Landfills Workshop

Regulations and Best PracticesJanuary 2016

Number of Waste Disposal Grounds per Location

# of Waste

Disposal Grounds

November 2015SWANA Page 3

Fictional Landfill – Tipping Fee Range

Tipping Fee

Low Range

($/tonne)

High Range

($/tonne)5,000 tonnes/yr 143 245

10,000 tonnes/yr 112 18320,000 tonnes/yr 67 109

Benefits of Working Together – Economies of Scale

Legislation, Regulation• Environmental Management and Protection Act, 2010

– Proclaimed June 2015• Municipal Refuse Management Regulations, 1986

– Continues in force as landfill chapters of the Code were not proclaimed

• Environmental Code– Landfill closures follow the Site Assessment and Corrective

Action Plan chapters of the Code• Hazardous Substances and Waste Dangerous Goods

Regulations – May apply if storing fuel, used oil, batteries etc.

Permits

• Private and Industrial landfills are permitted as Industrial Waste Works under EMPA, 2010– Privately owned facilities require a Financial

Assurance held by the Ministry– Municipally owned facilities require submission of

financial statements verifying money set aside• Municipal landfills continue to be permitted

under MRMR, 1986– No Financial Assurance required

Requirements

• Landfill and Transfer Station chapters of the Code were not proclaimed

• Minister's approval is required for establishing, expanding, operating or closing a landfill

• Detailed technical investigation is required• Design must provide long-term leachate

containment and removal

Requirements

• Groundwater monitoring is required in most circumstances

• Operating and Closure plans are required • Landfill closures will be treated as potentially

impacted sites• Follow the Site Assessment and Corrective

Action Plan chapters

Best Practice• Is the approved (regulated) practices of another jurisdiction

– Ie: Standards for Landfills in Alberta, 2010 • Should be followed in absence of detailed guidance in

Saskatchewan– For design and construction of new sites or site expansions– Closure has detailed guidance in Code chapters

• MRMR, 1986 has general guidance but no specific practices– Ie: states an application shall indicate the surficial geology, water

table, hydraulic gradients, and baseline ground water quality in the area

Draft Landfill Code Chapter

• Should not be sole reference in applications but could be used as a general guide– Has not been proclaimed– May not have same format/requirements in future

• Established industry best practice should be referenced

• In most cases best practice from only one jurisdiction should be used– Ie: picking and choosing parts from varying jurisdictions

should be avoided

Siting• Any proponent who intends to establish or operate a landfill

must apply for a permit from the minister authorizing that person to establish a landfill.

• Ministry can be involved early in the process to assist with guidance

• Several sites should be assessed to narrow down possible locations – Consider all possible receptors, environmental and human

• Once a primary location has been chosen:– Complete a full phase II site assessment– Determine the suitability of the site for solid waste disposal

Siting

• MRMR does contain some minimal siting requirements in Section 8

• Not to be located:– Within 500m of:

• a place where food is cooked, prepared or consumed• motel, hotel, domestic residence• School, church, community center, recreation facility or public

building – Within 100m of:

• Highway or cemetery

Siting• Some factors to consider in landfill siting process:

• Working through these helps ensure that any “fatal flaws” are identified early in the process

• Early public involvement is key

Waste source Distance to generators Zoning, planning, or existing land uses

Surface water, Wetlands Proximity to groundwater resources

Soil types and conditions

Utilities Public areas such as parks

Traffic

Surrounding land use, protected areas

Endangered plant or animal species

Historical, archeological, social preservation

Visual screening and buffer zones

Floodplains Other community selection criteria

Environmental Assessment

• Environmental Assessment of Project• Does the site qualify as a development under

the Environmental Assessment Act?• Preform a Proponent Self Assessment through

Environmental Assessment Branch– Further information:

http://www.environment.gov.sk.ca/EnvironmentalAssessment/

Design

• Follow industry accepted Landfill design best practices– Ie: Alberta Code of Practice for Landfills

• Considerations:– Site layout: operational, safety, security – Liner system appropriate for waste and soil conditions– Leachate management systems– Landfill gas management– Storm water management – Any future expansion needs– Eventual Closure and final cover systems

Design

• Design to be appropriate for all types of waste to be accepted and disposed of as well as site conditions– Consider all possible sources of waste: household,

commercial, institutional, industrial• Plan on a regional scale and design sites for waste

stream– Ie: may have once central solid waste site but may

include an inert landfill in region to cut down on transport

Design

• What designated areas need to be planned/considered– Consider efficiencies and security

• Will any wastes requiring special handling be accepted?

• Will Hazardous Substances and Waste Dangerous Goods Regulations need to be considered? – used oil, batteries, glycol, fuel storage

Design• Once all information has been gathered submit application

with all supporting documentation and design information to the Ministry for review – Ensure any and all documentation that is reference is appended

to the application for reference • MOE will review and may request additional information,

clarification, changes etc. before a permit to construct is issued – Review period is general 6-8 weeks with each submission– Allow adequate time in planning for review

• Permit to Construct is issued to the owner of the site

Construction

• Communication with Ministry should be maintained before, during and after construction

• When construction is completed verification will be required– As built drawings specifying any minor changes– Letter stating build as per specifications

Operations

• Once construction is completed an application for a permit to operate will be required

• Required submission of an operations plan for review and approval

• Operations plan can be submitted along with construction application package or after

• The operations plan will be a living document to be reviewed and updated annually

Operations Plans• Establishes operations routine to improve the efficiency of the operation

and maintain compliance• Will identify permit requirements • Will specify daily, weekly, monthly activities• Shall include, at a minimum, procedures for:

– Basic site information, hours of operation, equipment– Waste acceptance, placement, cover, compaction– Surface water management– Nuisance controls: litter, animals, dust, etc. – Record keeping, site inspections, annual reporting – Monitoring and maintenance programs for groundwater, leachate etc.– Contingency plans for identified exceedances – Emergency response plan– Current landfill layout plan including elevations and contours

Environmental Monitoring

• Generally can include:– Groundwater– Landfill gas– Leachate– Surface water

• Potential that not all sites require groundwater monitoring– Justification and sign off from a qualified person

would be required

Environmental Monitoring

• Information on monitoring programs as well as interpretation is included in annual reporting

• Stating analytical results is not enough– Analytical results without interpretation will not

meet permit requirements • Are there exceedances? Are there impacts?

What do they mean? Recommended Actions?

Expansion

• “A horizontal increase outside of the existing approved waste footprint OR volumetric increase of the designed waste disposal capacity.”– Digging a new cell– Switching from trench and fill to mounding/area

method• Previous perception was that entire site was

“approved” – this is not correct

Expansion

• Similar process to Landfill Design• Site is already “chosen” if expanding at current

location• If planning any major changes in waste

acceptance should still preform EA Self Assessment

• Application to include site assessment information and landfill design (operations plan)

Closure

• Should be closed if:– no longer intending to accept waste– waste has not been accepted for 2 consecutive

years– site is at capacity

• Notification to ministry of intent to close a landfill at least 180 days prior to closure

• Once closure plan is approved an Approval will be issued for decommissioning of the site

Closure• Initial first steps:

– Provide notice to users, including signage on site– Clean up site of any litter, recyclable material etc.– Provide initial cover of waste

• Submit Closure Plan for review and approval– Allow 6-8 weeks for initial review and any subsequent

discussions• Closure plan should:

– Minimize the need for further maintenance – Provide a final state that will have the least potential for future

impact on the environment

Closure• Closure Plan should be considered in advance and ideally

a draft is part of the design plan– Allows for advance budgeting for costs and materials – Planning for remaining site life allows for appropriate

calculation of gate fees to ensure money is set aside • For large sites closure is done in a progressive manner • Closure Plan will include:

– Site Assessment Information • Follow Site Assessment Chapter requirements

– Corrective Action Plan• Follow Corrective Action Plan Chapter requirements

Closure

• Ministry recognizes this is costly process• Municipality should provide notice and

complete initial first steps to clean up site• Can discuss appropriate timelines for

submission of required information– Completion of site assessment– Implementation of corrective actions

Closure• Key information to include in Closure Plan:

– Owner contact information– Description of all users of the site – Total quantity and description of waste disposed– Period of operation– Site plan showing adjacent land, land uses, location of drinking water

wells, surface water bodies w/in 1km– Geographical location of boundary, waste footprint, monitoring

wells, leachate holding ponds, storm water ponds etc. and current status

– Estimate of remaining contaminating lifespan• Inferred from interpretation of environmental monitoring or site assessment

Closure

• Delineation required– Source of contamination (what is your waste

footprint)– Potential/identified impacts

• Final cap cover– Required over source to prevent

infiltration/minimize leachate generation– Its this required over entire site?

Closure

• Key activities to include in corrective action plan:– Final site topographic plan– Site drainage plan– Source of cover material– Vegetative cover and landscaping plan– Closing sequence for phased operations– Post closure maintenance and monitoring

Closure

• Key environmental controls in corrective action plan:– Final cover system (clay or otherwise)– Gas control system (if needed)– Groundwater monitoring system – Leachate monitoring and collection as needed

• Should also include a schedule of activities and tasks to be completed during post closure care

Closure

• Post Closure/Long term Care– Continue to collect and treat leachate– Provide groundwater monitoring and any contingency

action as needed– Provide gas migration and emissions control if needed– Final cover maintenance– Maintenance of any drainage and erosion control

features • May be required for as long as the estimated

contaminating life span of the site

Unlawful Dump Sites

• Unlawful dumping = Non Permitted Landfills• Will be investigated by MOE Officers.• Waste including C&D waste which has been

unlawfully disposed of at a non-permitted site is a contravention of The Municipal Refuse Management Regulations and The Environmental Management and Protection Act, 2010 (EMPA, 2010).– regardless if placed on private or public property. – burning of mixed waste including C&D waste without a

permit is prohibited

Unlawful Dump Sites

• Regulations allow for farmer to dispose of own household waste on own land

• Does not allow for business waste to be accepted to own land or waste from others– C&D waste – recycling options– Can include fill, concrete, asphalt etc.

• Illegal dumping – permission is given for waste to be disposed of – landfilling w/o permit

• Littering – permission is not given, waste is dumped by unknown persons

Unlawful Dump Sites

Unlawful Dump/Burn Sites

Unlawful Dump/Burn Sites

Unlawful Dump/Burn Sites

• May be asked/ordered to clean up and conduct a site assessment by a QP, in particular if material was burnt. – discharges - any at site?– was material just dumped or was it burnt or visible

spill of materials?– Site assessment/VSA chapters of code applied.– Corrective Action Plan required.

General Information

• Saskatchewan Environmental Quality Guidelines– https://envonline.gov.sk.ca/seqg-search/– SEQG now has criteria for Soil Disposal at Landfills– Limits for maximum allowable concentration for

use as daily or intermediate cover

General Information

• Landfill Guidance Documents– http://www.environment.gov.sk.ca/solidwaste

• Online Business– https://envonline.gov.sk.ca/login/

• Assistance/General Inquiries – http://environment.gov.sk.ca/contact – 1-800-567-4224