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SA EPA gives clearer guidance for management of landfill facilities

South Australia’s EPA recently updated its state guidelines for the development and operation of waste depots following consultation with industry and its stakeholders. So, what does this mean for industry moving forward?

Landfill has an important role to play as part of the transition required to achieve sustainable resource recovery and waste management. In SA, the development and operation of landfill facilities are activities of environmental significance, which requires development approval under the Development Act 1993 (EP Act) and an environmental authorisation in the form of a licence.

Aiming to provide guidance, the SA EPA has published the Environmental management of landfill facilities – solid waste disposal guideline (EPA 2019), which has replaced the previous Guideline for environmental management of landfill facilities (municipal solid waste and commercial and industrial waste).

The guideline sets out the SA EPA’s expectations of landfill operators, developers, planning authorities and regulatory bodies on the site selection, development, design, construction, operation, closure and post-closure management of landfill facilities. It also aims to minimise the risk of adverse impacts associated with waste disposal on the land, water and air environments.

SA EPA director, Peter Dolan, said the decision to update the landfill guideline was not about wholesale change to industry practices, but instead aimed at bringing the guidance up to date with current industry practices.

“The updates to the guideline will provide certainty for the industry through the provision of greater technical guidance and expanded clarity on the SA EPA’s expectations.

“The review of the guideline is not intended to restrict industry practices, but enhance clarification of roles and responsibilities to facilitate early engagement with all parties and stakeholders. This will allow for flexibility in design and approach, while achieving consistent performance outcomes that reflect site specific risks,” he said.

The guideline states that it is vital that a precautionary approach be adopted to adequately address the environmental risks of landfill facilities, recognising that residual waste composition has changed and will continue to change over time in response to technological advances in recovery activities.

The guideline has been restructured to reflect each of the design and construction elements as an integrated system, together with regulatory and operational controls. Landfill design comprises of liner system at the base and side of the landfill, leachate collection system, cover system, gas collection system, environmental monitoring system, and post-closure plan for maintenance and utilisation of the landfill after its closure.

The guideline reflects contemporary best practice engineering design and construction, based on a revised classification system, together with the inclusion of new operational practices, updated regulatory references, and expanded guidance on closure, post-closure and landfill gas obligations.

It also reflects the changing nature of residual waste composition in relation to disposal, and the need to design and operate landfill facilities that take into account the changing chemical and physical composition of residual waste. This is especially relevant in SA, as it strives to introduce new and innovative resource recovery activities to further divert waste from landfill in the state.

“The previous guideline was 10 years old, and industry practices and knowledge have evolved over this time,” Dolan said.

“The nature of, and activities in landfill facilities have diversified, and the previous guideline did not provide guidance on the SA EPA’s expectations – for example, the conduct of resource recovery activities and the use of alternative covers.

“The quality and manufacture of geosynthetics have significantly changed over the past decade, as have design and quality assurance requirements. The composition of waste has also changed and will continue to change into the future.”

A workshop with industry stakeholders was conducted to establish the scope of the review before any changes were proposed, providing the industry with a genuine voice in the process. It also resulted in aspects of the guideline being excluded from review.

In terms of scope, the guideline applies to development proposals for new landfill facilities, operators of existing landfill facilities who currently hold a licence in accordance with the EP Act, applications to extend or amend existing landfill facilities that trigger development as defined under the EP Act or as required by an existing condition of licence, as well as closed landfill facilities.

However, it does not address the disposal of liquid waste and radioactive waste, filling of land with waste derived materials for beneficial reuse, and on-site containment of contaminated soil. The guideline however, does recognise that existing and proposed landfill facilities are each subject to a different suite of individual site-specific circumstances. The SA EPA will assess each facility on a case-by-case basis when applying the suggested measures and minimum engineering requirements to further the guideline’s objectives and required outcomes consistently across the industry.

Suggested measures and minimum requirements will be enforced through conditions of licence consistent with the environmental and regulatory risks presented by the site.

“Being flexible and listening to industry was a vital consultation strategy and required clear communication, and while there was a degree of risk in allowing industry to guide the review scope, this step established trust and confidence from the industry, which was critical to the process,” Dolan said.

“Landfill facilities incorporate a range of stakeholders, including local government authorities, consultants, engineers and licensees. Stakeholders often have differing views, so engagement with a broad range of stakeholders early, to listen and gain an understanding of their respective perspective, was invaluable.

“The industry has overwhelmingly welcomed the changes to the guideline, which is attributed to early engagement and consultation, and working with industry collaboratively. The next phase is implementation, which will be conducted largely one-on-one with licensees.”

All existing licenced landfill facilities must now comply with the guideline for all future cell developments, or within 12 months of publication. Existing leachate lagoons that do not meet the minimum specification of the guideline do not need to be updated within 12 months of publication, unless it is demonstrated that they are leaking, or they are no longer serviceable.

The SA EPA will assess the applicability of amended requirements of the guideline on a site-specific basis, taking into consideration existing approvals and site-specific risks.

Yorke Peninsula Council’s operations in this space will remain business as usual and there are no signs yet about how much it will affect them moving forward.

Yorke Peninsula Council operations manager, Stephen Goldsworthy, said the council contracts its waste out and the contractors take it out of the area to dispose of it at two different sites – at Cleanaway and Integrated Waste services sites.

“Neither of them have come back to say whether there will be any cost implications or anything like that with the updated guidelines.

“So, it will be business as usual I’d say. We are currently undertaking a cost analysis on a few ideas that council has got, but that has more to do with green organics. We also just recently undertaken an audit of our three-bin system, but we have yet to have our results back on that.

“We’re doing our homework to make sure we are on the right track in terms contamination levels of our waste and we are currently doing things the best that we can, but as far as the landfill guidelines affecting our operations go, we’re not aware of any major issues at this stage,” Goldsworthy said.