EPA’s Landfill Licence Review – Are You Prepared?
EPA Victoria is in the process of issuing proposed new licence conditions for all operating landfills. Depending on the level of risk your site poses to the environment there may be additional requirements of your licence
8 Requirements You May Face and Their Implications
- Amenity Conditions: Your new licence may specify the need for source controls to suppress odour, noise, dust and litter. If your site has previously been linked to amenity issues, for example community complaints or issues noted by EPA during inspection, then site-specific measures to address amenity risks can be prescribed by EPA as additional licence conditions.
- Site-specific Monitoring: EPA may prescribe site-specific monitoring requirements, in addition to your auditor-verified landfill monitoring program. This might be in relation to specific risks identified by EPA, for example asbestos in air monitoring.
- Hydrogeological Assessment: Similar to the process that EPA has rolled out for closed landfill sites, a Hydrogeological Assessment (HA) will be required for sites (or cells) that have not been lined to the BPEM standard. The HA will need to specify maximum target leachate levels to be maintained in each cell, and will need to be verified by an Environmental Auditor. There will also be a requirement to review and update the HA every 5 years.
- Leachate Extraction: A specific requirement for leachate extraction will be added to your licence. For BPEM lined cells the target leachate level will continue to be 300 mm above the base of the liner, whereas the leachate level in unlined or partially lined cells is to be determined by the HA.
- Background Gas Concentrations: There may be a requirement to determine background concentrations of methane and carbon dioxide. It is expected that this will be included as a licence condition if the BPEM action levels for landfill gas have been exceeded and/or an assessment of background gas concentrations has not yet been conducted for your site.
- Tipping Face Size: A new requirement will be added which limits the size and slope of the active tipping face. The size of the tipping face will be determined by EPA on a site-specific basis.
- Progressive Rehabilitation: The rehabilitation requirements outlined in your licence will be more specific about the timing and implementation of progressive rehabilitation. In particular, the rehabilitation plan will need to be updated after each cell is filled, and it will need to address the progressive capture and treatment of landfill gas and leachate from each completed cell.
- Capping Requirements: Required timeframes for placement of intermediate and final capping will be specified by individual licence conditions. The design, approval and construction quality assurance process for the final landfill cap will be clearly stepped out in the licence conditions.
Once you have been issued with draft licence amendments you will be given four weeks to provide comment back to EPA.
Amelia Russo, Associate – Environmental said: “The new licence conditions may sound onerous but early planning can alleviate any potential headaches and prevent non-compliance. Having assisted numerous landfill operators meet their obligations throughout EPA’s previous landfill licence reform, and with over 20 years of experience in landfill projects, Meinhardt is well placed to provide you with practical solutions. Site-specific constrains may limit your ability to achieve certain licence conditions; this presents opportunities to negotiate with EPA”.
Amelia Russo, Associate Director, Environmental Services
Direct: +613 8676 1223