means any premises used for the storage,treatment, reprocessing, sorting or disposalof waste.

Waste Guidelines: Environmental Guidelines:Assessment, Classification and Management ofNon-Liquid Wastes (EPA 1997).

Waste Minimisation and Management Act1995: Sets out statutory obligations for themanagement of waste, including provisionsfor the licensing and reporting of wasteactivities and waste facilities and provisionsimposing standard environment protectionrequirements for non-licensed wasteactivities and transporters.

Waste Minimisation and ManagementRegulation 1996: Sets out statutoryobligations for the management of wasteincluding provisions for the licensing andreporting of waste activities and wastefacilities and details measures relating tostandard environment protectionrequirements for many non-licensed wasteactivities and transporters.

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BIBLIOGRAPHY

American Public Health Association,American Water Works Association, WaterEnvironment Federation 1992, StandardMethods for the Examination of Water &Wastewater, Greenberg, A.E., Clesceri, L.S. &Eaton, A.D. (eds.), American Public HealthAssociation, Washington DC.

ANZECC 1992, Australian Water QualityGuidelines for Fresh & Marine Waters,Australia & New Zealand Environment &Conservation Council, Canberra.

ANZECC 1994, National Guidelines for theManagement of Wastes—National Manifest andClassification System, Australia & NewZealand Environment & ConservationCouncil, Canberra.

CCME 1991. National Guidelines for theLandfilling of Hazardous Waste (Report CCME-WM/TRE-028E). Canadian Council ofMinisters of the Environment.

Cheremisinoff, P. N. 1990. Hazardous WasteContainment and Treatment, Encyclopedia ofEnvironmental Control Technology Vol.4.Gulf Publishing Co.

Department of the Environment (UK) 1996.Landfilling Wastes, Waste Management PaperNo 26B. London.

Department of Water Affairs and Forestry(South Africa) 1994. Minimum Requirementsfor Waste Disposal by Landfill. Pretoria.

Harwell 1985. Proceedings of LandfillMonitoring Symposium. Harwell Laboratory,UK.

Keenan, J. D. 1986. Landfill LeachateManagement. Journal of Resource Managementand Technology, Vol.14, No.3, 1986, 177-180.

NHMRC 1985, Code of Practice for the Disposalof Radioactive Wastes by the User (RadiationHealth Series No 13), National Health &Medical Research Council, Canberra.NSWEPA 1994. Castlereagh Waste DisposalDepot: Stage II Environmental Audit FinalReport Volumes 1 to 3. AGC Woodward-ClydePty Ltd, Sydney.NSWEPA 1995, Provisional Water QualityInvestigations Manual: Preferred Methods for

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NSWEPA 1995b, Sampling Design Guidelines,NSW Environment Protection Authority,Sydney.

NSWEPA 1996, Environmental Guidelines:Solid Waste Landfills, NSW EnvironmentProtection Authority, Sydney.

NSWEPA 1997. Environmental Guidelines:Assessment, Classification and Management ofNon-Liquid Wastes. New South WalesEnvironment Protection Authority, Sydney.

USEPA 1989. Final Covers on Hazardous WasteLandfills and Surface Impoundments (EPA/530-SW-89-047). United States EnvironmentalProtection Agency, Office of Solid Waste andEmergency Response, Washington DC.

USEPA 1989. Requirements for HazardousWaste Landfill Design, Construction, andClosure (EPA/625/4-89/022). United StatesEnvironmental Protection Agency, Office ofResearch and Development, Washington DC.

USEPA. 1992. SW-846 Test Methods forEvaluating Solid Waste: Physical/ChemicalMethods, Office of Solid Waste andEmergency Response, Washington D.C.

USEPA 1995. Ground-Water and LeachateTreatment Systems (EPA/625/R-94/005).United States Environmental ProtectionAgency, Office of Research andDevelopment, Washington DC.

USEPA 1995. 40 CFR 264.90 to 264.101Standards for Owners and Operators ofHazardous Waste Treatment, Storage, andDisposal Facilities, Subpart F - Releases fromSolid Waste Management Units. UnitedStates Environmental Protection Agency.

USEPA 1995. 40 CFR 264.300 to 264.317Standards for Owners and Operators ofHazardous Waste Treatment, Storage, andDisposal Facilities, Subpart N - Landfills.United States Environmental ProtectionAgency.