GEHO0407BMHO e e

Guidance for the Landfill Sector
Technical Requirements of the Landfill Directive and Integrated

Pollution Prevention and Control (IPPC S5.02)
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prior permission of the Environment Agency.
April 2007
Environment Agency Guidance for the Landfill Sector 1

Executive Summary
Integrated Pollution Prevention and Control (IPPC) is a regulatory system that employs an
integrated approach to control the environmental impacts of certain industrial activities. It involves
determining the appropriate controls for industry to protect the environment through a single
permitting process. To gain a permit, operators will have to show that they have systematically
developed proposals to apply appropriate techniques taking account of relevant local factors.
The European Commission has not produced a best available techniques reference document
(BREF) for landfill. Instead the Landfill Directive provides certain technical standards for landfill sites.
Where the Landfill Directive does not provide the relevant technical requirements then the general
principles of the IPPC Directive, must be applied. This guidance sets out measures that are
considered appropriate to meet the relevant legal and technical requirements for PPC landfills.
The aims of this document are to:
• provide a clear steer for operators to help ensure they address all aspects of the Landfill
Regulations, PPC Regulations and other relevant legislation
• minimise the effort by both operator and the Environment Agency in the permitting of an
installation by expressing an interpretation of the Landfill Regulations requirements and clear
standards
• improve the consistency of applications by ensuring that all relevant issues are addressed;
• increase the transparency and consistency of regulation by having a structure in which the
operator's response to each issue, and any departures from the default standards, can be seen
clearly.
To further assist, separate guidance relevant to all industry sectors is available on a range of topics
such as noise and odour. There is also technical landfill guidance covering the management of
landfill gas, hydrogeological risk and monitoring. The landfill technical guidance is available free
through the Environment Agency website.
1 Environment Agency Guidance for the Landfill Sector

Contents
Contents 2
1. Introduction 3
1.1 Aims and scope of this guidance 3
1.2 Understanding the Landfill Directive and IPPC 3
1.3 Making an application 4
1.4 Installations covered by this guidance 5
1.5 Installation Issues 6
1.6 Timescales 6
1.7 Key Issues for the landfill sector 7
1.8 Technical overview 8
1.9 Landfill permitting 12
2. RISK ASSESSMENT 24
2.1 Risk assessment 24
2.2 Site investigation 25
2.3 Groundwater protection 26
3. MANAGEMENT 27
3.1 Management techniques 27
3.2 Accidents and their consequences 29
3.3 Finance 30
3.4 Energy 31
3.5 Security 32
4. OPERATIONS 33
4.1 Waste acceptance 33
4.2 Landfilling engineering 35
4.3 Closure, Aftercare And Surrender 51
5. EMISSIONS AND MONITORING 55
5.1 Emission benchmarks 55
5.2 Emission of landfill gas 55
5.3 Emissions to water 55
5.4 Standards and obligations 55
5.5 Units for benchmarks and setting limits in permits 56
5.6 Nuisance 57
5.7 Monitoring 64
6. INFORMATION 68
7. GLOSSARY OF TERMS 70
8. REFERENCES 74

1. Introduction
1.1 Aims and scope of this guidance
This guidance will be reviewed and updated as necessary based on changes to the legislation and
best practice.
This guidance aims to provide landfill operators and the Environment Agency’s officers with advice
on standards of operation and environmental performance relevant to the landfill sector. This
guidance provides recommendations for the standards that are likely to deliver good environmental
outcomes. They are not exhaustive and other mechanisms for achieving the same objectives are
available and may be proposed. If all the recommendations in this guidance are proposed in a
landfill permit application, delays (that may result from establishing an understanding of the
alternatives) in the determination of that application will be minimised.
This guidance aims to assist the landfill operator in the preparation of applications for Pollution
Prevention and Control Regulations 2000 (‘PPC’) landfill permits and Environment Agency officers
in the assessment of those applications and the development of a compliance regime. The use of
techniques and the setting of emission limit values at the default values quoted in the guidance are
not all mandatory, except where they are statutory requirements from the legislation. These are
identified throughout in shaded boxes The Environment Agency will consider the relevance and
relative importance of this guidance to the installation concerned when making technical
judgements about the installation. Where default standards are used in an application, the
Environment Agency is likely to accept these with little technical assessment. Any departures from
the default standards will need a detailed, site-specific technical justification.
The guidance also aims to provide a clear structure and methodology for operators to follow to
ensure they address the relevant requirements of the PPC Regulations, the Landfill (England and
Wales) Regulations 2002 (‘the Landfill Regulations’) and other relevant Regulations, that are in
force at the time of writing.
The guidance applies to all PPC landfills with the exception of underground storage (as defined in
Article 2(f) of the Landfill Directive).
Some landfills for certain waste types (e.g. landfills for inert waste) may have different
requirements. The Landfill Regulations do not apply to waste management licensed sites which
finally ceased to accept waste for disposal before 16 July 2001
1.1.1 Waste management licensed landfills
This guidance represents best practice at waste management licensed sites, particularly in relation
to measures such as capping and gas management.
1.2 Understanding the Landfill Directive and IPPC

The purpose of the IPPC Directive (96/61/EC) is to achieve integrated prevention and control of
pollution. It lays down measures designed to prevent or, where that is not practicable, to reduce
emissions to air, water and land in order to achieve a high level of protection of the environment
taken as a whole. Member States are obliged to take necessary measures to ensure that
installations are operated in such a way that,
‘all the appropriate preventive measures are taken against pollution, in particular through the
application of the best available techniques.’
The use of the best available techniques (‘BAT’) is a means by which operators can ensure that all
appropriate preventive measures are taken against pollution.

The main aim of the Landfill Directive (1999/31/EC) is to prevent or reduce as far as possible the
negative effects of landfilling waste on the environment and human health. It contains some
technical requirements for the development, operation and closure/ aftercare of all classes of
landfill. Article 1(2) of the Landfill Directive explains,
’In respect of the technical characteristics of landfills this Directive contains, for those landfills to
which the [IPPC] Directive (1996/61/EC) is applicable the relevant technical requirements in order
to elaborate in concrete terms the general requirements of that Directive. The relevant
requirements of the IPPC Directive shall be deemed to be fulfilled if the requirements of the Landfill
Directive are complied with.’
The Landfill Regulations reflect this by dis-applying BAT from the landfill elements of an installation,
requiring instead that the standards specified by the Landfill Regulations be applied.
The effect of this is that the technical requirements set out in Annex 1 of the Landfill Directive take
the place of the technical measures referred to in Articles 9(3) and (4) of the IPPC Directive for
landfills subject to the IPPC Directive.
Where the Landfill Directive and Regulations do not provide the relevant technical requirements
then where relevant, the general principles of the IPPC Directive, including ‘BAT’ must be applied.
BAT will not be applicable to one off activities such as landfill engineering, as best practice is
applied during the design and development of each new phase or cell. BAT will be applicable to
activities at a landfill that are ongoing, where a continual improvement over time can be achieved.
This will include operation of the non-landfill parts of the installation such as leachate and landfill
gas management.
1.2.1 Relationship with other guidance
There are a large number of technical and regulatory guidance documents for landfills (Section 7).
There are also PPC guidance documents that are relevant across all industry sectors, including
landfill. This document summarises the main technical requirements for landfills. Reference is
made to more detailed guidance where appropriate.
1.3 Making an application

A landfill permit application has to:
- assess the potential environmental impact (section 2)

- address the management, operations and emission and monitoring of the installation (sections 3,
4 and 5);
- demonstrate that the proposed techniques are appropriate for the installation.
In an attempt to focus application responses to the areas of concern to the Environment Agency,
i.e. those with the greatest potential impact on the environment and human health, a sector specific
application form for landfill PPC permits has been introduced.
In addition to completing the PPC permit application form, a PPC permit application for a landfill will
have to include the following documentation for it to be considered duly made:
- the conceptual model of the site;

- a site report;
- scale plans and drawings of the site;
- hydrogeological risk assessment;
- stability risk assessment;
- landfill gas risk assessment;
- nuisance and health risk assessments including an assessment of particulate matter;
- ecological assessment (if the site is close to a European Habitats site).

Section 1 of Part B of the application form asks the applicant to describe the landfill installation and
its environmental setting (the ESID - Environmental Setting and Installation Design) and the risk
assessments that have been undertaken during the preparation of the application. In Section 2 of
Part B, the applicant is asked to detail the specifications (both engineering and procedural) that will
be followed to ensure that the landfill operates in accordance with regulatory requirements. Any
technical standards will form the regulatory specification part of the permit.
To ensure a consistent approach and to assist applicants in the preparation of these key
documents, the Environment Agency has prepared templates which illustrate how the requirements
of Part B of the PPC permit application form for the landfill sector can be met. Applicants may
choose a different format for these documents but it is recommended that their technical content
should be the same as set out in the templates.
In addition to the templates, the Environment Agency has prepared specific guidance on the
contents of the risk assessments (section 2).
1.4 Installations covered by this guidance

1.4.1 PPC Landfills
This guidance relates to installations containing the activities listed below, as described in part A(1)
of schedule 1 to the Pollution Prevention and Control Regulations (England & Wales) 2000.
Section 5.2 - Disposal of Waste by Landfill
Part A(1)
(a) The disposal of waste in a landfill receiving more than 10 tonnes of waste in any day or with a
total capacity of more than 25,000 tonnes, excluding disposals in landfills taking only inert waste.
(b) The disposal of waste in any other landfill to which the 2002 Regulations apply.
Landfills which fall outside IPPC (non- IPPC Directive landfills) are those listed as 5.2 Part A(1) (b)
i.e.
- landfills receiving less than 10 tonnes per day or with a total capacity of less than 25,000 tonnes;
- all landfills taking only inert waste.
Although non-IPPC landfills will not have to meet the requirements of the IPPC Directive, they will
require PPC permits and are subject to the Landfill and PPC Regulations. The IPPC requirements
identified in this guidance are considered to be best practice for non-IPPC landfills.
1.4.2 Defining the installation
The installation includes the main activities as stated above and also associated activities which
have a technical connection with the main activities and which may have an effect on emissions
and pollution. These may involve activities such as:
- pre-treatment of waste for disposal
- landfill gas management and flaring
- leachate treatment and storage
- landfill gas utilisation plants
The landfill activity itself is taken to include operations such as wheel-washing, waste reception,
litter collection and other similar operations that are necessary to effectively operate a landfill.
The impact of the activities on the environment may be wider than just the on-site activities. This
guidance and the PPC Regulations cover issues downstream of the installation e.g. the final
disposal of leachate off-site. Operators are advised to discuss the extent of the physical site which
is contained within the installation with the Environment Agency prior to preparing their application.

Where activities are carried out in conjunction with the main activities and are not covered in this
guidance note (e.g. hazardous waste treatment), reference should be made to:
- other relevant PPC Technical Guidance Notes and,
- other relevant guidance notes issued under EPA 1990
Further guidance can be found in Landfill Directive Regulatory Guidance Note (RGN) No.16
(Reference 54) and government IPPC: a Practical Guide (Reference 25).
1.5 Installation Issues

Where there is more than one operator of the installation, the proposed techniques and measures
(including those to be taken jointly by more than one operator) must ensure the satisfactory
operation of the whole installation.
In some cases it is possible that actions that benefit the environmental performance of the overall
installation will increase the emissions from one permit holder’s activities. One example is where
there is a separate operator for the landfill gas utilisation plant. If the landfill gas is extracted solely
to provide fuel for the engines this may benefit the emissions from the engines but may impact
upon landfill gas migration control. Separate landfill gas extraction systems may be required for
migration control and for gas utilisation.
Recommendations for installation issues

1 The operator should consider possibilities for minimising impact to the environment as a whole, by operating together
with other permit holders. Possibilities include:
- Communication procedures between the various permit holders; in particular those needed to ensure that the risk
of environmental incidents is minimised;
- Ensuring the effective extraction of landfill gas;
- the combining of leachate to justify a combined or upgraded effluent treatment plant;
- the combining of gas flaring/energy generation plant;
- the avoidance of accidents (see section 3.2) from one activity which may have a detrimental knock-on effect on the
neighbouring activity;
- land contamination from one activity affecting another.
1.6 Timescales
1.6.1 Permit review periods
PPC permits can be reviewed or varied at any time. In addition, the Environment Agency is
required to review the conditions of permits ‘periodically’ but at least every 8 years. The
Environment Agency propose to review permits every six years. This period will be kept under
review.
The Groundwater Regulations require a review of authorisations at least once every four years.
This will be a review of the hydrogeological risk assessment by the operator.
1.6.2 Risk assessment review
Ongoing monitoring is an essential and integral part of the risk assessment approach to landfill
management. The risk assessment will have identified receptors and pathways for which
mitigation measures will have been incorporated into the landfill design. One of the objectives of
monitoring is to determine whether the assumptions made in the conceptual model were correct
and whether the mitigation measures are performing to specification. Most of the impacts of a
landfill are more difficult and expensive to remedy the longer they remain uncorrected. The data
gathered during the operation of the site should be used by the operator to review the validity of the
conceptual plan, the design assumptions made during the planning and development processes,
and to make changes where necessary.

The landfill permit requires that the operator undertakes an annual review of monitoring data
against the assumptions made in the risk assessments submitted with the PPC permit application.
1.6.3 Improvement timescales for existing landfills
Unless subject to specific conditions in the permit, improvement timescales will be set in the
Improvement Programme of the permit, based on two categories:
1. ‘Good-practice’ requirements, such as, management systems, housekeeping measures to

prevent fugitive or accidental emissions, and adequate monitoring equipment. Many of these
require relatively modest capital expenditure and so, with studies aimed at improving
environmental performance, they should be implemented as soon as possible and generally
well within 1 year of issue of the permit.
2. Larger, capital-intensive improvements, such as major changes to landfill gas management

systems or to leachate management and treatment systems should also be completed within 3
years of permit issue. NB For large projects that involve a change in land use (e.g. addition of
a leachate treatment plant) time scales must consider time taken to obtain necessary planning
permission.
Local environmental impacts may require action to be taken more quickly than the indicative
timescales above, and requirements outstanding from any improvement programme in a previous
permit should be completed to the original time-scale or sooner.
Where adequately justified, longer time-scales may be approved. For example, where an activity
already operates to a standard that is close to an appropriate standard an extended time-scale may
be acceptable. Unless there are statutory deadlines for compliance with national or international
requirements, the requirement by the Environment Agency for capital expenditure on
improvements and the rate at which those improvements have to be made, should be proportionate
to the environmental benefits that will be gained.
The operator should include in the application a proposed programme in which all identified
improvements (and rectification of clear deficiencies) are undertaken at the earliest practicable
opportunities. The Environment Agency will assess the relevant standards for the installation and
the improvements that need to be made, compare them with the operator’s proposals, and then set
appropriate improvement conditions in the permit.
1.7 Key Issues for the landfill sector

1.7.1 Waste acceptance
The understanding and control of waste types is essential in managing the risk from the landfill.
Waste Acceptance Criteria (WAC) and Waste Acceptance Procedures (WAP) are required for all
classes of landfill to ensure that:
- Wastes accepted are correctly described, coded and classified to ensure that hazardous wastes,
stabilised non-reactive hazardous wastes, non-hazardous wastes and inert wastes are disposed
of at the correct class of landfill.
- Wastes accepted are not prohibited and have undergone appropriate treatment (where
necessary) as required by the Landfill Regulations.
- Appropriate limits are placed on the waste types and composition acceptable at the landfill.
- The composition and behaviour of the waste is understood to an appropriate level and
procedures are in place to control waste inputs to a landfill.
More details are available in Environment Agency guidance, (reference 56)
1.7.2 Groundwater protection
All landfills must meet the requirement of the Groundwater Regulations - to prevent the direct
discharge of List I substances into groundwater and to prevent the pollution of groundwater by

substances in List II. PPC also require that installations are operated in such a way that no
significant pollution is caused, which for groundwater may incorporate substances beyond those in
Lists I and II of the Groundwater Regulations.
The Landfill Regulations (Schedule 2, paragraph 3(6)) require that leachate shall be collected,
extracted and treated to an appropriate standard unless the Environment Agency decide the landfill
poses no potential hazard to the environment in view of its location and the waste types involved.
1.7.3 Landfill gas management
All landfills receiving biodegradable wastes must have the following three elements:
- barriers to surface emissions and sub-surface migration of landfill gas;

- an active gas extraction system to achieve the maximum practicable collection efficiency;
- a system of gas treatment meeting emission standards.
Although biodegradable waste is not acceptable at landfills for hazardous waste, gas management
from these landfills must meet the three elements above. Passive venting of landfill gas is unlikely
to be acceptable because of the impact of methane on global warming.
1.7.4 Quality assurance
A quality approach should be adopted in all construction and operations, with construction quality
assurance (CQA) of all major engineering elements.
1.7.5 Integration of pollution control systems
The management of direct rainfall, surface water, groundwater, leachate, gas and particulate
matter are interrelated. The individual elements are discussed in Section 2 but the designer and
operator must consider these:
- as an integrated whole;
- such that no unacceptable risk to any environmental media is posed over the entire lifecycle of
the landfill until completion.
This consideration must also include stability and settlement.
Operational management must also consider contingencies for redundancy or failure of any
element of the management systems. For example, the treatment of the deposited wastes and the
management of leachate should any artificial liner fail in the medium term.
1.7.6 Landfill stabilisation
An important objective of landfill design is to return the products of waste degradation to the
environment in a controlled way, at a rate that the environment can accept without harm. The main
mechanisms for the removal of those decay products are the leachate and gas management
systems.
1.7.7 Sustainable development
Control measures should not place unnecessary burdens on future generations, and passive
measures should be used where possible.
1.8 Technical overview

The following concepts provide a framework whereby the technical requirements of the Landfill and
IPPC Directives may be met in an integrated way:
- the landfill life cycle;

- sustainable development in relation to landfills;
- development of the landfill design including the conceptual model.
1.8.1 The landfill life cycle
It is crucial that a landfill is considered as a continuous project, from concept, through planning,
design, construction and operation to closure, aftercare and completion. Information gathered for
each stage, and decisions and outputs arising, must be integrated with previous and subsequent
stages to continuously update the understanding of the site, its situation and the nature and impact
of its operations.
The life cycle of a landfill involves three main phases:
- development, which entails the stages from the initial concept through site investigation,
planning, design and the obtaining of necessary regulatory approvals/permissions;
- operational, which involves construction (or preparation) of the landfill and the deposit of waste;
- closure and aftercare, when the landfill has ceased taking waste for disposal and restoration
and aftercare maintenance measures are carried out until the permit is surrendered.
The planning and design stages should provide clear statements of how the objectives are to be
met. Landfill practice is a dynamic science and the life of a new landfill will span several decades or
longer. During planning and design, consideration should be given to changes that are likely to
occur over the whole life of the landfill, and provision made for these, where appropriate.
Procedures for continuous review and the incorporation of necessary changes should be included
in the operational and post-closure phases. Details of revisions and amendments to the design and
construction proposals must be recorded and should show how these relate to the project
objectives.
Closure and aftercare are discussed further in Section 2.11.
Article 7 of the Landfill Directive requires that the permit application contain details of the whole life
cycle of the landfill. These requirements can be found in Schedule 4 of the PPC Regulations.
Article 7 of the Landfill Directive
Member States shall take measures in order that the application for a landfill permit must contain at least particulars of the
following:
a. the identification of the applicant and of the operator when they are different entities;
b. the description of the types and total quantity of waste to be deposited;
c. the proposed capacity of the disposal site;
d. the description of the site, including its hydrogeological and geological characteristics;
e. the proposed methods for pollution prevention and abatement;
f. the proposed operation, monitoring and control plan;
g. the proposed plan for the closure and after-care procedures;
h. where an impact assessment is required under Council Directive 85/337/EEC of 27 June 1985 on the assessment of
the effects of certain public and private projects on the environment, the information provided by the developer in
accordance with Article 5 of the Directive;
i. the financial security by the applicant, or any other equivalent provision, as required under Article 8(a)(iv) of this
Directive.
Following a successful application for a permit, this information shall be made available to the competent national and
Community statistical authorities when requested for statistical purposes.

1.8.2 Sustainable development for landfills
In the context of individual landfill sites, sustainable development requires the optimisation of the
design and operation of the site in order to achieve necessary environmental protection and
beneficial afteruse, in a cost-effective manner, whilst minimising the burden on future generations.
For landfill, moves towards sustainable development are achieved by:
- using waste to construct a landform with a beneficial after use;

- reducing the input of reactive wastes, or providing measures to accelerate the stabilisation of
such waste;
- careful planning of appropriate resource usage in design, construction and operation;
- controlling waste disposal operations and adopting appropriate pollution control measures to
prevent unacceptable adverse effects on the environment in both the short and the long-term;
- consideration of costs and benefits;
- ensuring the geotechnical stability of the waste and associated structures;
- ensuring that long term control measures do not place unnecessary burdens on future
generations, e.g. by the use of passive measures such as physical barriers, gravity drainage
and other unpumped solutions in place of long term pumping or other active management
techniques.
Special considerations for landfill of hazardous waste
Investigation of landfill practice in Europe suggests that the main potential problem associated with
managing landfills for hazardous wastes will be the collection, treatment and disposal of leachate.
Whilst this is likely to be technically feasible, it may require the application of techniques which are
unfamiliar in the UK over an extended timescale.
The modelling work upon which the waste acceptance criteria are based assumed the ongoing
removal of leachate to a treatment plant. Compliance with the waste acceptance criteria may not,
of itself, result in a landfill that meets sustainable development criteria.
Operators will therefore need to think carefully about how to move landfill of hazardous wastes
towards sustainable development criteria. In particular, they should balance the treatment given to
the waste with the need for long-term management and monitoring of the landfill.
1.8.3 Landfill design and Conceptual Model
Design overview
In this section the term ‘design’ relates to the landform and all the engineering, operational,
restoration and aftercare elements needed to create it. The ‘conceptual model’ should describe the
design, construction and operation of a landfill and the nature of baseline environmental conditions,
as well as identifying possible sources, pathways and receptors and the processes that are likely to
occur along each of those source-pathway-receptor linkages. The conceptual model for the landfill
should cover all environmental media.
The landfill must gain approvals from the Waste Planning Authority (WPA) as well as the
Environment Agency, and the development of the conceptual model should therefore respond to
the requirements of both.
The iterative process is likely to include the following:

- initial concept;
- pre-application discussions with the Environment Agency and WPA;
- desk studies and fieldwork;
- preparation of the planning application and environmental statement;
- preparation of the PPC permit application;
- preparation of construction specifications and details of operational procedures;
- modification in response to monitoring and operational experience.

Detailed design
The level of detail required at each stage varies according to the design elements involved. Some
aspects, such as the landform, will need to be detailed at the planning application stage. Some,
such as the in-principle construction of leachate extraction wells, will need to be detailed in the
permit application. Other detail, such as the basal drainage layout of a future phase, may be left for
agreement when the time to prepare that phase approaches.
Both infrastructure and operations require careful planning. The main features should be
determined by the operator and the designer at an early stage during the planning process and
consolidated as part of the PPC permit application. The Environment Agency is likely to have
comments on aspects of the design during the planning processes, and in particular the risk
assessments carried out on the major design features of the proposal.
The information provided in the permit application will be a refinement of the work that will have
been undertaken in the development of the conceptual plan for the planning approval process. The
designer must consider the intended method of operation in designing the site and its
environmental protection measures, and their phased development. It is essential that the operator
is completely aware of the designer’s objectives for operational issues, and that the operator does
not vary from them without detailed review and, where possible, discussions with the designer.
A greater level of detail may be required for the translation of the design into the specification and
drawings needed for construction purposes.
The detailed design of a successful landfill requires consideration of all the elements summarised
below, and reconciliation of potential conflicts of priority, where those exist, so far as is possible:
- profile of the final landform, (including consideration of slopes stability, visual impact, void
capacity, settlement, aftercare management and waste density);
- phasing of the development;
- site infrastructure, incorporating safe traffic access and haul routes, all the facilities for
reception and handling of waste and administration of the landfill site;
- materials requirements and materials balance;
- lining system, performance (durability and monitoring), stability, and relationship with leachate
management systems;
- groundwater and surface water management;
- leachate management:
- landfill gas management;
- control of noise and dust;
- preparatory works required prior to filling with waste;
- monitoring requirements (groundwater, surface water, leachate, gas etc);
- standards for implementation, including quality management and CQA;
- closure, restoration, aftercare, afteruse and completion.
Table 1.1 Key factors affecting a landform

Key factors Potential interactions
Maximum and minimum surface Visual impact
gradients, and landscaping requirements afteruse
re: surrounding land restoration planting
direction of phasing
stability
surface water and erosion control
leachate and landfill gas management and monitoring
Capacity for waste waste type/site classification
site volumes
groundwater levels
materials balance
cost-effectiveness
gas and leachate issues especially very deep sites

Key factors Potential interactions
Settlement site volumes
afteruse
restoration
waste degradation rates
waste consolidation potential
interaction with engineered structures and lining systems
desired final restoration profile
Waste density site volumes
leachate and gas removal
cost-effectiveness
settlement
Integration of the design elements
The design must identify the interactions between all the design elements. The design process
must consider and acknowledge the interactions between these elements. There may be a need to
reconcile potential conflicts of priority. For example, the management of direct rainfall, surface
water, groundwater, leachate, gas, particulate matter and stability are interrelated; and so dealing
with risk to groundwater cannot be conducted at the expense of an unacceptable landfill gas risk.
Further examples of these potential interactions are given in Table 1.2.
Table 1.2 Potential interactions between design elements

Advantages of phasing Potential interactions
Progressive use of the landfill area, such that at any given May limit operational space.
time parts of the site may be in the process of being: Direction of phasing to be resolved between:
- capped and restored - screening for visual, wind and noise
- capped - location of materials resources
- actively filled - preference for leachate drainage to start at lowest point
- prepared to receive waste, or - access routes – start at furthest point or travel over
- undisturbed restoration?
to avoid frequent and disruptive preparatory works, each NB may be impracticable in deep sites.
phase should last 12 - 18 months.
Progressive restoration Potential instability in part-filled void, where support from
future waste is absent.
Progressive excavation of on-site materials, storage or
restoration materials, and minimisation of double handling
Minimises area required for active landfill operations and
concentrates activities within a sequence of defined areas
Phases development and restoration expenditure Need for protection of temporary edge of lining/capping
Reduces leachate generation by minimising areas of active Need to protect against leachate overflow into unlined
and unrestored tipping, and keeping them separate from areas
clean surface water
Limit delays to active gas extraction
Progressive installation of leachate and gas controls
May be a requirement of planning permission Achievement of agreed landscape plan
Can reduce impact on local amenity e.g. visual, noise, dust,
litter etc.
1.9 Landfill permitting

The Environment Agency has developed permit templates for all principal sectors regulated under
PPC. This includes a specific template for landfill that reflects differences from other PPC sectors
as introduced by the Landfill Regulations.

1.9.1 Permitting – general issues
The Environment Agency is required to act reasonably in all it compliance assessment and
enforcement activities. The tables in section 1.9.2 below include some detail as to how this will be
interpreted for the purposes of assessing compliance against permit conditions.
Operators of PPC permitted installations are required to notify the Environment Agency of changes
to operations under the PPC Regulations 2000, Regulation 16. On the basis of the scale of the
change, the Environment Agency will decide whether the change constitutes an administrative,
simple standard, standard or substantial variation in accordance with its charging scheme.
1.9.2 Permit structure
The structure of the permit template is as follows:
Introductory Note
Permit cover
Section 1 - Management
Section 2 – Operations
Section 3 – Emissions and monitoring
Section 4 – Information
Schedule 1 – Operations
Schedule 2 – Site
Schedule 3 – Permitted waste types
Schedule 4 – Emissions and monitoring
Schedule 5 – Reporting
Schedule 6 – Notification
Schedule 7 – Interpretation
Introductory note
The introductory note provides a summary of the permit to the operator and the public. It is a brief
non-technical description of where the site is, who operates it, what the activities are and the main
environmental issues at the site. The following items will generally be included in the Introductory
Note:
• The PPC Schedule 1 listed activity undertaken at the installation; including a brief overview of
any associated activities.
• Any Schedule 1 listed activities or associated activities that have significant effect on
emissions.
• The scale of the operation e.g. the waste inputs, throughput and total capacity of the landfill.
• Releases of significance to all media, including noise.
• Any environmental considerations required due to the location of the site e.g. proximity to a
river or Natura 2000 site.
Status Log of the Permit
The status log provides a list of the relevant applications, further information notices, variations,
transfers, etc. that affect the operation of the installation under the permit. It will be updated each
time the permit is changed e.g. on transfer, or when a variation is issued. The variation status log
provides an audit trail back to the original permit. The status log will therefore provide clarity to the
public and also help in the identification of all relevant files/ information relating to the permit since
the original application.
Other permits and superceded permits
Three tables set out details of:
• any other permit (regulated by the Environment Agency) which relates to the same installation;

• any Environment Agency licences, consents or authorisations that have been superceded in
their entirety by the PPC permit/s, for example, a waste management licence; and
• where it is appropriate details of other existing permissions for activities that may take place on
the site which are not covered by PPC permit(s).
Inclusion of this information provides clarity to the public and also serves to ensure that the whole
installation has the correct authorisations in place and there is no duplication.
The Permit cover
The permit cover details the permit number and the notice of determination and it is signed and
dated.
Signature. The permit must be signed by a person approved by the Environment Agency to sign.
That person should be satisfied that the necessary process requirements set out in ‘Determining
an IPPC Permit or Variation Application’ Work Instruction and any landfill PPC permitting work
instructions have been followed.
Date of Signing. The date of signing brings the permit into effect. Any previous licences or
authorisations applicable to the installation activities will cease to have effect from this date to the
extent that they are superseded by controls imposed by the permit. It is inappropriate to use a
different ‘effective date’ for the operation of the permit, because there would then be no licence or
authorisation in force at all for the period between signature and the permit taking effect. The
Environment Agency’s work instruction, ‘Determining an IPPC Permit or Variation Application’,
suggests that, where possible, the operator should be provided with a draft permit a minimum of a
few days before signing and for the permit to be sent to it as soon as possible after signing. This is
intended to avoid any problems with the permit coming into force immediately on signing.
Permit conditions
The table below provides some guidance on the purpose of the conditions. It follows the structure
of the conditions shown in the landfill permit template version 4. The exact wording of the condition
must be considered and any references to the application or the schedules, when they are being
enforced. Additional guidance on appropriate measures is available later in this document.
Section 1 Management
Condition Guidance Schedule

1.1 General Management
1.1.1 Requires an operator to manage and operate their site in accordance
with a management system that identifies and minimises risks of pollution.
The site must be managed by people who are competent and the operator
must ensure that there are sufficient numbers of people available.
1.1.2 Records must be kept to demonstrate compliance with that
management system.
1.1.3 A copy of the permit must be kept available.
1.2 Accidents that may cause pollution

The condition reflects the general requirement in Regulation 8(2)(c) of the
Landfill Regulations that the installation should be operated in such a way
that, ‘the necessary measures are taken to prevent accidents and limit their
consequences’. An assessment of the applicant’s proposals must still be
made in accordance with the corresponding section of the relevant technical
guidance. The condition requires the operator to operate in accordance with
and maintain the plan submitted with/ described in the application (this is a
form of incorporation). In condition 1.2 of the template permit there is an on-
going requirement to maintain the information submitted in the relevant part
of the application.

1.3 Finance
1.3.1 Identifies the financial provision agreement made by the operator and
requires it to be maintained. The condition refers to a specific agreement by
use of a date. This is to ensure that an application to vary the permit is made
to fund any review of the performance agreement.
1.3.2 Requires the charges for disposal of waste to cover the costs of setting
up, operating, closure and aftercare of the landfill, as required by The Landfill
Regulations, Regulation 11.
[An optional condition for existing sites reflects that operators of existing sites
may be compromised by the requirement to reflect aftercare cost in the
charges it makes for disposal].
1.4 Energy Efficiency

These conditions reflect the general principle (Landfill Regulations,
Regulation 8(3)(b)(ii)) that the installation should be operated in such a way
that, ‘energy is used efficiently’. In addition, energy efficiency is one of the
factors listed in Schedule 2 to the 2000 Regulations which should be taken
into account in determining which is the best of the range of techniques for
prevention and reduction of emissions. Indeed, the efficient use of energy
may be an available technique for the prevention and reduction of emissions.
Different sections of the relevant technical guidance will apply depending
upon whether the installation is the subject of a climate change levy or trading
agreement, or not. Refer to the Horizontal Guidance Series.
No condition is required where the only activity included in the installation is a

landfill falling within Part A(1)(b) of Part 1 of Schedule 1 to the PPC
Regulations, (e.g. landfills for inert waste) as the requirement to consider
energy efficiency is disapplied for such landfills.
1.5 Site Security

Standard condition to prevent unauthorised access as far as practicable. For
advice on how this can be achieved refer to the relevant section of this
guidance note.
1.6 Multiple operator installations

It is possible for the activities comprising a single installation to be operated
by more than one operator. Each operator will be issued with a separate
permit.
The text is intended to ensure that where there is more than one operator,
they communicate with each other when the notification condition (4.3.1) is
invoked.
Section 2 Operations
2.1 Permitted activities Sch 1

2.1.1 Identifies all the listed activities and unlisted directly associated activities Table
S1.1
within the installation covered by the permit. This condition also classifies the
site for the purposes of the Landfill Regulations, Regulation 7(1). Details are in
schedule 1, table S1.1. The operator will have identified these in his
application. The table also provides more detail/ clarification, e.g. by placing
limits upon the extent to which each activity may be operated.
2.2 The site Sch 2

2.2.1 This condition specifies the extent of the land on which the activities that
are the subject of the permit take place. This condition ensures that the
operator will need to apply for a variation (for which an additional site report will
be necessary) if it wishes to carry out activities on land not covered by the site
plan.
Where there is more than one permit for an installation it is possible that the
respective permit plans may overlap if there are shared areas of land over

which the activities of more than one operator may take place. This should be
avoided where possible, but, if there has to be overlap, each operator must
include such land in their site report and subsequent surrender application.
The site plan is in schedule 2 of the permit and it can be copied or
electronically scanned if of an appropriate size. The relevant area subject to a
permit should be edged in green.
Alternative conditions have been included in the template for those installations
operated by more than one operator. In this case the overall installation plan
should be edged in red, with the specific area covered by the operator of the
permit still edged in green.
2.3 Operating Techniques Sch 1

2.3.1 incorporates specified parts of the application. The incorporation table
S1.2
approach has been retained in respect of operational controls, in order to avoid
the need to draft numerous detailed conditions in respect of operational
matters. However, it should only be the key operational controls that are
covered, i.e. those which the Environment Agency consider are essential to
impose as requirements on the operator. This might be because they are
necessary for securing compliance with other permit conditions (e.g. emission
limits), for securing essential safe/ precautionary operation, critical to the
protection of the environment, or essential to ensure that appropriate measures
to prevent pollution are used.
Those parts of the application to be incorporated should be set out in table

S1.2. That table also lists excluded parts of the relevant section of the
application. The table should therefore include only those parts of the
application which describe operational matters that the Environment Agency
would not want changed without written agreement (including by variation
notice, as appropriate).
2.4 Off-site conditions

Conditions should only be specified in this section if the provisions of PPC
Regulation 12(12) apply.
2.5 Improvement Programme Table

S1.3
2.5.1 There are no standard improvement programme requirements in the
template permit.
Improvement conditions will be imposed where the Environment Agency

accept that the relevant requirements of the Landfill Regulations will need time
to be implemented and for the provision of other operational aspects such as
procedures. The relevant technical guidance may give indicative time-scales.
Improvement conditions will set a clear requirement and a standard that must
be met. The date by which this must be achieved will be clearly stated.
2.5.2 To assist with compliance assessment, improvements that do not require

a submission to us need to be notified to us once completed.
Where the output of an improvement condition leads to the agreement of

trigger levels or emission limits, these can be enforced from the improvement
condition. However, the permit should be varied by the Environment Agency to
include the limits in the schedule at the earliest opportunity.
2.6 Pre-operational conditions Table

S1.4A
2.6.1 This condition allows for the setting of measures that must be undertaken
before the permitted activities commence initially, or... Table
2.6.2 where there is a phased development, prior to the commencement of S1.4B
future operations.

2.7 Engineering
This condition requires the operator to submit construction proposals for new
cells and landfill infrastructure to the Environment Agency. Construction of a
new cell or landfill infrastructure is not allowed to start until the Environment
Agency has confirmed that it is satisfied with that proposal. Thereafter, the
construction must be in accordance with that proposal unless the change has
been agreed in writing with us, or the change is so minor that it has no impact
on the performance of any element of that design.
The operator is required to submit a CQA Validation Report for each new cell.
No waste may be deposited in a new cell until the Environment Agency has
confirmed it is satisfied with the CQA Validation Report. It remains the
Environment Agency’s responsibility to inspect the new cell prior to approving
its operation.
Where pollution controls are immediately necessary to prevent an incident or

accident, landfill infrastructure may be constructed provided that construction
proposals are submitted as soon as practicable.
If the Environment Agency does not confirm whether or not it is satisfied or

inform the operator that it requires further information after 4 weeks of receipt,
the Environment Agency will be deemed to be satisfied with the proposals and
CQA Validation Report submissions. If the Environment Agency is not satisfied
it must explain why the proposals are unsatisfactory so as not to delay
development.
2.8 Waste Acceptance Sch 1
Optional conditions for non-hazardous landfills are available for stable non-
Table
reactive hazardous waste, gypsum and other sulphate bearing wastes and S1.5
asbestos waste. This reflects the regulatory requirements placed on these
waste types by the Landfill Regulations. Table
S1.6
For landfills that have and will only accept inert waste, there is a separate
template permit.
Conditions for existing landfills will need to make clear any transitional
provisions that are allowed by the Landfill Regulations.
Waste types are to be specified by reference to the List of Wastes (England or

Wales as appropriate) Regulations 2005, by inclusion of permitted waste
types and codes in Schedule 3.
Guidance on waste acceptance criteria is available in the document ‘Guidance

for Waste Destined for Disposal in Landfills’ (Reference 56).
‘Medicinal products’ are those registered as medicines under the Medicines

Act, except where there is no active ingredient, e.g. saline, glucose.
‘Pharmaceutically active’ refers to waste that contains a medicinal product.
The waste acceptance procedures must be complied with and requirements to

visually inspect waste on arrival and at the point of deposit are specified
(except at in-house facilities where wastes may be inspected at the point of
dispatch).
The total quantity of waste to be deposited in the landfill is specified by

reference to pre-settlement levels on a drawing reference. This reference will
be site specific. Annual waste acceptance limits are specified in schedule 1.
At landfills for inert waste where settlement is minimal (e.g. shallow fill) a post-
settlement or ‘final contour’ plan may be used in place of a pre-settlement plan.

2.9 Leachate Levels (Haz/ non-haz template) Sch 4
Limits for the levels of leachate, with reference to the hydrogeological risk Table
S4.1
assessment for the site and Environment Agency guidance (Reference 53)
must be specified
A breach of the limit is a non-compliance with the permit. However, should the
limit be exceeded on a temporary basis following pre-notification from the
operator (e.g. in an emergency or during planned works) our enforcement
response must be proportionate to the risk to the environment.
2.10 Closure, aftercare and decommissioning
The operator is required to maintain the landfill and associated activities so as
to minimise risk of pollution on closure and decommissioning. Closure is an
ongoing process between the time when the site is ‘closed’, i.e. has ceased
accepting waste for disposal and ‘definitive closure’, i.e. when we agree that
the site may enter the aftercare phase.
Conditions 2.10.1 to 2.10.4 are optional conditions where there are non-landfill
activities that will require a site closure plan for their decommissioning, such as
leachate treatment plant, gas utilisation plant, storage areas, tanks.
2.11 Site Protection and Monitoring Programme

Site protection and monitoring programmes (SPMP) are required for activities
other than the permanent deposit of waste, such as for leachate treatment
plants. Refer to the PPC Land Protection Guidance, H7. Condition 2.11.1
requires the SPMP to be provided. This could be following the issue of the
permit or prior to the undertaking of an activity if not required immediately.
Condition 2.11.2 requires the SPMP to be implemented and maintained, and
reviewed every 4 years.
Further site specific conditions may be included on a site-specific basis at the

end of this section.
Section 3 Emissions and Monitoring
3.1 Emissions to water, air or land Sch 4

Point source emission limits are listed in Schedule 4.
Table
S4.2
For compliance with gas emission limits there is an uncertainty allowance
provided for within technical guidance on Landfill Gas, LFTGN05 and Table
LFTGN08. S4.3
Table
Where there is a substance of concern that does not have an established EQS S4.4
or Predicted No-Effect Concentration (PNEC) then a parameter can be
included within a table without an emission limit being specified. The limit
becomes the background concentration. It is anticipated that this would only be
included in exceptional circumstances.
Table S4.4 sets emission limits and monitoring requirements for emissions to
sewer, effluent treatment plant or by tankering off-site. Limits will only be set in
accordance with our H1 guidance.
3.2 Emissions to groundwater Sch 4

This condition is imposed to ensure compliance in accordance with
Table
requirements of the Groundwater Regulations : S4.5
(i) the permit should not be granted at all if it would allow the direct
discharge of a List I substance (Regulation 4(1)) (except in limited
circumstances)
(ii) If the permit allows the ‘disposal’ of a List I substance or any other activity

that might lead to an indirect discharge of a List I substance then ‘prior
investigation’ (as defined in Regulation 7) is required and the permit shall
not be granted if this reveals that indirect discharges of List I substances
would occur. In any event conditions to secure prevention of such
discharges must be imposed (Regulation 4(2) and (3)).
(iii) In the case of List II substances permits must not allow direct discharges
or possible indirect discharges, which must be subject to prior
investigation with conditions being imposed to secure prevention of
groundwater pollution (Regulation 5).
(iv) The Groundwater Regulations contain further detailed provisions

covering requisite surveillance of groundwater (Regulation 8);
conditions required when direct discharges are authorised (Regulation
9); when indirect discharges are authorised (Regulation 10); and
review periods and compliance (Regulation 11).
Guidance ’Hydrogeological Risk Assessment for Landfills and the Derivation of

Control and Trigger Levels (LFTGN01)’ Environment Agency 2003, should be
referred to.
The permit provides conditions 3.2.1 and 3.2.2 to address the requirements of
the Groundwater Regulations.
Trigger levels for emissions into groundwater will be specified in Schedule 4,

notwithstanding advice in LFTGN 01. That part of the LFTGN 01 has been
superseded by our charging scheme that allows ‘administrative’ variations for
no charge, where appropriate. See general note above.
The hydrogeological risk assessment (a term that is defined in the

interpretation in Schedule 7), is required to be reviewed on a 4-year basis and
time limits are imposed for its submission to the Environment Agency.
3.3 Fugitive emissions of substances

These conditions cover fugitive emissions, litter, mud and containment of ’ Sch 1
‘Fugitive emissions‘ are emissions that do not have specific emission limits (or Table
exceptionally background concentration limits). They are controlled by S1.7
conditions referring to appropriate measures to prevent or minimise them.
Fugitive emissions might include those from points such as relief vents, diurnal Table
S1.8
emissions, etc, as well as ‘diffuse’ emissions, e.g. landfill gas from an Litter
uncapped area. Refer to Schedule 7 Interpretation for definition of fugitive
emissions. Table
S1.9
Mud
The measures to be taken to mitigate a fugitive emission should be included
within the application or procedures. Where there is a site-specific reason for Table
including other measures they can be added to schedule 1, tables S1.7, S1.8 S4.6 gas
and S1.9. For example, if there is a problem with litter at an existing site that
Table
requires a more detailed assessment of the operator’s measures, the relevant S4.7 gas
management plan should be required for assessment before the issue of the
permit. Guidance on what is considered appropriate is included below. Table
S4.12
gas
Condition 3.3.3 requires litter or mud from the activities to be cleared from
affected areas outside the site as soon as practicable. Table
S4.13
particulat
Liquids
es
Condition 3.3.4 concerns the containment of potentially polluting liquids stored
in above ground tanks, e.g. by bunding of tanks.
Landfill Gas and Particulates

Condition 3.3.5 requires that limits for landfill gas and particulates are not
exceeded. The limits for landfill gas are set out in the monitoring tables S4.6,
and S4.12. Table S4.13 details the requirements for monitoring particulates in
ambient air and sets emission limits (refer to Guidance M17 Monitoring of
Particulate Matter in Ambient Air around Waste Facilities).
NB table numbers may vary.
3.4 Odour
Sch 1
3.4.1 is a standard condition that refers to appropriate measures that should be
Table
contained within the operator’s procedures. Specific measures can be S1.10
specified in schedule 1, table S1.10, but only where there is a site-specific
reason for doing so. This will normally be where an existing site has a known
odour problem. More guidance is provided below. Reference should also be
made to Horizontal Guidance Note H4 and Guidance for the Regulation of
Odour at Waste Management Facilities.
Condition 3.4.2 is for the setting of limits for odour.
The term ‘annoyance’ in used in the condition. This is to avoid use of the term
‘nuisance’ which has a specific meaning under other legislation although the
general intent is the same.
Should there be a breach on a temporary basis following pre-notification from

the operator (e.g. in an emergency or during planned works) the Environment
Agency’s enforcement response must be proportionate to the risk to human
health and the environment. This may involve a review of the operator’s odour
management plan.
3.5 Noise and Vibration Sch 1
Table
Noise management is a specific requirement of the Landfill Regulations,
S1.11
Schedule 2, paragraph 5(1)(c). Condition 3.5.1 addresses the general
principle and in most cases will be sufficient to control noise and vibration from
the permitted installation. Further measures can be specified in schedule 1,
table S1.11, but only where there is a site-specific reason for doing so. This will
normally be when an existing site has a known noise problem.
An alternative condition allows for the setting of specific noise levels in

exceptional cases where there is a particular noise or vibration issue at the
installation. An assessment of the applicant’s proposals should be made,
having regard to the indicative standards in the corresponding section of the
relevant technical guidance. See also the Environment Agency’s IPPC H3
Horizontal Guidance Note.
Should there be a breach on a temporary basis following pre-notification from

the operator (e.g. in an emergency or during planned works) the Environment
Agency’s enforcement response must be proportionate to the risk to human
health and the environment. This may involve a review of the operator’s noise
and vibration management plan.
3.6 Monitoring Sch 4
3.6.1 sets out the requirements for monitoring at the site. The specific
requirements of substances, parameters, frequency, locations, etc are in the
tables of schedule 4.
Site specific requirements must be set in schedule 4, based on the technical

assessment of the application.
In the tables that do not set an emission or other limit, there is a column for
’Other specifications‘ (Tables S4.8 to S4.11). This can be used to specify
requirements such as control levels (for groundwater) and assessment levels.
These are not limits that require notification under the permit and any

specification must set out the actions required should a value be exceeded.
For existing sites the template includes assessment levels for fugitive
emissions of landfill gas and concentrations of certain gases in gas extraction
infrastructure.
Regulation 14 and schedule 3 to the Landfill Regulations require a monitoring

programme. This part of the permit is based on the operator proposing and us
agreeing to an emissions monitoring programme. The permit template contains
certain additional requirements in respect of monitoring, some of which are
discretionary and some of which are mandatory.
3.6.2 requires records to be maintained of the monitoring undertaken by the

operator.
3.6.3 requires topographical surveys to be undertaken at certain times to track

the progress of filling for strategic purposes, or to define levels, e.g. the base of
a new cell.
3.6.4 is an optional condition for sites where a Site Protection and Monitoring
Programme is required (i.e. where there are non-landfill operations permitted),
for the provision of site reference data within 6 months of the permit being
issued.
Section 4 Information
4.1 Records
This condition imposes standard obligations upon operators in respect of key
aspects of keeping records. It does not list the records that are required to be
kept under other conditions of the permit. Instead it simply imposes the
minimum requirements for all record keeping such as the speed of making
records, legibility and the retention time. Records should usually be kept for 6
years. Some records need to be kept until permit surrender as they may be
used to inform a decision on permit surrender.
4.2 Reporting Sch 5

Condition 4.2.1 requires annual reports to be sent to the Environment Agency,
usually by 31 January each year. The Environment Agency may agree an
1
alternative date for submission on a site-specific basis . It includes reports of:
(a) a review of monitoring data against assumptions made in risk assessment.
This is not intended to reproduce the 4 –yearly groundwater review, but to
ensure that monitoring data is compared with original predictions to identify
whether those assumptions were broadly correct. Where data suggests that
the assumptions were not correct, the operator may need to undertake a
review of their HRA to understand potential impacts.
(b) progress against management system targets to confirm that there is a
mechanism of continual improvement in the management system,
(c) what energy has been used in accordance with the Landfill Regulations,
Regulation 8(3)(b)(ii),
(d) the quantity of leachate treated and disposed of and the quantity of surface
water treated and disposed of (e.g. in a settlement lagoon prior to discharge) at
the installation,
(e) details of any contamination or clean up of the ground outside the landfill
area,
(f) any topographical surveys undertaken.
(g) a summary of the void used since the previous topographical survey, to
track the rate of filling,
(h) a summary of the settling behaviour of the waste, so that predictions can be
1
This is an example of a condition that does not require prior notification under PPC Regulation 16 each time the operator
wishes to change the date. A one off agreement is adequate until a further request to change the date is submitted

made of likely settlement rates,
(i) an assessment of remaining void space for strategic purposes, to identify
what capacity for waste disposal is available in particular parts of the country
as required by the EU Regulation on waste statistics (No. 2150/ 2002).
[NB Items (g) – (i) are required by the Landfill Regulations, schedule 3,
paragraph 6.]
(k) a summary of the operator’s compliance testing of wastes accepted/
rejected in accordance with the waste acceptance procedures in the Landfill
Regulations.
(j) Where waste acceptance ratios (further to the waste acceptance criteria) are
set, then reports of compliance with those ratios may be required.
Condition 4.2.2 requires monitoring and assessments from Schedule 5, in

accordance with the reporting periods specified therein.
Condition 4.2.3 requires quarterly reports of waste types and quantities

accepted (or removed).
Condition 4.2.4 allows the Environment Agency to give an operator 6 months

notice to submit a report assessing whether all appropriate measures continue
to be taken against pollution. It is hoped that this condition will allow the
Environment Agency to obtain much of the necessary information prior to
conducting a review of the permit. It can be used to provide information across
a sector. This condition is not intended to preclude the Environment Agency
from seeking information to a faster timescale where necessary using other
powers, perhaps for enforcement purposes or where a specific problem is
identified.
Condition 4.2.5 is imposed where there is a requirement for a site protection

and monitoring programme to ensure that any changes to the SPMP are
reported.
European Pollution Emissions Register - The European Pollution Emissions

Register data will be gathered through notices served on operators under
Regulation 28 to the PPC Regulations and so such issues are not addressed
through the permit.
4.3 Notifications
Notification of an emission exceeding a limit or a significant pollution situation Sch 6
(actual or potential) is handled in three stages within conditions 5.1.1 and
5.1.2:
a) The first stage is an immediate report as soon as the situation is

identified. This may be achieved through a telephone call to the
Environment Agency’s emergency hot line or an e-mail or telephone
call to the local Area office. The immediacy is considered necessary as
the Environment Agency may need to carry out immediate action or
make preparation (e.g. closure of the drinking water abstraction
downstream of the emission);
b) The second stage is the Part A report which is normally required within
24 hours. This report gives written confirmation of the original report
and gives details such as quantities, environmental medium etc.;
c) The third stage is the Part B report and is intended to give a more
accurate update of the Part A report and most importantly to give
details of any remediation undertaken and any corrective action to
ensure that a similar situation does not occur again. Any subsequent
similar incidents could point to an inadequate management system
that could require further investigation.

Prior notification – Permit condition 4.3.3 and 4.3.4. These conditions require
the prior notification of permanent or longer-term cessation of the activity and
again if the activity is resumed.
4.3.4 is only applicable where a site closure plan for activities other than landfill
operations is required.
4.3.5 requires notification of when the operator is to undertake monitoring, so

that the Environment Agency can witness or audit monitoring to confirm it is
carried out to an appropriate standard.
Change in fit and proper person details – Conditions 4.3.6 – 4.3.9 require
the operator to notify us of changes in technically competent management,
relevant convictions or the status of the operator (e.g. administrative changes
of corporate details, specified financial difficulties). It is important that the
Environment Agency have up to date information on the operator for
enforcement and environmental protection purposes.
Climate Change Agreement condition 4.3.10 requires notification of re-

certification or termination of the agreement.
4.4 Interpretation
This condition refers to Schedule 7 where terms/ expressions used in the Sch 7
permit are defined. It may be necessary to include additional definitions for site
specific conditions. Note that definitions set out in the PPC Regulations and the
Landfill Regulations themselves are incorporated through the definition given
here of ‘PPC Regulations’ (save any which are specifically defined in the
permit) and similarly for the Landfill Regulations.

2. RISK ASSESSMENT
2.1 Risk assessment
The operator should assess that the controls over emissions from the proposed activities/
installation will provide a high level of protection for the environment as a whole, in particular
having regard to environmental quality standards (EQS) etc, revisiting the techniques in Section 3
as necessary.
The preparation of a risk assessment and the development of a conceptual model will be required
at all sites prior to permitting. Risk assessment should be a structured, transparent and practical
process that aids decision-making, undertaken in accordance with Government and Environment
Agency guidance. The following risk assessments are required as part of the application:
- hydrogeological risk assessment;

- landfill gas risk assessment;
- stability risk assessment;
- nuisance and health risk assessments including an assessment of particular matter;
- ecological assessment (if the site is close to a European Habitats site).
The level of detail (or tier) at which the risk assessment should be produced should be discussed
with the Environment Agency. For some low risk sites (e.g. non-IPPC sites) the requirements may
be for a simple risk assessment. The following documents should be consulted for the production
of the landfill risk assessments:
- Guidelines for Environmental Risk Assessment and Management (reference 27)

- H1 Environmental Assessment and the Appraisal of BAT (reference 41)
- Guidance on the assessment of risks from landfill sites (reference 107)
- Hydrogeological risk assessments for landfills and the Derivation of Groundwater Control and
Trigger Levels (reference 65)
- LandSim (reference 69)
- Guidance on the management of landfill gas (reference 91)
- GasSim (reference 98)
- The stability of landfill lining systems (references 86 and 87)
- M17 Monitoring of particulate matter in ambient air around waste facilities (reference 51)
- H3 Horizontal guidance for noise (references 42 and 43)
- H4 Horizontal guidance for odour (references 44 and 45)
- Further guidance applying the habitats Regulations to waste management facilities (reference
110)
In implementing the Landfill Directive, the main decisions that must be supported by risk
assessment are provided in Schedule 2, paragraph 1 of the Landfill Regulations 2002.
Additionally, the Landfill Regulations, Regulation 5 states that a planning permission under Town
and Country Planning Act 1990 may be granted for a landfill only if Schedule 2, paragraph 1(1) has
been taken into consideration.
Landfill Regulation requirements
Schedule 2, Paragraph 1 of the 2002 Regulations
1. – (1) The location of a landfill must take into consideration requirements relating to –
(a) the distances from the boundary of the site to residential and recreational areas, waterways, water
bodies and other agricultural or urban sites;
(b) the existence of groundwater, coastal water or nature protection zones in the area;
(c) the geological or hydrogeological conditions in the area;
(d) the risk of flooding, subsidence, landslides or avalanches on the site; and
(e) the protection of the natural or cultural heritage in the area

(2) A landfill permit may be issued for the landfill only if –
(a) the characteristics of the site with respect to the requirements in sub-paragraph (1); or
(b) the corrective measures to be taken indicate that the landfill does not pose a serious environmental risk.
There are two overarching decisions in the permitting process to be supported by risk assessment:
- whether the environmental location of the landfill is such that the landfill would pose a serious risk
such that a permit cannot be issued;
- whether proposed measures are sufficient to minimise damage to the environment and risk to
human health such that the landfill does not pose a serious risk i.e. the predicted impact of the
landfill installation is acceptable.
For existing landfills, the location is already determined, so the risk assessment must ensure that
the selected techniques in the form of engineered design and operational procedures are sufficient
to provide a high level of protection for the environment as a whole. The assessment must be
considered for the whole lifecycle of the landfill up to the point where the site no longer poses a risk
to the environment.
The selection of techniques to protect the environment should achieve an appropriate balance
between the environmental benefits they bring and the costs to implement them. The operator must
assess the potential environmental impact of emissions from the activities as a whole. The
environmental impacts that should be considered are; those that may be harmful to human health
or quality of the environment, cause offence to human senses, result in damage to material
property or impair or interfere with amenities or other legitimate use of the environment.
2.2 Site investigation

In order to develop the site conceptual model, it will be necessary to carry out sufficient site
investigation to:
- meet the requirements of the Groundwater Directive;

- establish that the site is suitable for its intended purpose;
- establish baseline (background) conditions for the site;
- enable an assessment of the impact of the development on local populations and the
environment;
- enable a monitoring programme to be developed and implemented to identify whether there
are any environmental impacts from uncontrolled releases from the site;
- develop the engineering design of the site, including the stability of the substratum;
- allow design of measures to mitigate any adverse impacts.
It is essential that sufficient information be gained to provide a robust risk assessment and landfill
design as a result of a full understanding of the conceptual model.
2.2.1 Recommendations
Recommendations for site investigation

1 The site investigation should comprise both desk study and where necessary, field investigations. The scale and
extent of the investigations should relate to the nature of the proposed landfill (types of waste), the complexity and
sensitivity of the geological and hydrogeological environment, and the proximity of potential receptors which may be
affected (reference 65). Since knowledge of many of these aspects will only be revealed as the investigation unfolds,
any investigation should be phased. Each phase should have clear identifiable objectives, which should be re-
appraised during and between phases.
2 A quality approach should be adopted for all site investigation activities, as part of the overall quality approach to
landfill design, construction and operation.
3 The investigations should include both the site and the surrounding areas that will be influenced by the landfill. For
areas of a landfill installation which lie outside the permanent deposits of waste, reference should be made to

Recommendations for site investigation
Environment Agency guidance documents H7 and H8 which detail the site report requirements (references 46 and
47).
4 The investigations should include the initial design of the monitoring programme, and installation of groundwater and
soil gas monitoring points to allow collection of background/ base readings over the maximum practicable period of
time (and in any case for a minimum of 12 months). For example, this should take into account seasonal fluctuations
in groundwater levels.
5 An accurate topographic survey should be undertaken for both site design purposes and for the calculation of void
space (topographical surveys are considered in more detail in the monitoring section (2.10)). All borehole positions
and other site features such as streambeds, springs, outcrops and exposures should be surveyed. Wherever
possible, the survey data should be in an electronic format that can be easily used as part of the design process. For
example, a computer-aided design drawing file with the capability to produce an output format, which can be
universally read by other systems (a .dxf format is the most common).
6 The operator should consider the use of aerial photographs which can provide a useful means of communicating the
context of the site and recording development throughout its life, and the use of aerial survey may be advantageous
in areas where access is difficult.
2.3 Groundwater protection

The Landfill Directive (as given in Schedule 2, paragraph 1 of the Landfill Regulations, 2002)
reinforces the focus on the Environment Agency’s duty to protect groundwater. Our position on the
location of landfills for planning consultation responses and permitting decisions is set out in
Groundwater Protection: Policy and Practice (GP3) (reference 63) and associated guidance,
(reference 64). It is relevant to new landfills and for the permitting of new areas (i.e. those areas
not already licensed or permitted on 15 June 2002). The Environment Agency is not required to
apply Schedule 2 paragraphs 1(1) and (2) of the Landfill Regulations when granting a PPC permit
2
for an ‘existing landfill’ .
2
‘existing landfill’ - a landfill which was already in operation on 15 June 2002 or had not been brought into
operation by that date, but the relevant authorisation (licence or permit) was granted before that date.

3. MANAGEMENT
3.1 Management techniques
An effective system of management is a key mechanism for ensuring that all appropriate pollution
prevention and control techniques are delivered reliably and on an integrated basis.
The Environment Agency strongly support either certification to the ISO 14001 standard or
registration under EMAS (EC Eco Management and Audit Scheme) (OJ L114, 24/04/01). Both
certification and registration provide independent verification that the EMS conforms to an auditable
standard. EMAS now incorporates ISO 14001 as the specification for the EMS element, and the
Regulators consider that overall EMAS has a number of other benefits over ISO14001 - including a
greater focus on environmental performance, a greater emphasis on legal compliance and a public
environmental statement. For further details about ISO 14001 and EMAS contact British Standards
Institute (BSI) or the Institute of Environmental Management and Assessment (IEMA), respectively.
The third party audit should ensure that organisational structure and resources allocated are
adequate to implement the management system. Any environmental problems are more likely to
result from a failure to implement the system that exists, rather than an inadequacy of the system
itself.
The operator must consider how to minimise the environmental risks and impact of the normal
running of the activities, including start-ups and shutdowns. The operator must ensure the reliable
operation of equipment used to carry out permitted activities. Properly maintained equipment
should be available when required and achieve optimum performance without suffering
breakdowns. Poor maintenance is a common cause of environmental incidents. To satisfy these
requirements for plant whose failure could lead to increased emissions to the environment, the
operator must:
- Carry out a programme of Planned Preventative Maintenance (PPM), rather than waiting for
equipment to fail before taking action. Use the manufacturers recommended inspection and
maintenance schedules, or have a written justification for using any other schedule.
The recommendations below are considered to be capable of delivering wide environmental

benefits. These are not prescriptive and the operator can use other measures, providing an
equivalent level of environmental protection is provided.
Recommendations for management techniques

Operations and maintenance
1 Effective operational and maintenance systems should be employed on all aspects of the process whose failure could
impact on the environment, in particular there should be:
- documented procedures to control operations that may have an adverse impact on the environment.
- a defined procedure for identifying, reviewing and prioritising items of plant for which a planned preventative
maintenance regime is appropriate
- documented procedures for monitoring emissions or impacts
a preventative maintenance programme covering all plant, whose failure could lead to impact on the environment.
2 The maintenance system should include auditing of performance against requirements arising from the above and
reporting the result of audits to top management.
3 The operator must ensure that all staff have clearly defined roles and responsibilities, with instructions covering what
they should (and should not) do. The Environment Agency will use these instructions when investigating incidents
caused by human errors or omissions. These procedures should be written for a post holder rather than for an
individual.
4 The management system must be reviewed to keep it up to date. Formal systems such as ISO14001 will normally be
subject to an annual review. Operators should review management systems, accident management plans, site
closure plans etc. at least once every 4 years. This will ensure that the operator has carried out at least one review of
his systems before the Environment Agency carry out a formal review of the permit. Similarly the Environment
Agency expect the personnel system to be reviewed at least once every 4 years to keep it up to date and to ensure
that staff turnover does not result in any decrease in expertise. A review should be carried out as soon as practicable

in the event of a significant change to the activities such as a company take-over, expansion of the activities or an
accident.
Accidents/incidents/non-conformance
5 The operator is responsible for the environmental performance of the installation and achieving compliance with the
permit. Incidents that require investigation include any malfunction, breakdown or failure of plant, equipment or
techniques and any near misses. The operator should be able to cope with abnormal operation and return the activity
to normal operation.
To satisfy the requirements of this part of the condition, the operator must be able to:
- Detect abnormal operation and investigate the causes.
- Assess the information and decide on the corrective action required.
- Implement the short-term corrective actions to return to normal operation.
- Implement the longer-term corrective actions to prevent re-occurrence of the problem.
- Take action to enable the public to know how to take action if a problem arises. (the operator must take
responsibility for minimising the environmental impact of their activities and be responsive to the concerns of the
local community.)
- Have systems in place to deal with complaints and to take appropriate measures to prevent, or where that is not
possible to minimise, the causes.
- Display an identification notice at or near the site entrance so that the general public is informed about the nature of
the site and so that they can contact the operator or us. It should be easily readable from outside the site in
daylight hours and should include the following information:
- Site name and address
- Permit holder name (company name at least)
- Operator name if different (company name at least)
- Emergency contact name and telephone number of the permit holder and/or operator
- Statement that the site is permitted by the Environment Agency;
- Permit number;
- Environment Agency national numbers, 0845 933 3111 and 0800 807060, (or any other number
subsequently notified in writing by the us)
- Days and hours when the site is open to receive waste
6 There should be an accident plan as described in Section 3.2 which:

- identifies the likelihood and consequence of accidents
- identifies actions to prevent accidents and mitigate any consequences
7 There should be written procedures for handling, investigating, communicating and reporting actual or potential non-
compliance with operating procedures or emission limits.
8 There should be written procedures for handling, investigating, communicating and reporting environmental
complaints and implementation of appropriate actions.
9 There should be written procedures for investigating incidents, (and near misses) including identifying suitable
corrective action and following up
Competence and training

10 Training systems, covering the following items, should be in place for all relevant staff which cover:
- awareness of the regulatory implications of the permit for the activity and their work activities
- awareness of all potential environmental effects from operation under normal and abnormal circumstances
- awareness of the need to report deviation from the permit
- prevention of accidental emissions and action to be taken when accidental emissions occur
11 The skills and competencies necessary for key posts should be documented and records of training needs and
training received for these posts maintained. Evidence that may contribute to operators being able to demonstrate
that their staff are competent in respect of the responsibilities they undertake include:
- Academic qualifications e.g. being a graduate with a relevant degree;
- Professional qualifications e.g. membership of an appropriate institution;
- Vocational qualifications e.g. NVQs
- External training qualification/ certification e.g. certificate of technical competence;
- Attendance of external or in-house training courses;

- Those with approved training to cascade that training to other staff;
- Mentoring of inexperienced staff, as part of ‘on the job’ training.
12 The key posts should include contractors and those purchasing equipment and materials.
13 The potential environmental risks posed by the work of contractors should be assessed and instructions provided to
contractors about protecting the environment while working on site.
14 Where industry standards or codes of practice for training exist (e.g. WAMITAB) they should be complied with.
3.2 Accidents and their consequences

This section covers accidents and their consequences. It is not limited to major accidents but
includes spills and abnormal operation.
Landfill Regulations requirements
Regulation 8 (2) of the 2002 Regulations
(2) A landfill permit shall also include appropriate conditions -
(c) ensuring that the landfill is operated in such a manner that the necessary measures are taken to prevent accidents and to
limit their consequences.
The operator must ensure that accidents are considered as part of carrying out the permitted
activities. Accidents are one of the common causes of environmental incidents. (General
management requirements are covered in Section 3.1).
Recommendations for accidents and their consequences

1 The operator should produce and maintain an accident management plan.
2 The accident management plan should:

- Identify the potential accident hazards at the installation,
- Undertake an assessment of the risks (hazard x probability) of accidents and their potential environmental
consequences,
- Identify potential risk management measures,
- Specify the risk management measures that are used at the installation to reduce the risk of accidents, and
- Include contingency actions to be undertaken in the event of an accident in order to mitigate the consequences.
3. Particular areas of accidents to consider at landfills may include, but should not be limited to, the following:
- uncontrolled migration of landfill gas;
- fire;
- explosion;
- waste slippage;
- failure of a basal or side wall liner
- incompatible wastes coming into contact;
- release of leachate to an uncontained area;
- overfilling of tanks / lagoons;
- emission of a treated leachate before adequate checking of its composition;
- vandalism.
4 The operator should review the plan periodically and at least once every 4 years.

Recommendations for accidents and their consequences
5 In the case of an accident that has the potential to cause, or does cause, an adverse environmental impact the
operator must:
- undertake immediately any action required by the accident management plan;
- undertake any other action required to minimise the environmental consequences; and
- investigate the causes of the event and take action to prevent a recurrence.
6 The operator should have procedures in place to review the plan in the event of an accident
7 Operators should take particular account of the hazards displayed by any hazardous wastes to be deposited when
preparing their accident management plan.
3.3 Finance
Operators must be aware of costs over the whole life of the landfill installation. Adequate provision
must be made for post-closure aftercare and for response to any unforeseen incidents. It is vital
that the provisions reflect the long-term management requirements up until the point of completion
and surrender.
Landfill Regulation requirements
Regulation 11 of the 2002 Regulations
The Operator of a landfill shall ensure that the charges it makes for the disposal of waste in its landfill covers all of the
following;
(a) the costs of setting up and operating the landfill;

(b) the costs of the financial provision required by regulation 4(3)(b) of the 2000 Regulations; and
(c) the estimated costs for the closure and after-care of the landfill site for a period of at least 30 years from its
closure.
This regulation relates to charges, rather than directly to the aftercare period, which is covered by
Regulation 15 (see Section 4.3). It must be noted that Regulation 11 provides for ‘at least’ 30
years. For a site that has taken biodegradable waste, completion may take significantly longer
than this.
3.3.1 Costs
Operators must be aware of the cost of each element of the works and of the landform as a whole.
This should include the costs of site assessment, operations, environmental control and monitoring,
restoration and aftercare, as well as of the preparation and development works. Costs should be
assessed in terms of the total costs, the costs expressed per tonne of waste, and costs against
time over the whole life of the landfill.
Without a demonstration of the cost of a landfill project and its cost-effectiveness, even the most
technically advanced landfill design may remain just a design. A failure to determine the financial
viability of a project may lead to financial difficulties and environmental problems if funds run short
before its closure, restoration and completion.
A consistent basis for cost assessment should be defined to allow a valid comparison of alternative
designs or design elements.
3
The assessment of unit costs (£/m or £/t) can be extended from a simple total to a calculation for
each item. This will enable the effects of significant variable items to be rapidly assessed.
Consideration should also be given to the distribution of development, restoration and aftercare
costs across a landfill. In this way the cost for areas such as those at the perimeter where the

waste is particularly thin, or those areas requiring difficult engineering works, can be assessed and
the site’s boundaries and profile adjusted accordingly.
A financial model will be of value in comparing the cost-effectiveness of differing designs, for
example, of liner and cap. Similar sensitivity analyses can be made of different parameters to
assess their impact on profitability.
The cost-effectiveness of the landfill should be assessed, taking account of commercial aspects
related to the availability of competing facilities.
Adequate provision must be made for post-closure aftercare and for response to any unforeseen
incidents.
The management of leachate and gas from landfills for hazardous wastes may require techniques
which have been uncommon in the UK, and which may require off-site disposal of residues. The
costs for this, over the necessary timescale, must be fully reflected in the financial provision and in
the charges made by the operator.
3.2 Financial Provision
Financial Provision for landfills must be 'adequate'; it has to be sufficient, secure and available to
operators so that they can discharge their permit obligations. The requirements are set out in the
Policy on Financial Provision for Landfills and associated guidance, (reference 105).
3.4 Energy
Regulation 8 (3) of the 2002 Regulations
(3) A landfill permit shall also include -
(b) such other conditions as appear appropriate to the Environment Agency, including in particular conditions giving
effect to -
(ii) in the case of landfills falling within paragraph (a) of Part A(1) of Section 5.2 in Part 1 of Schedule 1 to the 2000
Regulations, the principle that energy should be used efficiently.
For landfills to which the IPPC Directive applies, the Landfill Regulations require that appropriate
permit conditions are set to give effect to the principle that energy should be used efficiently.
Landfills taking only inert wastes and small landfilling activities (those with an input of less than 10
tonnes per day or with a total capacity of not more than 25,000 tonnes) are not required to consider
energy efficiency.
Recommendations for energy efficiency

1 The operator should ensure that energy usage at the installation is measured and recorded. The areas of energy
usage at a landfill installation that should be recorded include:
- Leachate treatment plant;
- Treatment plant associated with the landfill;
- Leachate and groundwater pumping;
- Site office energy usage
2 Operating, maintenance and housekeeping measures should be in place to ensure energy is used efficiently
3 The operator should ensure that basic, low cost, physical techniques are in place to avoid gross inefficiencies
4 The operator should review energy usage at the landfill at least every four years. Other appropriate triggers for a

review would include the planning and commissioning of plant, including leachate treatment plant.
5 The review of energy usage should include proposals for improving energy efficiency
6 Where the review identifies measures to improve energy efficiency these should be implemented as soon as
practicable.
3.5 Security
Schedule 2 Paragraph 7 of the 2002 Regulations
7. – (1) The landfill must be secured to prevent free access to the site.
(2) The gates of the landfill must be locked outside operating hours.
(3) The system of control and access to each facility must provide systems to detect and discourage illegal dumping in
the facility.
Security measures must be implemented in order to prohibit unauthorised access to the operational
areas of the site. Operational areas shall include areas of the installation where active tipping is
taking place, leachate and gas plant are operational and any area where landfill gas or leachate
extraction systems are exposed and could be subject to deliberate damage. Access may be
allowed to areas that are fully restored and where members of the public will not be adversely
affected by the permitted activities carried out at the installation.
Recommendations for security

1 Fencing and gates – Perimeter fencing and gates should be provided at all landfills to prevent unauthorised access
as far as practicable (including the prevention of free access of animals and wildlife as required by the Animal By-
products Regulations).
Security fencing may be appropriate for vulnerable locations (the suggested minimum height for security fencing is 2
m with cranked top and barbed wire strands).
Perimeter fencing should be inspected regularly by a nominated person.
The fencing should be maintained in good repair at all times.
2 The operator should consider the use of the following measures to prevent free access to the site
Security cameras
Security guard
Intruder alarms, lighting, shutters and bars on accommodation

4. OPERATIONS
To assist operators and Environment Agency’s officers, this section summarises the
recommendations (i.e. what is considered to represent the appropriate measures for an efficiently
operating installation in the sector). These recommendations may not always be absolutely
relevant or applicable to an individual installation, when taking account of site-specific factors, but
will provide a benchmark against which permit applications can be assessed.
Summarised recommendations are shown in the boxes. The heading of each box indicates which
issue is being addressed. In addition, the sections immediately prior to the boxes cover the
background and detail on which those summary recommendations have been based. Together
these reflect best practice.
It is intended that all the recommendations identified in the following sections, both in the boxes
and the descriptions, should be considered and addressed by the operator when making a permit
application. Where particular standards are not relevant to the installation in question, a brief
explanation should be given and alternative proposals provided. Where the required information is
not available, the reason should be discussed with the Environment Agency before the application
is finalised. Where information is missing from the application, the Environment Agency may, by
formal notice, require its provision before the application is determined.
The operator should address the indicative requirements in this guidance note, but also use the
note to provide evidence that the following basic principles of IPPC have been addressed:
- preventing the release of harmful substances, and
- Where prevention is not practicable, those emissions that may cause harm have been reduced
such that no significant pollution will result.
4.1 Waste acceptance

4.1.1 Landfill Regulations requirements
The Landfill Regulations provide detailed technical measures for waste acceptance. The following
box provides a summary of these requirements. Reference should also be made to guidance on
wastes destined for disposal in landfills (reference 56) and guidance on sampling and testing to
meet landfill waste acceptance criteria and procedures (reference 57)
Summary of legislative requirements for waste acceptance

1 The Regulations require in Regulation 7 (1) that all landfills must be classified as for inert, non-hazardous or
hazardous wastes.
2 There are restrictions on the types of waste that can be accepted at each landfill class. Regulation 10 sets out which
wastes which can be accepted in the different classes of landfill. Regulation 9 prohibits the acceptance of certain
wastes at landfill.
3 The permit for a specific landfill can specify additional restrictions on waste acceptance, either as a consequence of
the application restricting the waste types or as a consequence of the risk assessment.
4 Subject to limited qualifications, all wastes must be treated before landfill - Regulation 10 paragraph 1.
5 Schedule 1 of the Landfill Regulations as amended establishes waste acceptance criteria, including numerical limit
values for some parameters and classes of landfill. These numerical criteria must be met in order for a waste to be
acceptable at a landfill.
6 Schedule 1 of the Landfill Regulations as amended establishes waste acceptance procedures. These require the
basic characterisation of all waste to be accepted at landfill. A system of compliance testing is required to
demonstrate that the basic characterisation accurately describes the waste accepted at the landfill. The hierarchy of
waste characterisation and testing are the subject of separate guidance (reference 57).

Summary of legislative requirements for waste acceptance
7 Schedule 1 of the Landfill Regulations as amended establishes specific requirements for the separate disposal of
asbestos wastes and high sulphate wastes (reference 56).
8 Regulation 12 (1) requires a visual inspection of the waste at the entrance to the landfill and at the point of deposit, or
at the point of dispatch for in-house facilities.
9 Visual inspection at the landfill entrance should take place unless it is not practicable to see the waste due to the
vehicle or container in which the waste is delivered. Visual inspection is not usually practicable where the waste is
delivered in:
- A front end loader
- A rear end loader
- Compaction container
- Road sweeper collector
- A sheeted container
- any other enclosed vehicle where there is no access for inspecting the waste without unloading the vehicle.
In these circumstances the operator should check that the delivery vehicle is consistent with vehicle type normally
used for the waste described in the documentation. If for whatever reason a landfill operator is concerned or
suspicious about the nature of the waste, then particular effort should be made to complete a visual inspection at the
landfill entrance. Where the waste is not consistent with the description provided, then the load should be
quarantined while further checks are undertaken or refused from site.
10 All waste should be visually inspected at the point of deposit by staff who are:
- Aware of the waste description for each load they are inspecting
- Familiar with the wastes permitted for disposal at the landfill
Procedures should be in place to allow the staff inspecting the loads to make detailed queries about the wastes that
are permitted at the landfill including information on basic characterisation and compliance testing.
Where the visual inspection of the waste identifies that the waste is not consistent with the description provided for
the waste or is otherwise not permitted at the landfill then the load of waste should be:
- Reloaded on to the delivery vehicle
- Removed to a designated quarantine area.
The waste should not be accepted for disposal at the landfill.

11 The operator must provide a receipt to the person delivering each load of waste to the site (Regulation 12 (5)).
12 The operator must notify the Environment Agency without delay if any waste delivered to a site is not acceptable
under the permit (Regulation 12 (6)).
Recommendations for landfill of hazardous waste

13 In addition to compliance with waste acceptance criteria, operators should also consider:
- any site-specific limitations;
- the physical parameters specified in Section 4.2.9;
- testing of the hazardousness (i.e. the concentration of constituents causing the display of hazards) of the waste, to
assess any precautions to be taken to protect the environment or human health;
- the compatibility of the wastes accepted, with other wastes in order to prevent any adverse reactions such as gas
emissions or mobilisation of leachable constituents, and with the landfill engineering materials.
14 Having regard to the hazards prohibited by the Regulations, and to the limitations on organic content and pH set by
the Waste Acceptance Criteria, the waste interactions that the operator should consider are:
- solubilisation of metals by interaction with alkalis or ligands;
- generation of low levels of gases by interaction of alkalis and other wastes, or of moisture with other wastes.
The operator should consider possible interactions between wastes and landfill engineering materials.

4.2 Landfilling engineering
4.2.1 Rainwater, Surface water and groundwater controls
2.—(1) Subject to the following provisions of this paragraph, appropriate arrangements shall be made with regard
to the characteristics of the landfill and prevailing meteorological conditions in order to—
(a) prevent surface water or groundwater from entering into landfilled waste;
(b) collect contaminated water and leachate and treat it to the appropriate standard so that it can be
discharged.
(2) Arrangements need not be made in accordance with sub-paragraph (1)(c) if the Environment Agency
decides that the landfill poses no potential hazard to the environment in view of its location and the kinds of
waste to be accepted at the landfill.
(3) This paragraph shall not apply to inert landfills.
Recommendations for rain water, surface water and groundwater

1 The operator should plan water management at the landfill to take into account the meteorology, hydrology and
hydrogeology of the site.
2 A final plan for the water control infrastructure is an integral part of the engineering design and should be linked to the
site restoration plan.
3 Ingress of rainwater and surface water should be predicted and minimised.
4 Water balance calculations should be undertaken and should be based on data that are accurate and relevant to the
specific site location and should also consider seasonal variations.
5 Rainwater running off areas outside the landfill should be intercepted and channelled away from construction,
operational and post-closure phases.
6 Rainwater coming into contact with waste and/or leachate should be managed as leachate. Other rainwater from the
landfill should be treated to remove suspended solids prior to use or discharge.
7 Non-operational areas should have temporary caps installed and completed areas should be capped and restored as
soon as practicable. These measures can assist in reducing infiltration. Capping should be protected against erosion
and infiltration. Drains on the landfill should be able to accommodate settlement.
8 The surface water drainage system should be designed to cope with predicted storm events.
9 New culverting, particularly of clean water beneath landfills will require specific Land Drainage consent by the
Environment Agency.
10 The requirement in Schedule 2, paragraph 2 to prevent groundwater from entering into the landfilled waste will be
interpreted by the Environment Agency in a risk-based manner. Groundwater should be prevented from entering the
landfill as far as is necessary to ensure that there is no unacceptable risk to the stability or effectiveness of
engineering controls (e.g. the lining and leachate collection systems), other environmental protection measures and
the environment. What constitutes acceptable risk must be determined on a site-specific basis through risk
assessments that satisfy the requirements of the Groundwater Directive and explicitly address:
- the geotechnical stability of the lining system, wastes and underlying geological strata;

Recommendations for rain water, surface water and groundwater
- the efficacy of the leachate collection system (e.g. drainage layer, pipework, pumps and abstraction chambers);
- the effectiveness of any groundwater control systems (e.g. drainage layers, pumps, abstraction points);
- the ability to maintain operational and management control of the leachate and groundwater regimes in the long
term (i.e. until the licence or permit may be surrendered)
- the ability to effectively collect landfill gas and control the migration of landfill gas.
11 Any long-term control of groundwater should, where possible, be accomplished by passive means such as barriers or
gravity drainage.
12 Where the natural geological barrier required by the Landfill Regulations is absent, operators of new sub-water-table
landfills should address the particular risk of direct discharge of listed substance to groundwater in the long-term.
13 Any groundwater management system should be designed to:

- accommodate the calculated flows;
- avoid clogging of drainage layers;
- accommodate discrete spring flows;
- accommodate anticipated settlement and overburden;
- allow CCTV inspection, jetting and maintenance.
4.2.3 The geological barrier
Schedule 2 Paragraph 3(1) to 3(5) of the 2002 Regulations
3.— 1) The landfill must be situated and designed so as to—

(a) provide the conditions for prevention of pollution of the soil, groundwater or surface water; and
(b) ensure efficient collection of leachate as and when required by paragraph 2.
2) Soil, groundwater and surface water is to be protected by the use of a geological barrier combined with—
(a) a bottom liner during the operational phase of the landfill; and
(b) a top liner following closure and during the after-care phase.
3) The geological barrier shall comply with the requirements of sub-paragraph (4) and shall also provide
sufficient attenuation capacity to prevent a potential risk to soil and groundwater.
4) The landfill base and sides shall consist of a mineral layer which provides protection of soil, groundwater
and surface water at least equivalent to that resulting from the following permeability and thickness
requirements—
(a) in a landfill for hazardous waste: k < 1.0 x 10-9 metre/second: thickness > 5 metres;
(b) in a landfill for non-hazardous waste: k < 1.0 x 10-9 metre/second: thickness > 1 metres;
(c) in a landfill for inert waste: k < 1.0 x 10-7 metre/second: thickness > 1 metres.
5) Where the geological barrier does not meet the requirements of sub-paragraph (4) naturally, it may be
completed artificially and reinforced by other means providing equivalent protection but in any such case, a
geological barrier established by artificial means must be at least 0.5 metres thick.
Recommendations for geological barriers

1 A geological barrier must provide a barrier to the movement of contaminants i.e. it must possess purifying powers
(attenuative properties).
2 A geological barrier is required for all landfills
3 The geological barrier must extend along the base and all the way up the sides of the landfill site. Designs must
demonstrate the stability of any side-wall geological barrier

Recommendations for geological barriers
4 The geological barrier must provide sufficient attenuation to prevent a potential risk to soil and groundwater. A risk
assessment will be required to demonstrate the performance of the proposed geological barrier for a site against the
requirements of the Groundwater Regulations and the Landfill Regulations, i.e. there must be no discharge to
groundwater of List I substances and no pollution of groundwater by List II substances at any stage during the life
cycle of the site.
5 The risk assessment should consider:

- both the operational and post-closure phases;
- failure and degradation of other controls, such as the artificial sealing liner, the leachate management system and
operational/management controls including groundwater pumping;
- likely variation of leachate concentration with time;
- stability and settlement;
- the role of the barrier in controlling landfill gas.
6 Where the geological barrier does not provide sufficient environmental protection naturally it can be artificially
enhanced3 [NB constraints apply on major aquifers and within source protection zones II and III through the
Environment Agency’s policy for the protection of groundwater (Reference 63 and 64)]. In low sensitivity locations it
may be possible to use a wholly artificially established geological barrier.
7 The artificial barrier must be at least 0.5m thick. This precludes the sole use of a geosynthetic liner product to
enhance the geological barrier.
8 Construction of the artificial barrier should follow the guidance on the construction of compacted clay liners
(Reference 80), bentonite enhanced soils (Reference 79), or other appropriate guidance.
9 There are two discrete elements that can be provided artificially, a layer to reinforce the geological barrier, i.e. an
artificially established mineral geological barrier and the artificial sealing liner. The provisions of the 2002 regulations
preclude the use of a single artificial sealing liner in the absence of a geological barrier. Section 4.2.3 provides detail
on the artificial sealing liner requirements.
4.2.4 The artificial sealing liner
Schedule 2 Paragraph 3(6) of 2002 Regulations
(6) A leachate collection and sealing system to ensure that leachate accumulation at the base of the landfill is kept to a
minimum must also be provided in any hazardous or non-hazardous landfill in accordance with the following table—
Leachate collection and bottom sealing
Landfill category Non-hazardous Hazardous
Artificial sealing liner Required Required
Drainage layer > 0.5 metres Required Required
Recommendations for the artificial sealing liner

1 Guidance on the use of geomembranes (reference 74) should be used.
2 As mineral artificial sealing liners are only likely to be acceptable where there is a substantial natural geological
barrier, it is unlikely that there will be circumstances where a single mineral layer can be regarded as both an
artificially established geological barrier and an artificial sealing liner.
3
The Landfill Regulations 2002, Schedule 2, paragraph 3(5)

Recommendations for the artificial sealing liner
3 The selection of any artificial sealing liner by the operator should be made on the basis that risk assessment of the
overall landfill design demonstrates that there is no likelihood of unacceptable discharges from the landfill over its
entire lifecycle.
4 The assessment of stability by the operator should take into account the interactions between the multiple layers
present in the lining system.
5 Liner systems should, in addition to the property of very low permeability, be stable, robust, durable, and resistant to
chemical attack, puncture and rupture.
6 Robustness, durability and puncture resistance may be provided by:

- the inherent strength of the liner components themselves;
- the combination of two or more components acting synergistically;
- physical thickness;
- protective layers.
7 The operator should assess the chemical compatibility of the liner materials (and, if used, any artificial support
structures) with the probable waste, leachate and gas composition and temperature.
8 The operator should consider the effect of potential weaknesses or imperfections in the liner materials on the short
and medium term performance of the liner.
4.2.5 Additional considerations related to lining systems
The Landfill Regulations do not set out detailed technical measures for liner protection, leak
detection and cut-off walls. However, these may be important considerations in the engineering of
a landfill site.
Recommendations for liner protection

1 Where mineral liners are acceptable as the artificial sealing liner, they should be protected against erosion,
weathering, desiccation, vegetation and penetration by, for example, granular material of the leachate drainage layer.
Protection can be afforded by leachate collection layers, with geotextile separation above the clay.
2 Geomembranes should be protected against puncture, ultra violet degradation, thermal and localised stress, and
stress concentrations, e.g. indentations, which can lead to stress cracking. The Environment Agency has provided
guidance on the use of a test for determination of the effectiveness of materials used as geomembrane protection
(reference 76).
3 The operator should select a suitable material to provide appropriate protection. A range of materials including
geotextiles and mineral materials can provide this appropriate protection.
4 Where mineral layers are used for liner protection, they are generally finer grained, 300mm thick or more, overlain by
a separation geotextile and the leachate collection system. The operator should ensure that the placement of the
protection layer does not damage or over stress the liner in particular damage by the placement machinery itself. The
operator should provide erosion control, particularly on sloping areas.
Recommendations for leak detection

1 The operator should monitor the performance, of the liner system in order to verify design assumptions and inform the
design of future phases. This may require installation of permanent, or semi-permanent monitoring systems to verify
design assumptions in the short to medium term.
2 The use of geophysical leak detection is required on all composite liners where the upper barrier is a geomembrane,
to check for defects after the installation of the leachate drainage layer and prior to waste deposition (reference 75).

Recommendations for leak detection
3 Risk assessment may indicate the need for a leakage interception layer within the lining system. The operator should
consider its purpose which may be for detection, interception and removal of any leakage through all or part of the
liner system, or for detection only. The system should be divided into compartments to assist in the location of any
significant leakage, and in its possible remediation.
4 Any leak interception system should be carefully monitored and the results interpreted carefully. For example,
instances have occurred where the seepage intercepted has, on investigation, been demonstrated to be pore water
expelled from the mineral liner component under the loading effect of the wastes.
5 The operator should consider whether land should be reserved adjacent to the landfill as a contingency against
unanticipated seepage, for example, to allow the construction of interception facilities.
Cut-off walls may be used to intercept or divert uncontaminated groundwater up-gradient of a site,
or to reduce flows. At existing landfills, they may be used as part of remediation measures to
reduce off-site leachate or gas migration. They may be used as part of a landfill liner system or, for
example, be specified as pre-defined remedial works to be constructed in the event of seepage
from the site being detected.
Recommendations for cut-off walls

1 Cut–off walls should be keyed into low permeability strata. Where the cut-off wall is part of a gas management
system, it should be keyed into low permeability or saturated strata and should incorporate a layer with low gas
permeability.
2 Cut-off walls should consist of physical passive barriers, providing a permeability contrast, and may be drained or
undrained, but actively pumped systems may also be used.
4.2.6 Leachate management
2. – (1) Subject to the following provisions of this paragraph, appropriate arrangements shall be made with regard
to the characteristics of the landfill and prevailing meteorological conditions in order to -
(a) control rainwater entering the landfill body;
(b) prevent surface water or groundwater from entering into landfilled waste;
(c) collect contaminated water and leachate and treat it to the appropriate standard so that it can be
discharged.
(2) Arrangements need not be made in accordance with sub-paragraph (1) (c) if the Environment Agency
decides that the landfill poses no potential hazard to the environment in view of its location and the kinds
of waste to be accepted at the landfill.
This paragraph shall not apply to inert landfills.
Schedule 2 Paragraph 3 (1) of the 2002 Regulations
3. – (1) The landfill must be situated and designed so as to -

(a) provide the conditions for prevention of pollution of the soil, groundwater or surface water; and
(b) ensure efficient collection of leachate as and when required by paragraph 2.
Schedule 2 Paragraph 3(6) of the 2002 Regulations
(6) A leachate collection and sealing system to ensure that leachate accumulation at the base of the landfill is
kept to a minimum must also be provided in any hazardous or non-hazardous landfill in accordance with the
following table -

Landfill Category Non-hazardous Hazardous
Artificial sealing liner Required Required
Drainage layer ≥ 0.5 metres Required Required
The Environment Agency’s approach to the management of leachate levels is covered in its landfill
permitting regulatory update guidance (Reference 53).
Recommendations for leachate management

1 Leachate levels in landfills should be set and managed in order to provide for a high level of environmental protection.
The operator should develop site-specific action levels below the specified compliance limit. This will not form part of
the landfill permit but should be contained within the operators environmental management system and are designed
to instigate the pumping of leachate to ensure that the compliance limit is not breached.
2 The operator should use a water balance calculation to predict the volume of leachate produced with time.
3 The gradient of the base of each cell should be a minimum of 2% (1 vertical to 50 horizontal)4 towards the sump.
4 The drainage layer should be used along the entire base of the cell and should be continued up inter-cell bunds. The
drainage blanket shall be extended up perimeter side slopes to a level above the vertical height of the maximum
leachate level. The remaining area of the perimeter side slope will require a drainage system that is designed to
accommodate transmission of leachate to the base of the site, to minimise leachate head on the side slope.
5 The hydraulic conductivity of the drainage blanket is important in both the initial phase and the long term and is
related to the grading of the material used. The material used must be uniformly graded equivalent to the
specification in Table 2.1 below. The grading should be confirmed via Particle Size Distribution testing on the material
once it has been placed on site.
6 Any drainage aggregate should have a minimum soaked ten percent fines value of 100 kN5.
7 Other drainage media are acceptable provided that the operator explicitly assesses the following issues and
demonstrates that they are suitable for use:
- chemical resistance/compatibility
- strength and physical characteristics
- long term hydraulic performance
- permeability
- transmissivity
- stability
- redundancy
- liner protection
- fires (tyres),
compacted thickness (tyres)
8 Drainage layers, pipework and geotextile separation layers are potentially susceptible to silting and to blockage by
biomass growth and chemical accretions. Any new leachate removal system should be accessible for CCTV and
jetting so that any blockage in the collection pipework can be investigated and removed. Maintainable pipework is
required in all leachate drainage layers. The ability to abstract leachate from the drainage layer is essential in the
short, medium and long term. Polymeric pipes or other materials with equivalent specifications should always be
used.
9 Leachate should be drained to collection sumps located at low points from where it can be removed from the landfill
for disposal or recirculation. Wherever possible, drainage should be designed for ease of access and shorter pumping
mains, and should permit future gravity removal if possible.
10 Leachate should be removed from the drainage collection system by:

- vertical wells;
- side slope risers located on the site perimeter;
by gravity drains through, say, an end bund of a valley site in a landraise site.
4
Recommended gradient to ensure flow towards the sump.
5
Recommended 10% fines value to ensure that the drainage material does not break down under loading and block the
drainage media.

11 During the development of a landfill cell a ‘target pad’ should always be installed in preparation for retro drilling to
replace a failed extraction well and/or monitoring point. The design of the target pad will be site specific, but it is
anticipated that it will comprise a significant local increase in drainage blanket thickness possibly in conjunction with
some sort of liner protection material (reference 83).
12 Leachate extraction wells should have:

- a minimum internal diameter 600mm6;
- walls with slots for leachate ingress only within the permitted leachate level;
- air tight sealing of the top of the well;
- sealing between the well and waste for at least the top 2 metres7;
- appropriate strength and protection;
- [for new wells] provision for access for CCTV and jetting of the leachate collection pipework;
- heavy, lockable, gas tight covers that cannot be removed by one person;
- appropriate written safety procedures for entry;
- been designed to accommodate settlement of the waste around the extraction well and any associated
deflection.
- Designed so as not to damage the liner below
13 Layout of leachate collection and monitoring wells should avoid locations that are difficult to access for monitoring and
abstraction purposes. Lateral movement during waste placement and subsequent settlement is likely to result in
damage to and often loss of the well. The direction of filling can also have an impact on wells. Filling against leachate
wells from the same direction in each lift can result in their failure.
14 Where practicable, side slope risers should permit access for CCTV or jetting and for inspection to validate the design
assumptions. For this, and for pump access, it is important that side slope risers are at a continuous gradient over
their length and do not follow, for example, any intermediate benches in the landfill side slope. The effects of the side
slope riser on the stability of the adjacent liner system should be assessed, together with the need for additional
protection. Side slope risers should be sealed near the surface, i.e. at least the top 2 metres, to prevent air ingress
into the landfill. The design should allow for the use of permanent buried pipework as soon as is practicable to carry
leachate from the removal manholes to the treatment or disposal facility. Pipework outside the lined area should be
constructed to be leakproof and integrity assured.
15 Irrespective of whether leachate is treated on or off site, the operator should consider the measures required to treat
contaminated water and leachate to the appropriate standard required prior to discharge. This should include the
measures described below:
- assessment in accordance with Environment Agency horizontal guidance, H7.
- the necessary wastewater treatment system for the activity including any off site treatment where appropriate; the
identification of the main chemical constituents of the treated effluent (including the make-up of the COD) and
assessment of the fate of these chemicals in the aquatic environment. This applies whether treatment is on or off-
site;
- contingency plans for leachate management in the event of breakdown of various components
- monitoring of leachate quality in accordance with guidance on monitoring of landfill leachate, groundwater and
surface water (reference 67) and the permit.
16 Leachate storage and treatment lagoons should be designed, built and operated to minimise the risk of leakage. As
part of the construction quality assurance procedures, tests on the integrity of the storage (e.g. drop head tests)
should be undertaken. Monitoring systems should demonstrate that leakage is not occurring.
17 The operator of a biodegradable waste landfill can consider leachate recirculation into the waste mass as part of the
leachate management system provided:
- There is an effective leachate drainage and extraction system in the relevant cells of the landfill
- Leachate levels are under control and are being managed in the relevant cells of the landfill
- Landfill gas infrastructure with adequate capacity is in place to extract, collect and treat the volume of landfill gas
from the part of the landfill where recirculation is taking place
- Leachate composition will not impede stabilisation processes within the landfill
- Where necessary the leachate is treated prior to re-introduction to the waste
6
Recommended diameter, so that in the event of a failure, secondary pipework may be fitted within the annulus, or re-
drilling undertaken within existing pipe work at the same location.
7
Recommended depth to prevent air ingress to the site that may impact on gas management and to prevent odours.

- The recirculation system is designed to avoid the formation of preferential pathways within the waste and ensure
an even distribution through the waste
- The recirculation system is designed to prevent odour or amenity problems
- The recirculation system is designed to prevent air ingress into the landfill that may impact on the operation of the
active landfill gas extraction system
18 Leachate recirculation at landfills for hazardous waste will not be permitted.
Recommendation for aggregate drainage materials

British Standard Sieve Size (mm) Percentage Passing (%)
63 100
37.5 85 – 100
20 0 – 25
10 5
4.2.7 Surface sealing
(7) Where the potential hazards to the environment indicate that the prevention of leachate formation is
necessary, surface sealing may be prescribed taking account of the following guidelines-
Landfill Category Non-hazardous Hazardous

Gas drainage layer Required Not Required
Artificial sealing liner Not Required Required
Impermeable mineral layer Required Required
Drainage layer <0.5 metres Required Required
Top soil cover <1 metre Required Required
Capping design should take account of:
- the balance between the requirement to minimise leachate generation and the need to flush
contaminants from the waste;
- the containment of landfill gas;
- the need to physically separate some wastes (e.g. asbestos) from the environment.
Environment Agency guidance on capping and restoration of landfills should be used (reference
85).
Recommendations for surface sealing

1 Hazardous and non-hazardous landfills will normally require a cap. Landfills for inert waste will not normally require a
cap.
2 The capping system should contain:

- a sealing layer
- a surface water drainage system
- cover soils.
3 The operator should determine the appropriate sealing layer on the basis of the hydrogeological and landfill gas risk
assessments (references 65 and 91).
4 The operator should take into account the interactions between all the elements in the capping system in the stability
risk assessment (references 86 and 87)

Recommendations for surface sealing
5 The requirement for a gas drainage layer will depend upon the site-specific gas extraction system. In most
biodegradable landfills retro drilled landfill gas extraction boreholes are the preferred method of gas management.
Gas drainage layers may have a greater role for inorganic landfills where landfill gas will be compositionally and
volumetrically dissimilar to biodegradable landfills.
4.2.8 Risk based design
(8) The requirements of sub-paragraphs (3) to (7) may be reduced to an appropriate extent if on the basis of an
assessment of environmental risks, having regard in particular to Directive 80/68/EEC[14]-
(a) It has been decided in accordance with paragraph 2 that the collection and treatment of leachate is not
necessary; or
(b) It is established that the landfill poses no potential hazard to soil, groundwater or surface water.
4.2.9 Control Of landfill gas
One of the main purposes of the Landfill Directive is to minimise the contribution of landfill sites to
the production of greenhouse gases. This is to be achieved through the following requirements:
- to divert biodegradable municipal waste from landfill;

- to pre-treat waste; and.
- to collect and treat landfill gas from all landfills receiving biodegradable waste.
In order to meet the objectives of the Directive it is necessary to optimise the amount of methane
collected and oxidised to carbon dioxide.
4. – (1) Appropriate measures must be taken in order to control the accumulation and migration of landfill gas.
(2) Landfill gas must be collected from all landfills receiving biodegradable waste and the landfill gas must be
treated and, to the extent possible, used.
(3) The collection, treatment and use of landfill gas under sub-paragraph (2) must be carried on in a manner
that minimises damage to or deterioration of the environment and risk to human health.
(4) Landfill gas that cannot be used to produce energy must be flared.
The Landfill Regulations establish the fundamental principles that landfill gas management must
achieve but they do not provide detailed technical measures.
The Environment Agency will regulate the management of landfill gas in accordance with the
following principles:
- active extraction as early as possible

- passive venting is not acceptable;
- maximising extraction efficiencies;
- emission limits on all point source releases;
- emission monitoring of point and diffuse sources;
- ambient air monitoring on a risk basis.
The Environment Agency has produced detailed technical guidance on the management of landfill
gas comprising of the following documents:

Guidance on the management of landfill gas (LFTGN 03)
Guidance for monitoring trace components in landfill gas (LFTGN 04)
Guidance for monitoring enclosed landfill gas flares (LFTGN 05)
Guidance on gas treatment technologies for landfill gas engines (LFTGN 06)
Guidance on monitoring landfill gas surface emissions (LFTGN 07)
Guidance for monitoring landfill gas engine emissions (LFTGN 08)
Guidance on landfill gas flaring Version 2.1
Guidance on Pumping Trials to Determine Whether Installation of Gas Flaring Systems at Landfill
Sites Can be Justified Version 1.0
Recommendations for landfill gas management

1 The landfill operator should develop a landfill gas management plan based on a site specific risk assessment. The
guidance documents above give detailed guidance on the scope and content of the landfill gas management plan.
Operators should apply an appropriate tier of site specific risk assessment based on the above guidance. For
hazardous and non-hazardous waste landfill sites, this is likely to require the application of a Tier 2 or Tier 3 risk
assessment (LFTGN 03). Probabilistic models of landfill gas generation such as GasSim should be used to predict
gas generation, screen out risks and carry out air dispersion modelling of emissions.
2 Where the risk assessment identifies that landfill gas will be generated, the following elements will be required to
manage landfill gas:
- containment - barriers to prevent sub-surface migration and minimise surface emissions of landfill gas;
- collection - an active gas extraction system to achieve the maximum practicable collection efficiency.
- utilisation, flaring and treatment - a system of combustion or other treatment processes meeting the emission limits
for that process. Treatment of the gas stream pre or post combustion will be a site-specific issue based on the
precise composition of the gas stream.
3 The gas extraction system should be designed and operated to maximize the quantity of landfill gas collected and to
prevent the escape of landfill gas beyond the containment system. The gas extraction system should not be designed
to attempt to extract gas from outside the waste body or the containment system.
4 Pumping trials provide information on how much gas can practically be extracted from the waste. This information
should be used to validate the predicted gas generation rates, the site specific risk assessment, and also to optimise
the extraction well spacing prior to installing the landfill gas extraction scheme.
5 Cells should be designed and operated both for water balance purposes and to minimise the period before active gas
extraction can be installed. Areas of the site that are temporarily capped should have temporary or sacrificial gas
extraction installed. Depending on the site specific risk assessment, gas extraction may be required on operational
areas of the site to control fugitive emissions.
6 Leachate recirculation can increase landfill gas production rates and must take place as part of a controlled landfill
gas and leachate management strategy. Leachate recirculation must not take place until the landfill gas extraction
system is in place to collect and treat the gas generated. The design of leachate recirculation systems should
minimise the risk of air ingress into the body of the waste.
7 The landfill gas collection pipework and extraction system should be designed to adequately deal with the predicted
volume and flow-rate of landfill gas produced. The collection pipework should be laid at an appropriate falls to allow
condensate to drain freely and prevent blockage or restriction of gas flow within the transmission pipework. There
should be adequate provision to de-water the system and drain the condensate back into the waste mass or leachate
treatment system, either by gravity or a pumped system. Condensate should not be drained across the restored
surface of the landfill site.
8 The capacity of the treatment system should be sufficient to deal with the volume of gas generated at the landfill.
Where utilisation is proposed, the flaring capacity should be sufficient to treat all the gas when utilisation equipment is
off line. Where there are a number of gas engines the flaring capacity should be such that it can deal with any
plausible combination of off line engines (i.e. a wide range of gas flows). This may require more than one flare. In the
event of an engine going off line, the landfill gas flare should automatically ignite and flare the gas. The engine
management system should include telemetry to inform the operator of any engine failure.

9 No ‘open‘ flares are to be installed, except for emergency or test purposes. Operational ‘open’ flares at landfills
subject to permitting or re-permitting under the PPC Regulations should be replaced with ‘enclosed’ flares or other
techniques offering equivalent performance. Where appropriate, this requirement may be included within an
improvement schedule, for completion within one year of date of issue of permit.
10 Operators should review their landfill gas management plan and site specific risk assessment on an annual basis
More frequent review will be required if there are changes to the management of landfill gas on site such as:
- an increase or decrease in gas extraction
- change in waste streams
- introduction of leachate recirculation
- changing the number of engines
- changes in the trace component analysis of the gas
- odour issues at the site
11 The annual review should aim to optimise landfill gas extraction by

- estimating gas production
- validating the assumptions made in the risk assessment using site-specific data, especially engine and flare
emission data, and trace component analysis of the raw landfill gas.
- reviewing the monitoring and reporting of gas volumes collected and treated;
reviewing the monitoring of surface fluxes of landfill gas and comparing the collection efficiency against an 85%
benchmark8 (LFTGN 03)
12 Emission limit values in the permit for flare and engine emissions, based on the above guidance documents, are
minimum requirements to be met at all landfill sites. The site-specific risk assessment (i.e. local air quality) may
require additional parameters or more stringent emission limit values to be included in the permit.
For landfill sites where the engines are unlikely to meet the emission limits, the operator should use guidance on the
potential for pre and post combustion clean-up based on a cost benefit appraisal (reference 99) to determine the
appropriate measures.
13 The landfill gas management system shall be operated to minimize potential air ingress into the waste. Air ingress
can cause aerobic conditions within the site leading to elevated temperatures and formation of hot-spots within the
waste. Aerobic conditions will also inhibit the methanogenic bacteria that produce landfill gas. The operator should
propose control levels for oxygen and nitrogen (balance gases) at the wellhead in the Landfill Gas Management Plan.
Concentrations of oxygen must not exceed >5% v/v9 at the wellhead, unless there are justified site-specific reasons
for migration control.
The design of the landfill gas collection infrastructure should take account of potential air ingress and a programme of
inspection and maintenance of the infrastructure should form part of the landfill gas management plan.
A major cause of air ingress is excessive suction being applied to the collection infrastructure through over-
abstraction of landfill gas. Landfill gas extraction schemes should be designed to operate with a maximum extraction
pressure. The operator’s procedures should ensure that the system operates within this limit.
14 Hot spots and fires can be caused by air ingress into the site. Extinguishing fires and cooling hot spots can be
extremely difficult. Preventative measures and early detection are the best options to control the risk. Early detection
can be achieved through routine monitoring of carbon monoxide and gas temperature within the body of the waste
and in the landfill gas collection infrastructure. However routine temperature monitoring at the gas well head can be
quite onerous and result in disruption of the landfill gas extraction system. Therefore monitoring of carbon monoxide
should be routinely undertaken to monitor possible hot spot development. Temperature monitoring should be
undertaken as part of further investigations, should levels of carbon monoxide indicate that there is a possible
problem. The levels of carbon monoxide and temperature can vary depending on the landfill characteristics so
establishing background levels of these indicators is advisable.
Monitoring for carbon monoxide can be carried out using handheld instrumentation during balancing of the gas
extraction system. The presence of hydrogen gas and hydrogen sulphide gas can cause interference in handheld
instruments measuring carbon monoxide; therefore concentrations of these interfering gases should also be carried
out during routine monitoring. Any increase above background levels must be investigated using laboratory analysis
8
LFTGN 03 (2.3.1 pg 21)
9
The 5% oxygen limit is recommended by the Health and Safety Executive (HSE). It gives a large factor of safety before the
minimum 12% oxygen level required for an explosive atmosphere.

to confirm carbon monoxide levels. The routine monitoring should be carried out at the well head wherever possible,
and at such a frequency so that a baseline trend can be established. The operator’s landfill gas management plan
should include details of the frequency and assessment levels for carbon monoxide monitoring and details of likely
further investigations and actions should the assessment level be exceeded. Where no background concentration of
carbon monoxide is available, then a carbon monoxide concentration > 100 ppm10 should trigger further investigation.
15 Landfill gas does pose a risk of fire and or explosion if not managed correctly. The Dangerous Substances and
Explosive Atmospheres Regulations 2002 will apply to landfill sites where landfill gas is present. Operators will need
to carry out a risk assessment to identify hazardous zones and apply control measures to minimise the risk within
those zones. The Environmental Services Association has produced a series of Industry Codes of Practice that
provide detailed technical guidance on application of these regulations to landfill sites.
Indicative Requirements for landfills for hazardous wastes
Compliance with waste acceptance criteria for hazardous wastes implies that organic content will
be very limited and hence there should not be significant acetogenic and methanogenic processes.
Landfill gas will therefore not be the familiar mixture mainly of methane and carbon dioxide,
although low levels of methane production may be found at some of the landfills.
Volatile organic compounds (VOCs) may be present in hazardous wastes such as contaminated
soils, but the waste acceptance criteria limitation on organic content, together with the requirement
for treatment, are likely to limit concentrations of VOCs.
Production of gases such as carbon dioxide, ammonia and hydrogen sulphide is possible by
chemical reaction. Production of hydrogen by reaction with water is known to occur from some
wastes. If generation is significant, such wastes may be prohibited as highly flammable (hazard
H3A).
Unless chemical reactions take place between wastes, there is unlikely to be a significant pressure
differential between the landfill and the environment. It is therefore considered that it is likely that
concentrations and emissions will be low.
Recommendations for landfill gas management at landfills for hazardous wastes

1 Although emissions of landfill gas are unlikely to be high in fine-grained hazardous wastes, until more is known about
the characteristics of such sites, gas migration barriers and gas collection systems/layers should be incorporated into
site designs for hazardous waste landfills. Where landfills are proposed below the ground, the operator should
consider the durability of liners and their permeability to the predicted gases.
2 Landfill gas from hazardous waste landfills should be collected for treatment. Passive venting is not considered to be
best practice.
3 The operator should design the treatment method for the collected gases on the basis of the expected composition,
and sustainability in terms of inputs of materials (such as absorbents or reactants) and energy.
4 As experience is so limited, operators should consider carefully the potential of the proposed waste mix for emission
of gases. If there is doubt about the ability to control emissions in a sustainable way, then the pre-treatment of the
wastes and or the mix of wastes should be considered to eliminate the potential for emissions.
10
This figure is derived from and R&D paper on fires (yet to be published). This referred to >25ppm however this was
considered to be too tight given possible interference on handheld instruments. 100ppm was chosen as this should be
distinguishable above any background or interference.

4.2.11 Stability And settlement
6. – (1) The placement of waste must ensure stability of all the waste on the site and associated structures and in
particular must avoid slippages.
(2) Where an artificial barrier is used, the geological substratum must be sufficiently stable, taking into
account the morphology of the landfill, to prevent settlement that may cause damage to the barrier.
The stability and settlement of the waste, the constructed landform, its foundation and the
environmental management infrastructure and the interactions between them must be assessed.
This is to demonstrate that the environmental management infrastructure will not be compromised,
neither will there be any risk to safety or detriment to the landform over the entire lifecycle of the
landfill. References should be made to the technical reports on the Stability of Landfill Lining
Systems (references 86 and 87). In assessing the landfill engineering proposals for all landfill sites
the structural/physical stability over the entire lifecycle of the landfill must be demonstrated.
Recommendations for stability and settlement

1 The operator should assess the stability of the landfill. The assessment should include:
- Settlement or slippage within the foundation (subgrade) beneath the landfill base or sides;
- Slippage within the liner system;
- Slippage at the waste/liner interface;
- Rotational failure within the waste, or through the whole cross-section;
- Slippage failure of the cap or of its components;
- Effects of settlement on the landfill cap and restoration;
- Effects of settlement on environmental management infrastructure.
The assessment should take account of the presence and movement of waste and leachate.
2 The operator should not analyse waste stability by ascribing to it conventional geotechnical parameters, unless the
waste is homogeneous and its geotechnical properties known. This is because waste is generally a heterogeneous
material subject to decomposition, consolidation, and considerable variation, both spatially and with time. The
operator should justify any assumptions and should undertake sensitivity analysis.
3 For household waste and similar industrial and commercial waste, convenient rules of thumb that the operator may
consider are:
- A maximum finished slope of 1 in 4 will generally provide an acceptable factor of safety;
- For temporary slopes between phases of a landfill, 1 in 2 to 1 in 3 has been found to be satisfactory.
However, as the biodegradable component of landfilled municipal solid waste declines and pre-treatment of waste
increases in response to the Landfill Directive, such rules of thumb will require re-evaluation.
4 Stability and settlement should be monitored in the construction, operational and aftercare phases.
5 Stability can be a problem at the interfaces between geosynthetics and mineral layers. In the formation of all liner
systems it is necessary to construct layers of different materials, either for separate or synergistic purposes. The
operator should consider all potential interactions between layers, both in use and under construction. The interface
friction should be assessed between each layer under all conditions of use, both static and dynamic, temporary or
permanent.

Recommendations for stability and settlement
6 An accurate prediction of settlement is difficult because time-related settlement data are rarely available from surface
measurements. Those data that are available indicate that long-term settlement of biodegradable waste can be
approximated to an exponential curve which could result in most settlement taking place over 30 years with the
majority occurring in an initial 5 year period. Pre-treated wastes with less biodegradable content may have different
characteristics. To anticipate the effects of settlement, designers should add a surcharge to the post-settlement
levels, and distinguish clearly on design drawings the ultimate post-settlement levels and the surcharged levels to
which each phase of the site is to be filled, capped and restored.
If the depth of fill at any point is D on closure, and d ultimately, then:
Settlement = (D-d) ÷ D; whereas

Surcharge = (D-d) ÷ d, and is therefore a higher figure.
Values of 15-25% are typical of the settlement allowance that may need to be made when considering the void
capacity and final pre-settlement contours of a household waste landfill.
7 Where differential settlement may occur, provision should be made to accommodate the settlement and the
associated stresses, most commonly by:
- additional thickness of capping materials to accommodate differential movement or to allow removal of material if
settlement does not occur as predicted;
- irregular edges and boundaries to compensate for predicted settlement differentials.
8 The operator should ensure continuous surface water drainage across areas of differential settlement, for example
using flexible synthetic/membrane channels.
Additional considerations for the landfilling of hazardous wastes

9 Hazardous wastes are likely to be fine-grained materials such as filter cakes and ashes. This waste is likely to be less
heterogeneous than domestic waste, and may be granular, with little cohesion. Whilst the landfill engineering may
play a role in retaining the wastes initially, wastes should have at deposit, or achieve during the active management
phase, sufficient mechanical strength for the creation of a sustainable landform in the long-term.
10 Stability assessment should take account of the site-specific circumstances, and should use geotechnical parameters
appropriate to the waste material as defined by the Landfill Regulations 2002, schedule 1, paragraph 14. Cohesive
materials should have a bearing capacity of not less than 50 kPa. Non-cohesive waste should have an in situ bearing
ratio of at least 5%. Monolithic wastes should have a compressive strength not less than 1MPa.
4.2.12 Construction Quality Assurance (CQA)
It is essential that a quality approach is adopted for the landfill development, in particular for landfill
engineering. Whilst construction quality assurance (CQA) techniques cannot guarantee the works
have been carried out in accordance with the specifications, they should give confidence that the
following requirements have been met:
- Mechanisms are in place to ensure that the construction of the engineered systems will meet the
standards and specifications agreed with the Environment Agency and
- The design, construction and testing are well documented to provide and audit trail.
CQA procedures should follow the guidance given in:
- Framework Policy for Engineering (reference 72)

- Guidance on the use of geomembranes in landfill engineering (reference 74)
- Guidance on the geophysical testing of geomembranes for landfill engineering (reference 75)
- Guidance on non-woven protector geotextiles for landfill engineering (reference 77)
- Guidance on the use of geosynthetic clay liners (reference 78)
- Guidance on the use of bentonite enriched clay soils (reference 79)
- A technical note on the design, construction and quality assurance of compacted clay liners
(reference 80)

- The use of nuclear density gauges for compliance testing of earth works on landfill sites
(reference 81)
- Landfill Engineering: Leachate drainage, collection and extraction services (reference 83)
- Guidance on the management of landfill gas (reference 91)
Recommendations for construction quality assurance

1 A quality approach should be provided for construction and engineering at the landfill. Construction quality assurance
(CQA) is required for all major engineering undertaken at the landfill.
2 CQA should be provided for:

- All elements of basal containment engineering including liners and artificially established geological barriers;
- Sidewall lining;
- Sub-grades for lining;
- Liner protection;
- All elements of the capping system;
- Surface water and groundwater management systems;
- All elements of the leachate management system including leachate extraction wells
- All elements of the landfill gas management system
3 There may be circumstances where landfill gas and other controls need to be implemented in a very short time scale
either for safety purposes, to prevent the uncontrolled release of landfill gas or as emergency repairs to the
management system. In circumstances of this type then the operator can adapt the CQA process accordingly so as
not to delay essential works. This does not remove the need for planned and foreseeable work to be implemented in
accordance with the CQA requirements set out in guidance on the management of landfill gas (reference 91).
4 CQA plans should be submitted sufficiently in advance of the programmed work to allow the Environment Agency to
approve the proposals.
Four weeks is considered a reasonable minimum time for approval to be gained for a CQA plan.
Operators should discuss their programme of works with the Environment Agency to agree a programme of
submission and approval for CQA plans.
The CVs of all office and site based CQA personnel involved in the works should be provided to the Environment
Agency prior to the commencement of the works;
The roles and responsibilities of each member of the CQA team should be outlined within the CQA Plan for the
works;
Approval should be made on the basis of both the qualifications and the experience of the proposed CQA Inspector.
The complexity of the proposed works should also be considered CQA/Design Engineers while generally office based
should ideally be a chartered civil engineer or geologist;
Validation report should be signed by CQA/Design Engineer who should be a chartered civil engineer/geologist;
Stability Risk Assessments should be signed by personnel suitably qualified to carry out this work
5 A validation report should be produced and submitted and should include:

- Details of how the CQA plan has been complied with;
- Justifications for any changes or deviations from the agreed plan
- The results of all testing – this must include the records of any failed tests with a written explanation, details of the
remedial action taken, referenced to the appropriate secondary testing.
- Plans showing the location of all tests.
- ‘As-built’ plans and sections of the works.
- Copies of the site engineer’s daily records
- Records of any problems or non-compliance and the solution applied.
- Any other site-specific information considered relevant to proving the integrity of the construction.
- Validation by a qualified person that all of the construction has been carried out in accordance with the
Construction Proposals.
4.2.13 Waste handling and placement
Recommendations for waste handling

1 Every load should be visually inspected by personnel trained to recognise waste that may not be acceptable, and in
what they should do following its recognition (Section 2.1).

Recommendations for waste handling
2 The size of the working area should be designed for the control of rainwater ingress (Section 2.2.1), stability and
settlement (Section 2.2.9) and nuisance (Section 2.3.3), as well as operational logistics and safety.
3 Waste should be levelled and compacted as soon as it is discharged at the working area.
4 Typically, the density following initial compaction of about 0.8 tonnes/m3 is the optimum for the biodegradation
processes. There is an inverse relation between density and hydraulic conductivity; at typical densities at the base of
deep landfills, waste may have a relatively low hydraulic conductivity.
5 Daily cover principally assists in preventing materials becoming windblown and deterring scavengers, birds and
vermin. The operator should ensure that waste is covered as soon as practicable. Guidance on the use of daily cover
is given in separate Environment Agency guidance (reference 84). Any cover materials used should meet the
objectives of landfill cover set out in the guidance.
6 Difficult wastes - The operator’s risk assessment should identify any wastes which have characteristics that require a
particular method of handling at the site which is not part of normal day to day procedures. Typical examples are:
- finely particulate material;
- empty containers;
- very large objects;
- sludges;
- very light materials, for example expanded polystyrene;
- malodorous wastes.
Consideration should be given to choosing a pre-treatment under Regulation 10(1) to reduce the handling difficulties
posed by such wastes.
Additional considerations for landfill of hazardous wastes

7 The operator should consider the appropriate plant for the emplacement of hazardous wastes. Placement of moist,
fine-grained materials alone may pose problems for typical landfill plant. Sites in Europe accepting such a waste mix
appear not to experience placement problems.
8 The need to cover moist, fine-grained wastes at such sites should be determined by the operator on a site-specific
basis taking into account in particular the particulate matter risk assessment and the landfill gas and odour
assessments. Where relevant the need to prevent exposure to the waste on the site and the need to minimise the risk
of fires must be considered.
Where wastes are not accepted for disposal at the landfill then, unless they are removed by the
delivery vehicle, they should be temporarily stored in a quarantine area.
Recommendations for quarantine areas

1 The operator should have a system for tracking wastes stored in the quarantine area.
2 Storage areas should be clearly marked and signed with regard to the quantity and hazardous characteristics of the
wastes stored therein.
3 The total maximum storage capacity of the quarantine area should be clearly stated in the application, accompanied
by details of the method used to calculate the volumes held against this maximum. The stated maximum capacity of
storage areas should not be exceeded and the application should be updated to reflect any changes before they are
implemented.
4 All containers should be clearly labelled with the date of arrival, a unique reference number or code enabling
identification and, relevant hazard code(s), chemical identity and composition of the waste. All labelling should be
resilient enough to stay attached and legible throughout the whole time of storage at the installation.
5 Storage area drainage infrastructure should ensure that all contaminated run-off is contained, that drainage from
incompatible wastes cannot come into contact with each other and that fire cannot spread between storage /
treatment areas via the drainage system.

Recommendations for quarantine areas
6 Procedures should be in place for the regular inspection and maintenance of storage areas, including drums, vessels,
pavements and bunds. Inspections should pay particular attention to signs of damage, deterioration and leakage.
Records should be kept detailing action taken. Faults should be repaired as soon as practicable. If containment
capacity or capability of bund, sump or pavement is compromised, (unless effecting a repair is more expedient and
working with wastes in close proximity does not compromise safety), then waste should be immediately removed until
the repair is completed.
7 There should be daily inspection of the condition of containers and pallets and written records should be kept of these
inspections. If a container is found to be damaged, leaking or in a state of deterioration, it should immediately be
over-drummed or the contents transferred to another container or processed.
8 All spills of hazardous wastes should be logged, where spills are greater than 200 litre then additionally the
Environment Agency should be informed.
9 Containers should be stored in such a manner that leaks and spills could not escape over bunds/edge of the sealed
drainage area.
4.3 Closure, aftercare and surrender

This section covers the closure requirements for landfills, and the requirements leading up to
surrender of the permit.
4.3.1 Site reports
The PPC Regulations require a site report to be produced at both the application and surrender
stages. The site report required to be submitted as part of the permit application shall, ‘describe the
condition of the site of the installation… and shall, in particular, identify any substance in, on or
under the land which may constitute a pollution risk’ (paragraph 1(2) of Schedule 4). For any
landfill part of an installation this requirement is generally satisfied by the Environmental Setting
and Installation Design (ESID) report, plus risk assessments.
The surrender application must contain ‘a site report describing the condition of the
site…identifying, in particular, any changes in the condition of the site as described in the site
report contained in the application for the permit’ (Regulation 19 (3)(c)). The surrender application
must also contain ‘a description of any steps that have been taken to avoid any pollution risk on the
report site resulting from the operation of the installation…or to return it to a satisfactory state’
(Regulation 19(3)(d)).
Guidance on Site Reports and the protection of land under the PPC Regime can be found in
Environment Agency guidance H7 and H8 (references 46 and 47). For the areas of permanent
deposits of wastes, further guidance can be found in Environment Agency guidance on landfill
completion and surrender (reference 103).
Regulations 15 and 16 of the 2002 Regulations
15. – (1) The following closure and after-care procedures shall apply to all landfill sites.
(2) The procedures may relate to the closure of the whole of the landfill or part of it.
(3) The closure procedure shall begin -
(a) when the conditions specified in the landfill permit are satisfied;
(b) when the Environment Agency approves the initiation of the closure procedure following a request from the
operator; or
(c) by a reasoned decision of the Environment Agency which shall be set out in a closure notice served on the
operator in accordance with regulation 16.
(4) A landfill shall not be definitively closed until –

(a) such reports as may be required by the Environment Agency have been submitted to it by the operator; and
(b) the Environment Agency –
(i) has assessed all the reports submitted by the operator;
(ii) has carried out a final on-site inspection; and
(iii) has notified the operator by notice in writing served on the operator that it approves the closure.
(5) Following definitive closure of a landfill, after-care procedures shall ensure that –
(a) the operator remains responsible for the maintenance, monitoring and control for such period as the
Environment Agency determines is reasonable, taking into account the time during which the landfill could
present hazards;
(b) the operator notifies the Environment Agency of any significant adverse environmental effects revealed by
the control procedures and takes the remedial steps required or approved by the Environment Agency; and
(c) the operator is responsible for monitoring and analysing landfill gas and leachate from the landfill and the
groundwater regime in its vicinity in accordance with Schedule 3 for as long as the Environment Agency
considers that the landfill is likely to cause a hazard to the environment.
(6) Notwithstanding regulations 19 and 21 of the 2000 Regulations (requirements on surrender or revocation of
permits), the Environment Agency shall not accept any complete or partial surrender of the landfill permit, or
revoke it in whole or part, for as long as the Environment Agency considers that the landfill (or the relevant part of
it) is likely to cause a hazard to the environment.
(7) The operator shall not be relieved from liability under the conditions of the landfill permit by reason of the
Environment Agency’s approval of closure under paragraph (4)(b)(iii).
16. – (1) Where the Environment Agency has taken a reasoned decision under regulation 15(3)(c), it shall serve a closure
notice under this regulation (‘a closure notice’) on the operator of the landfill.
(2) A closure notice shall –
(a) state the Environment Agency’s reasons for requiring initiation of the closure procedure;
(b) specify the steps the operator is required to take to initiate the procedure; and
(c) the period within which they must be taken.
(3) The Environment Agency may withdraw a closure notice at any time.
Landfill closure process
Closure procedures can be instigated for all or part of a landfill and so separate areas or phases of
a landfill might be expected to go through the closure procedures at different times. When the site
ceases accepting waste for disposal it is considered to be ‘closed’. The landfill operator must
provide the Environment Agency with reports (a Closure Report) to describe how the site will be
managed and monitored in the aftercare phase to ensure that it does not cause pollution or harm.
Once the Environment Agency is satisfied that such measures are in place and adequate it will
inspect the site and confirm in writing that the site is ‘definitively closed’. The site or part thereof
will then enter the aftercare phase.
The objective of the final site inspection is to confirm that the information provided by the operator
in the closure report adequately addresses all the issues required by the Landfill Regulations and
as a final check to confirm that all the authorisation conditions are being complied with. The
Compliance Assessment Report (CAR) form should be used as a guide to final inspection, but the
additional issues for the purposes of the Landfill Regulations also need to be considered. The
inspection will be undertaken by the Environment Agency officer with the most appropriate
experience/ knowledge of the site and issues to be addressed.
Definitive closure may be agreed on installation of the cap, drainage layer and such soils as are
required to protect the cap, i.e. the pollution prevention structures. It need not include full
restoration, planting and contouring as may be required by any planning permission.
Once the Environment Agency notifies the operator in writing that it approves the closure, the site
will be definitively closed and may enter the aftercare phase.
The aftercare phase
A site closure plan should be developed as part of the permit application for the site to ensure that
the installation is maintained to avoid any pollution risk up to the point of surrender, when the site

no longer poses a pollution risk. This plan will need updating on a regular basis to take account of
revisions to working practice and monitoring results.
The aftercare phase will last until the Environment Agency is satisfied that the site is no longer
likely to cause a hazard to the environment (when completion occurs, and the permit is
surrendered). Operators of sites that have reached the aftercare stage will therefore:
- remain bound by the conditions of the waste management licence or PPC permit until it is
successfully surrendered;
- remain responsible for maintenance, monitoring and control of the site for as long as the
Environment Agency consider is reasonable, taking into account the length of time during which
the site could present hazards;
- be obliged to notify the Environment Agency if the control procedures reveal any significant
adverse environmental effects and take any remedial actions required or approved by the
Environment Agency;
- remain responsible for monitoring and analysing landfill gas and leachate and any other
emissions from the landfill along with groundwater in the vicinity of the site, for as long as the
Environment Agency considers that the landfill is likely to pose a pollution risk;
- be required to undertake the monitoring and analysis referred to above in accordance with the
requirements set out in Schedule 3 of the Landfill Regulations.
Landfill completion (and surrender)
A long-term risk assessment must be produced for the whole lifecycle of the site at the application
stage. Completion should form part of the overall risk assessment process for the landfill and
needs to be directly considered at the permitting stage (reference 103). Site specific indicative
completion criteria should be put forward at the PPC application stage as part of the
hydrogeological, landfill gas and stability risk assessments.
The operator should recognise that the objective of the legislation with respect to surrender is to
ensure that sites remain under regulatory control until there is no longer a need for such control.
PPC permits and Waste Management Licensed landfills have the same basic requirement, to
ensure that surrender of the authorisation does not take place until the Environment Agency
consider the landfill no longer poses any pollution risk.
It is important to note that at completion, a site may not be at all suitable for development. It simply
confirms that the Environment Agency consider that additional or active control measures are
unlikely to be required to prevent pollution or harm as a result of emissions from the undisturbed
site. Development work which disturbs the contents of the site or which was not identified as a
receptor in the risk assessment conducted to demonstrate completion will not have formed part of
that decision.
Recommendations for closure, aftercare and completion and surrender

1 The operator should maintain a site closure plan.
2 Care should be taken at the design stage to minimise risks during decommissioning. For existing installations, where
potential problems are identified, a programme of improvements should be put in place to a timescale agreed with the
Environment Agency. Designs for parts of the installation outside the landfill area should ensure that:
- Underground tanks and pipework are avoided where possible (unless protected by secondary containment or a
suitable monitoring programme)
- There is provision for the draining and clean-out of vessels and pipework prior to dismantling
- Lagoons are designed with a view to their eventual clean-up
- Insulation is provided that is readily dismantled without dust or hazard
- Materials used are recyclable (having regard for operational or other environmental objectives)
3 The site closure plan for parts of the installation outside the landfill area should include:
- Either the removal or the flushing out of pipelines and vessels where appropriate and their complete emptying of
any potentially harmful contents
- Plans of all underground pipes and vessels
- the method and resource necessary for the clearing of lagoons

Recommendations for closure, aftercare and completion and surrender
- the removal of asbestos or other potentially harmful materials other than from the landfill unless agreed that it is
reasonable to leave such liabilities to future owners
- methods of dismantling buildings and other structures,
- testing of the soil to ascertain the degree of any pollution caused by the activities and the need for any remediation
to return the site to a satisfactory state as defined by the initial site report
4 The Site Closure Plan should be reviewed at least once every four years. Other triggers for the review of the site
closure plan would include any proposed changes to the phasing of the landfill. The plan should be kept updated as
material changes occur.
5 Monitoring plays a vital part in determining the performance of the landfill against any assumptions made and the
annual reviews should consider the progress made towards the initial completion criteria. The operator should review
the completion criteria including the following factors:
- quality and quantity of leachate;
- generation, flow and concentration of gas;
- trace composition of the gas;
- potential for leachate or gas to be generated in future;
- physical stability of the waste and associated structures;
- presence of particular problem wastes which could present a risk in the future.
The review of the completion criteria should be undertaken a least once every four years. Another trigger for a review
of the completion criteria would be where the annual review of monitoring data against the assumptions in the risk
assessment indicates a significant deviation from the expected performance of the landfill.
The Environment Agency has produced guidance on landfill closure in its Regulatory Guidance
Note 7 (Reference 102) and its frequently asked questions on landfill closure (Reference 102A).

5. EMISSIONS AND MONITORING
5.1 Emission benchmarks
Guidance is given below on release concentrations or mass release rates achievable for key
substances using the best combination of techniques. These benchmarks are not mandatory
release limits and reference should be made to Section 1 and references 91, 92, 93, 94 regarding
their use.
Care should always be taken to convert benchmark and proposed releases to the same reference
conditions for comparison. The guidance on monitoring landfill gas engine emissions and guidance
on monitoring enclosed landfill gas flares (references 93 and 94) set out how to convert measured
values to reference conditions. The benchmarks given in section 3.2 do not take sampling,
analytical errors or uncertainties into account.
Limits in permits may be set for mean or median values over long or short periods. The periods and
limits selected should reflect:
- the manner in which the emission may impact upon the environment
- likely variations which will arise during operation
- possible failure modes and their consequences
- the capabilities of the monitoring and testing system employed
5.2 Emission of landfill gas

Reference must be made to the relevant technical guidance that supports this document (See
Section 4.2.9 and references 91, 92, 93 and 94).
5.3 Emissions to water

Guidance is given on emissions from leachate treatment plant in a separate document, Guidance
on the treatment of hazardous and non-hazardous landfill leachate (reference 58).
Significant releases are likely to include leachate treatment plant, and surface water discharges.
The Environment Agency will follow its guidance H1 (reference 41) when deciding which limits to
specify in any discharge to sewer.
Limits in permits may be set for mean or median values over long or short periods. The periods and
limits selected should reflect:
- the manner in which the emission may impact upon the environment
- likely variations which will arise during operation
- possible failure modes and their consequences
- the capabilities of the monitoring and testing system employed
Where automatic sampling systems are employed, limits may be defined such that:
- not more than 5% of samples shall exceed the benchmark value
5.4 Standards and obligations

There are also national and international standards and obligations that must either be
safeguarded through the permit or, at least, taken into account in setting permit conditions. This is
particularly the case for any EC-based EQSs.

5.4.1 EC-based EQ standards
IPPC: A Practical Guide explains how these should be taken into account and contains an annex
listing the relevant standards (reference 25). They can be summarised as follows:
Air quality
- Statutory Instrument 2000 No.928, Air Quality (England) Regulations 2000 gives air quality
objectives to be achieved by:
- 2005 for nitrogen dioxide
- 2004 for SO2 and PM10
- 2003 for CO, 1,3-butadiene and benzene
- in two stages for lead by 2004 and 2008 respectively
- Statutory Instrument 2002 No. 3043 The Air Quality (England) (Amendment) Regulations 2002,
which sets a tighter objective for CO and a longer-term objective for benzene to be achieved by
2010.
Surface Water quality
- Directive 76/464/EEC on Pollution Caused by Dangerous Substances Discharged to Water

contains two lists of substances. List I relates to the most dangerous and standards are set out in
various daughter Directives. List II substances must also be controlled. Annual mean
concentration limits for receiving waters for List I substances can be found in SI 1989/2286 and
SI 1992/337 the Surface Water (Dangerous Substances Classification) Regulations. Values for
List II substances are contained in SI 1997/2560 and SI 1998/389. Daughter Directives cover
EQS values for mercury, cadmium, hexachlorocyclohexane, DDT, carbon tetrachloride,
pentachlorophenol, aldrin, dieldrin, endrin, isodrin, hexachlorobenzene, hexachlorobutadiene,
chloroform, 1,2-dichloroethane, trichloroethane, perchloroethane and trichlorobenzene.
Other waters with specific uses have water quality concentration limits for certain substances.
These are covered by the following Regulations:– SI 1991/1597 Bathing Waters (Classification)
Regulations– SI 1992/1331 and Direction 1997 Surface Waters (Fishlife) (Classification)
Regulations– SI 1997/1332 Surface Waters (Shellfish) (Classification) Regulations– SI 1996/3001
The Surface Waters (Abstraction and Drinking Water) (Classification) Regulations
5.5 Units for benchmarks and setting limits in permits

Releases can be expressed in terms of:
3
- ‘concentration’ (for example mg/l or mg/m ), which is a useful day-to-day measure of the
effectiveness of any abatement plant and is usually measurable and enforceable. The total flow
must be measured/controlled as well,
- ‘specific mass release’ (for example, kg/ product or input or other appropriate parameter), which
is a measure of the overall environmental performance of the plant (including the abatement
plant) compared with similar plants elsewhere,
- ‘absolute mass release’ (for example, kg/hr, t/yr), which relates directly to environmental impact.
When endeavouring to reduce the environmental impact of an installation, its performance against
each of these benchmarks should be considered, as appropriate to the circumstances, in
assessing where improvements can be made.
When setting limits in permits, the most appropriate measure will depend on the purpose of the
limit. It may also be appropriate to use a substance as a surrogate for others. These may be
monitored on a regular basis, supported by less frequent check-analyses of a wider range of
substances.
For water, UK benchmarks or limits are most frequently 95 percentile concentrations or absolute
concentrations, (with flow limited on a daily average or maximum basis).

5.6 Nuisance
5. – (1) Measures must be taken to minimise the nuisance arising from the landfill in relation to-
(a) emissions of odours and dust;
(b) wind-blown materials;
(c) noise and traffic;
(d) birds, vermin and insects;
(e) the formation of aerosols; and
(f) fires.
(2) The landfill must be equipped so that dirt originating from the site is not dispersed onto public roads and
the surrounding land.
11
The Landfill and PPC Regulations require that the Environment Agency regulate nuisance .
Nuisance is also regulated through the planning system. Normally an environmental impact
assessment will address nuisance issues. For the majority of potential emissions, effective controls
can only be applied through design and operational measures applied through the permit
application and conditions. Setting nuisance conditions to comply with the Landfill and IPPC
Directives will be carried out in consultation with the local authority.
Recommendations for nuisance management

1 All of the potential impacts of a landfill site should be identified at the risk screening phase of the conceptual model
development and refined at the planning application stage. Detailed measures to mitigate the impacts should be
included in the landfill design and set out in the permit application.
2 The operator should consider the prevailing wind direction and strength when planning the filling direction and
sequence. This will assist in the general reduction of nuisance caused by odour, dust, litter and noise. Careful
phasing is critical in minimising these airborne emissions.
3 The operator should consider the intended method of operation in designing the site, its environmental protection
measures, and their phased development.
5.6.1 Particulate matter
Recommendations for particulate matter control – dust and aerosols

1 Procedures should be in place to deal with particulate matter arising from:
- the placement of wastes;
- traffic on site roads during periods of dry weather;
- site preparation and restoration activities;
- surface emissions;
- carriage of dust/mud onto the highway.
2 The choice of abatement should achieve the required environmental benefits, at proportionate effort and cost and
must take into account the following issues:
- abatement of particulate matter at the source of generation is likely to be more effective than suppression of
particulate matter once they have become airborne;
- particle size is very important - coarse particles have much greater settling rates than finer particles: coarse
particles will settle out as deposited dust quite close to the source; whereas fine particulate matter may remain
airborne for longer periods and travel much greater distances. These are implicated more in health exposure
impacts. There is no sharp dividing line between the sizes of suspended particulate matter and deposited
particulate matter, although particles with diameters >50 mm tend to be deposited quickly and particles of diameter
11
The term ‘nuisance’ is not used in Environment Agency permits to avoid confusion with ‘statutory nuisance’
that is regulated by the local authority. Instead the phrase ‘cause annoyance’ is used to reflect that these are
issues that may result in harm to human health.

Recommendations for particulate matter control – dust and aerosols
<10 mm have an extremely low deposition rate in comparison;
- many dust-suppression techniques are ineffective for the finer particles;
- biological activity - Much particulate matter (solid or liquid droplets) from some landfills is biologically active.
Biological aerosols (bioaerosols) consist of finely divided biological organisms suspended in air. These aerosols
can vary in size from 0.5 to >100 µm and can occur as aggregates, as droplets or attached to inert dust particles.
Bioaerosols are complex in nature, and may include: viruses, bacteria, actinomycetes, fungi, enzymes, endotoxins,
mycotoxins and glucans. They can affect organisms by infection, allergy, toxicity, pharmacological and other
processes. Bioaerosols are most likely to be formed when degrading waste is disturbed.
3 The site design should minimise the area left uncovered. Restoration should take place as soon as possible following
the end of waste disposal in a cell or phase.
4 Surfaced site roads should extend as far as possible to the tipping face and should be kept for as long as possible.
Surfaced site roads should be maintained and kept in a clean condition.
5 The operator should control the movements of site traffic including restrictions on routes and speeds.
6 Wheel washers should be located far enough from the site entrance to allow any residual debris to be deposited
within the site.
7 Dust suppression should be provided including the availability of ‘bowsers’ and water supplies. Leachate should not
be used for dust suppression.
8 Particulate monitoring programmes should be developed for the categories of particulate matter identified in M17
(reference 51). The waste streams and substances identified in the selection of appropriate Environmental
Assessment Levels (EALs) (see M17 and IPPC H1 references 51 and 48) would form the basis for the monitoring of
hazardous substances. The monitoring programmes should be reviewed until the appropriate frequencies and
parameters can be determined on a site specific basis.
Additional considerations for the landfilling of hazardous wastes

9 The placement of hazardous fine-grained materials poses a potential risk of wind-blown dust unless control measures
such as primary cover or wetting are used. Cover and wetting should be the subject of risk assessment, taking
account of the specific waste types and receptors. An alternative approach is to treat the waste to solidify or pelletise
it.
5.6.2 Litter
The term litter should be taken to mean any wind-blown material other than particulate matter.
Litter is an important potential cause of pollution from landfill installations and measures must be in
place in order to:
- Prevent the formation of litter by controlling potentially wind-blown materials;
- Capture litter that is generated;
- Manage accumulations of litter within the installation;
- Collect litter from beyond the boundary of the installation.
Recommendations for litter control

1 The operator should manage accumulations of litter within the site and prevent litter escaping from the site.
2 The operator should manage the generation of litter through the following measures:
- Instructions to ensure incoming waste remains sheeted for as long as possible prior to emplacement (see section
2.1 on the requirements for visual inspection of wastes);
- Provision of an emergency tipping area to allow discharge of light waste within a secure litter enclosure during
adverse weather; this may be a permanent fixture or mobile;
- Adequate compaction during waste emplacement;
- Adequate covering of wastes following emplacement;
- Minimising the extent of the active tipping area;
- Adequate plant on active phase for placement, compaction and covering of waste;
- Ensuring the adequate supply of daily and intermediate cover material;
- daily meteorological monitoring, as part of the daily and weekly operations;

Recommendations for litter control
- instructions to ensure the full discharge of a vehicle discharging waste at the site, to prevent any waste retained in
the vehicle after tipping being subsequently released;
- closure of the site to specific or all waste types during adverse weather conditions.
3 The operator should prevent litter escaping the site through the following measures:
- consideration of prevailing wind direction and strength and the proximity of receptors when designing the filling
development and sequence, this may require a risk assessment approach;
- installation of permanent and mobile litter fences around the active area;
- the installation of temporary bunds immediately adjacent to tipping area;
- regular inspections and collection of litter around the site boundary and beyond; specifically, ditches, haul roads,
water courses;
- deployment of additional temporary personnel to collect litter, as deemed necessary from inspections and
monitoring.
5.6.3 Birds and other vermin
Birds can be attracted to landfill sites in large numbers, particularly where sites receive appreciable
amounts of food wastes. Usually only large birds such as gulls and corvids are regarded as a
problem.
Other than birds, rats and flies are the main pests that require control. Sites with extensive non-
operational land can also become infested with rabbits.
Recommendations for bird and other vermin control

1 The operator should have procedures to deal with the presence of scavenging birds which should be consider:
- the deposit of excrement and scraps of food on mobile plant and vehicles on-site, reducing driver's visibility and
damaging nearby property;
- bird-strike damage to aircraft;
- the introduction of pathogens to nearby water bodies, crops and animals;
- the introduction of alien species to sensitive local habitats.
2 Measures which can be used to mitigate bird nuisance should include the employment of good landfill practice, with
prompt disposal and compaction, working in small active areas with progressive covering of waste (if appropriate),
and netting, together with the use of bird scaring techniques. These measures include:
- flying birds of prey over the site;
- bird kites mimicking birds of prey;
- shell crackers - containing flare and bangers;
- rope bangers;
- gas cannons;
- scarecrows - fixed or mobile;
- amplified recordings of bird distress calls (species specific);
- electronic sounds imitating calls of distress;
- bird corpses or dummies.
Measures involving explosions or distress calls have inherently adverse environmental impacts in terms of noise and
may scare desirable species living in the vicinity of the site.
3 A log of techniques employed should be maintained by the operator to demonstrate compliance with requirements
and as part of the performance monitoring system. The log will also assist in assessing the effectiveness of the
different methods employed.
4 There are advantages and disadvantages to all of the methods and the degree of effectiveness of any method may
deteriorate with time and may need to be changed regularly. The measures used should be subject to a periodic
review by the operator.
5 The operator should take into account the new set of aviation safety standards which was introduced by the
International Civil Aviation Organisation in 2003. One of these standards relates to bird hazard reduction at, or in the
vicinity of aerodromes, particularly large numbers of flocking birds feeding at landfill sites. The new standard states

Recommendations for bird and other vermin control
that:
garbage disposal dumps or any such other source attracting bird activity on, or in the vicinity of an aerodrome
shall be eliminated or their establishment prevented, unless an appropriate study indicates that they are
unlikely to create conditions conducive to a bird hazard problem.
6 For new landfill sites within 13 km of an aerodrome, existing planning controls require consultation with the Civil
Aviation Authority.
7 The operator should use the following measures to deal with pest infestation:
- effective site management involving prompt emplacement, compaction and covering of wastes in well-defined cells,
intermediate capping and prompt capping of completed areas;
- ensuring previously employed waste is not disturbed, exposed or moved;
- regular visits by pest control contractors or fully trained operatives;
- inspection and treatment of areas where rats live, for example sewers, culverts and drains.
8 Fly infestations commonly arise from waste that has been awaiting collection for some time. Procedures should be in
place to prevent or limit the acceptance of such wastes. The operator should reduce the risk of infestation by prompt
burial of such wastes in order to interrupt the reproductive cycle of the fly. The potential for fly infestation to develop
should also be considered if engineering works require waste to be re-excavated.
5.6.3 Landfill fires
Current understanding suggests that the two primary causes of landfill fires are vandalism and poor
practice in the management of landfill gas.
Recommendations for preventing fires

1 Measures should be taken to ensure that the risk of fires are minimised by:
- site security to prevent unauthorised access;
- prompt emplacement, compaction and covering of wastes in well-defined cells;
- prompt capping of completed areas;
- prevent air ingress in to the waste and gas extraction and collection systems.
2 Waste acceptance procedures should preclude the acceptance of hot or reactive wastes.
3 Fires should be reported to the Environment Agency and must be extinguished as soon as possible.
5.6.5 Mud on the road
Recommendations for preventing mud on the road

1 The management of the landfill should include the following measures to prevent mud escaping from the site, to
prevent potential accident hazards, dust and other amenity issues.
- effective wheel and body cleaners to remove mud and debris from vehicles prior to their leaving the site;
- maintenance (e.g. regular water changes for wet systems) of wheelwash equipment;
- supervision of the use of wheelwash to ensure that vehicles use the equipment correctly;
- main site roads maintained in a mud free condition by employing a mechanical sweeper/washer;
- sufficient distance on surfaced site roads between haul roads and any wheel wash facilities;
- monitoring of site road between final wheel wash and public highway;
- monitoring of public highway
2 In the event that mud or other debris is carried onto the public highway, warning signs to inform users of the potential
hazard should be erected on the highway following approval by the highway authority.
3 Road sweepers should be employed immediately to clean the affected area.

5.6.6 Odour
The operator should consider the issues below to address odour:
- Identification of sensitive receptors, in particular the type of receptor, location relative to the odour
sources and an assessment of the impact of odorous emissions on the receptors.
- An overview of any complaints received, what they relate to (source/operation) and remedial
action taken. The types and source of odorous substances used or generated, intentional and
fugitive unintentional) release points and monitoring undertaken.
- A description of the procedures in place to prevent and/or minimise odour annoyance or each
odour source.
- Identification of any circumstances or conditions which might compromise the ability to prevent or
minimise odour annoyance, and a description of the actions that will be taken to minimise the
impact.
Odour is typically associated with trace components in landfill gas, the handling of odorous wastes
and inadequate emplacement and covering of biodegradable wastes. Given the fugitive nature of
odour emissions, emphasis should be given to preventative measures relating to landfill gas
management (see section 2.2.7) and waste acceptance and emplacement (see sections 2.1 and
2.3.2).
Odours should be minimised through good practice in waste handling and emplacement and the
management of leachate and landfill gas. The document IPPC H4 gives general guidance on the
control of odour at IPPC facilities (references 44 and 45). The Environment Agency’s internal
guidance on the regulation of odour at waste management facilities (reference 100) is also relevant
to permitted sites.
Recommendations for odour control

1 The management of odour should include procedures dealing with:
- waste materials, such as wastes from transfer stations, which have decomposed significantly prior to landfilling;
- old waste disturbed by digging;
- malodorous wastes;
- agricultural and sewage treatment residues;
- leachate and leachate treatment systems;
- landfill gas.
2 Procedures should be in place to maintain information relating to sensitive receptors including:

- Type of receptor, location relative to the odour sources and, where undertaken, description of the findings of any
assessment of the impact of odorous emissions on the receptors.
- Details of any routine monitoring undertaken to assess odour exposure of receptors
- An overview of any complaints received, what they relate to (source or particular operation) and remedial action
taken.
3 Procedures should be in place to maintain a description of the types of odorous substances deposited/disposed of
and generated (intentional and fugitive (unintentional)). This should include:
- the treatment applied before landfill, which should limit wastes that are inherently odorous.
- the distinction between wastes which are inherently odorous where the impact is likely to be more immediate and
those wastes that may give rise to odour because of microbiological action in the landfill (organic or inorganic).
4 Procedures should be in place to maintain a description of the point, linear or area sources of release.
5 In order to reduce the release of odorous compounds and their impact at sensitive receptors, the minimisation of
odour should be considered in relation to:
- the types of wastes;
- site layout;
- engineering aspects of the operation;
- management procedures;
- and the day-to-day operational practices.

Recommendations for odour control
6 A structured odour management plan should be developed and maintained including:
- Control measures to prevent or control odour.
- A demonstration/justification that there will not be an odour problem from the emissions under normal conditions.
- A description or copy of any conditions or limits put in place by any regulatory authority, which relate to the
prevention of minimisation of odour.
- Identification of the actions to be taken in the event of abnormal events or conditions which might lead to odour, or
potential odour problems.
- An understanding of the impact in the event of abnormal events or conditions, for example the failure of a landfill
gas flare. This may require modelling the dispersion of odours under such circumstances.
- Monitoring undertaken.
- Communication with for example local residents if an odour problem arises or is likely to arise.
Odour control is not a once-off activity and requires a constant re-evaluation of control techniques and this should
form part of the odour management plan.
7 The operator should undertake a regular odour impact assessment. The impact assessment should cover a range of
reasonably foreseeable odour generation and receptor exposure scenarios and the effect of different mitigation
options. Assessment should include point sources (for example flares) as well as linear or area sources (tipping
faces, cracks in the cap etc.).
8 Waste Acceptance
- sulphate wastes should be disposed of in cells in which biodegradable waste is not accepted (reference 56).
- co-ordination between the gatehouse and operators at the tipping face should take place where known odorous
wastes are to be deposited.
- excavation of waste or removal of cover during for example the installation of gas wells, or for other operational
needs, may give rise to odours
9 Covering of wastes.
- Tipping areas should be kept as small as possible.
- Waste should be covered as soon as possible.
- On areas of intermediate capping, the degree of capping should be sufficient to prevent the possible release of
odours. After the initial tipping and compacting it is likely that the odours will tend to become more characteristic of
anaerobic degradation/landfill gas. This phase should coincide with an increase in gas abstraction capacity.
10 Landfill Gas management

Certain odorous trace compounds in landfill gas have low odour thresholds. These include organo-sulphur
compounds, cyclic compounds, aromatic hydrocarbons, esters and carboxylic acids, which derive from microbial
interactions. An effective landfill gas management plan (see Section 2.2.7) in conjunction with good operational
practice (i.e. not leaving odorous waste uncovered) should be implemented to prevent such releases. Full
containment of the waste, including temporary and/or phased capping of the site, in addition to incorporating an active
landfill gas control system should be applied as odour control measures. Point source emissions such as those from
landfill gas flares should be considered in the selection and assessment of the control system.
Landfill gas control systems should be well constructed, operated and maintained.
Passive venting during the early operational stages may give rise to odours and active extraction systems should be
installed to minimise the release of uncontrolled landfill gas emissions.
11 Leachate management
An enclosed treatment operation should be used where the proximity of the operation to receptors is likely to cause
nuisance.
Enclosed storage of leachate should be provided where it is close to a sensitive receptor.
Leachate sumps/ wells/ side wall drainage systems should be effectively sealed (retaining any necessary access for
monitoring and maintenance).
5.6.7 Noise
Within this section ‘noise’ should be taken to refer to ‘noise and/or vibration’ as appropriate,
detectable beyond the site boundary. Where noise issues are likely to be relevant, the operator will
be required, in the Application, to provide information on the following: (for more details on noise
see references 42, 43 and 101):

- the main sources of noise and vibration that will fall within the IPPC installation and also on
infrequent sources of noise and vibration
- the nearest noise-sensitive sites
- conditions/limits imposed under other regimes
- the local noise environment
- any environmental noise measurement surveys, modelling or any other noise measurements
- any specific local issues and proposals for improvements.
The level of detail supplied should be in keeping with the risk of causing noise-related annoyance
at sensitive receptors. Where an installation poses no risk of noise-related environmental impact
because the activities undertaken are inherently quiet, this should be justified and no further
information relating to noise need normally be supplied. There can still be an underlying level of
annoyance without complaints being made.
Recommendations for noise and vibration control

1 The operator should develop and maintain a noise action plan detailing any mitigation and control that are intended to
be used, or required to be used (for example under planning conditions), to reduce the noise to an acceptable level
2 The operator should apply the following measures:

- regular and effective maintenance by trained personnel of any parts of plant or equipment whose deterioration may
give rise to increases in noise (including the maintenance of plant and equipment, buildings as well as specific
noise attenuation measures associated with plant, equipment or machinery);
- training of site personnel in the need to minimise noise;
- siting of noisy equipment away from receptors and accounting for prevailing wind direction;
- where short term noisy operations have to be undertaken, there often has to be a trade off in terms of a higher
noise level for a shorter period versus less noise but of longer duration. For example during site preparation,
working longer hours, or using more plant (or larger plant) may be preferable if it results in noisy operations being
completed in a much shorter time;
- early notification of local residents or at least inform them in advance of work being started, likely timescale and
telephone number if disturbance occurs;
- regular maintenance of the access roads to repair ‘pot-holes’; this serves to significantly reduce noise generated by
empty vehicles;
- operating only within the agreed / planning permission operating hours
3 Construction of any sound bunds/barriers around the ‘active’ cell, landfill gas flares or other areas, should be in
accordance with BS 5228 199737;
4 Additional measures that may be required are:

- modification of existing plant to reduce noise;
- replacement of older site plant with modern quieter designs
5 The design criteria of enclosed landfill gas flares should include noise reduction.
6 Where appropriate, monitoring of noise should undertaken at a frequency agreed with the Environment Agency,
based on the risk assessment

5.6.8 Traffic
Recommendations for traffic management

1 Traffic impact is a major factor for consideration at the site design and planning stage and is often dealt with by
planning conditions. It can also be covered by a legal agreement under S106 of the Town & Country Planning Act
1990. Consideration should be given to:
- routing vehicles to and from the site via major roads wherever possible;
- routing to avoid residential areas;
- using one-way routes to avoid traffic conflict in narrow roads;
- carrying out road improvements, for example, strengthening road haunches, improved provision of footpaths,
improvement of sight lines, provision of passing places or lay-bys, provision of new roads;
- limiting the number of vehicle movements;
- restrictions on working hours;
- limiting vehicle size;
- alternative means of transporting waste, for example rail, barge and conveyor transport;
- whether additional traffic control measures are required for major contracts e.g. import of materials required for site
engineering.
5.7 Monitoring
This section describes monitoring and reporting requirements for emissions to all environmental
media. Guidance is provided for selecting the appropriate monitoring methodologies, frequency of
monitoring, compliance-assessment criteria and environmental monitoring.
14. – (1) The following requirements shall apply to landfill sites from the start of the operational phase until
definitive closure.
(2) The operator shall carry out the control and monitoring procedures set out in Schedule 3.
(3) Where the procedures required by paragraph (2) reveal any significant adverse environmental effects, the
operator shall notify the Environment Agency as soon as reasonably possible.
(4) When it receives a notification of significant adverse environmental effects in accordance with paragraph (3),
the Environment Agency shall determine the nature and timing of corrective measures that are necessary
and shall require the operator to carry them out.
(5) The operator shall report at intervals specified by the Environment Agency, on the basis of aggregated data,
the results of monitoring and on such other matters which the Environment Agency requires to demonstrate
compliance with the conditions of the landfill permit or to increase its knowledge of the behaviour of waste in
landfill.
(6) The operator shall ensure that quality control of –
(a) analytical operations of control and monitoring procedures; and
(b) analyses of representative samples taken in accordance with regulation 12(2),
is carried out by competent laboratories.
Closure and after-care procedures for landfills
15. – (5) (c) the operator is responsible for monitoring and analysing landfill gas and leachate from the landfill and
the groundwater regime in its vicinity in accordance with Schedule 3 for as long as the Environment Agency
considers that the landfill is likely to cause a hazard to the environment.

1. This Schedule sets out minimum procedures for monitoring to be carried out to check -
(a) that waste has been accepted for disposal only if it fulfils the relevant waste acceptance criteria;
(b) that the processes within the landfill proceed as desired;
(c) that environmental protection systems are functioning fully as intended; and
(d) that the conditions of the landfill permit are fulfilled.
The remainder of Schedule 3 sets out requirements for water, leachate and gas monitoring, and
then makes the following provisions.
5. – (1) Significant adverse environmental effects, as referred to in regulations 14(3) and 15(5)(b), should be
considered to have occurred in the case of groundwater when an analysis of a groundwater sample shows a
significant change in water quality.
(2) The level at which the effects referred to in sub-paragraphs (1) are considered to have occurred (‘the
trigger level’) must be determined taking account of the specific hydrogeological formations in the
location of the landfill and groundwater quality.
(3) The trigger level must be set out in the conditions of the landfill permit whenever possible.
(4) The observations must be evaluated by means of control charts with established control rules and levels
for each downgradient well.
(5) The control levels must be determined from local variations in groundwater quality.
6. The topography of the site and settling behaviour of the landfill body shall be monitored in accordance with
Table 3 (i.e. the following).
Operational phase After-care phase

Structure and composition of landfill Yearly
body
Settling behaviour of the level of the Yearly Yearly reading
landfill body
The monitoring of the performance of the site infrastructure, waste mass and its surroundings
provides the basis for management decisions about the need for, or implications of, changes to any
aspect of these over the entire life cycle of the landfill. Monitoring programmes may have several
objectives and should be reviewed on a regular basis to ensure that the objectives are being met.
The objectives of monitoring include:
- demonstrates that the landfill is performing as designed and in accordance with risk assessment
predictions;
- provides reassurance that management and control systems are preventing pollution of the
environment (by reference to a pre-established baseline);
- meets the control and monitoring requirements of legislation;
- demonstrates compliance with assessment levels and compliance limits set in the permit;
- indicates where further investigation is required and, where risks are unacceptable, the need for
measures to prevent, reduce or remove pollution; and
- identifies when a site no longer presents a significant risk of pollution or harm to human health.

Guidance on the Monitoring of Landfill Leachate, Groundwater and surface water (reference 67)
and Guidance on the Management of Landfill Gas (reference 91) should be used. Monitoring and
control procedures for waste acceptance, landfill gas combustion, particulate matter, noise and
odour are covered elsewhere in separate Environment Agency guidance documents (references
48, 49, 50, 51, 87, 92, 93, 94, 95, 100 and 101).
The requirements of all the monitoring programmes should be considered from the early
development of the conceptual model. Monitoring of baseline (or background) concentrations prior
to infilling is essential in order to assess the environmental impacts associated with the proposed
development and provide the site report, and will be valuable throughout the life of the site.
Ongoing monitoring is an essential and integral part of the risk assessment approach to landfill
management. The risk assessment will have identified receptors and pathways for which
mitigation measures will have been incorporated in the landfill design. One of the objectives of
monitoring that should be reflected in the operators procedures is to determine whether the
assumptions made in the conceptual model were correct and whether the mitigation measures are
performing to specification. Most of the impacts of a landfill are more difficult and expensive to
remedy the longer they remain uncorrected.
Recommendations for monitoring

1 Monitoring should be designed for a specific purpose and must be fit for that purpose. Combined gas and
groundwater monitoring boreholes are not recommended due to conflicts between the objectives of the monitoring
(e.g. depths of screened portions of the borehole).
2 The position and construction of monitoring points should be reviewed during the design of the main and any
supplementary site investigations and later during the regular review of monitoring data and, if necessary, upgraded
to reflect the design proposals.
3 The monitoring data gathered during the operation of the site should be used by the operator to review the validity of
the conceptual model and the design assumptions made during the planning and development processes. This
interpretation of monitoring data should be conducted on at least an annual basis and the conceptual model and
monitoring plan revised accordingly.
4 Assessment levels and compliance limits form the basis of emission control and assessment at landfill sites and the
operator should have procedures in place with regard to the following.
- Assessment Levels are criteria relating to specific parameters that are used to determine whether a landfill and its
pollution control systems are performing as designed. They are levels that are intended to help identify the
development of adverse, or unexpected, trends in emissions. Such trends may results from failure of site
engineering or management, or from variations between actual conditions and those assumed within the
conceptual model.
- Assessment levels for groundwater are called ‘control levels.’
- Assessment levels should be treated as an early warning system to enable appropriate investigative or corrective
measures to be implemented, particularly where there is potential for a compliance limit to be breached.
- Compliance limits are limits given in a PPC permit for specific parameters. They can be considered as
concentrations at which significant adverse environmental effects and/or breaches of legislation have occurred.
- Compliance limits for groundwater are called ‘trigger levels.’
5 Environmental monitoring may be required, for example, when:

- there are vulnerable receptors
- the emissions are a significant contributor to an Environmental Quality Standard (EQS) that may be at risk
- the operator is looking for departures from standards based on lack of effect on the environment;
- to validate modelling work
6 Where environmental monitoring is needed, the following should be considered in drawing up proposals:
- determinands to be monitored, standard reference methods, sampling protocols
- monitoring strategy, selection of monitoring points, optimisation of monitoring approach
- determination of background levels contributed by other sources
- uncertainty for the employed methodologies and the resultant overall uncertainty of measurement
- quality assurance (QA) and quality control (QC) protocols, equipment calibration and maintenance, sample storage
and chain of custody/audit trail

Recommendations for monitoring
- reporting procedures, data storage, interpretation and review of results, reporting format for the provision of
information
7 A network of stable, permanent survey control stations should be established and maintained for the control of all
survey work around the site. The following requirements should be met:
- the stations should be referenced to Ordnance Survey National Grid co-ordinates
- the grid alignment should be accurate to within 1 metre and levels referenced to Ordnance Datum
- the horizontal accuracy should be not be less than 1 metre in 20 000 metres
- the level values of the stations should be accurate to within 0.005 metres.
- a schedule of descriptions, co-ordinates and level values of all control stations, together with details of Bench
Marks used, should be submitted in writing to the Environment Agency.
8 A topographical survey should be undertaken at least annually. A survey should also be undertaken prior to the
disposal of waste in any new cell of the landfill. This should ensure that there is an accurate record of the locations of
engineering structures and their level referenced to AOD. A survey should also be undertaken following the closure of
the landfill or a part of the landfill.
The plan produced by the topographical survey should:

- be of an appropriate scale adequate to show the surveyed features of the landfill.
- be of a scale of at least 1:1250
- include 1 metre contours
- include the landform or an indication of the landform immediately adjacent to the landfill
- include all roads, structures, boundaries, monitoring points, extraction points and all other relevant site features in
the permitted installation
- include the positions of ground features to within 1 metre
- where there are significant landform changes since the previous survey, include spot levels to 0.01m at intervals of
no greater than 50 metres in open areas of even gradient and spot levels to 0.01m at intervals of less than 50m
when indicating embankments, stockpiles and other such features.
Additional considerations for landfill of hazardous waste
9 The Landfill Regulations require that monitoring should check that the processes within the landfill proceed as
desired. The operator should undertake routine monitoring of landfill leachate and gas at landfills for hazardous
waste. However, given the lack of UK experience of this type of landfill operators should consider carefully other
additional monitoring necessary to demonstrate that the objectives for stabilisation of the waste body are being met.

6. INFORMATION
Section 3 sets out the general management requirements which will include systems of record
keeping. The following box sets out the recommendations for record keeping and reporting.
Recommendations for record keeping and reporting

1 The operator should keep records of the development of the site, its operation and closure. The key parameters to
be recorded will be specified in the PPC permit. These will typically include:
− records of management system
− any sampling of waste carried out
− amenity monitoring and management including: odour, noise, litter, particulate matter
− monitoring data including: leachate, landfill gas, surface water, groundwater
− leachate levels, quality and quantities
− landfill gas generation and collection
− waste types and quantities
− topographical surveys. These should be carried out annually, prior to the disposal of waste in a new cell/area
and following closure of the landfill (or any part).
− the specification and as built drawings of the basal, sidewall and capping engineering systems.
2 Other records that should be kept are:

− PPC permit application(s) including any supporting documentation and amendments.
− Detailed restoration and aftercare scheme
− Waste acceptance procedures
3 The permit will require the operator to report on various aspects of the site operations. Reports to be submitted
annually will typically include:
− results of the monitoring and assessment carried out in accordance with permit including a review of that data
against the relevant assumptions, parameters and results in the risk assessments submitted with the application
− any annual improvement targets against the operators management system
− topographical surveys
− additional volume of the void that is occupied by waste
− assessment of settlement behaviour of the landfill body
− calculation of remaining capacity (in cubic metres)
− summary of information from the basic characterisation of wastes accepted
− compliance testing of wastes undertaken
− annual summary of waste types and quantities.
4 In accordance with Regulation 12 of the Landfill Regulations, the landfill operator should keep a register of the
quantities and characteristics of the wastes deposited at the site. This record can provide the landfill operator with
valuable historical information and will be used for statistical purposes by Government and the European Community.
This register should include:
-- quantity of waste deposited (this requirement is already common practice at UK landfills and may be recorded
either in tonnage or volume).
-- waste characteristics (this information can be extracted from the basic characterisation information associated
with the waste being sent to landfill, such as its EWC code, the SIC code and appearance of the waste).
-- waste origin. Where practicable the source of the waste should be recorded. However sometimes waste will be
delivered to a landfill within a multi-collection vehicle (i.e. from numerous origins). In these circumstances the name
of the waste collector in combination with a designation of 'multi-collection vehicle' would be sufficient.
-- the delivery date.
-- the identity of the producer, or in the case of the municipal waste, the collector. The waste producer is the person
best placed to provide the information on waste characterisation. In the event that waste is accepted on site that does
not meet the relevant waste acceptance criteria, details of the waste producer will assist in subsequent investigations.
For municipal waste it is recognised that the waste producers are householders and therefore it would be more
appropriate to record information on the collector of the waste. This is also appropriate for multi-collection vehicles.
Where a landfill operator believes that the identification of a specific waste producer is commercially sensitive, then
this should be recorded within the register as such, and a simple justification summary included.
Additional considerations for landfill of hazardous waste

Recommendations for record keeping and reporting
5 The Landfill Regulations require the precise location of deposits of hazardous waste to be registered. This is a
requirement of Regulation 47 of the Hazardous Waste Regulations 2005.
This is already common practice on existing landfills and typically these pre-existing arrangements will remain
acceptable. The underlying principle that a landfill operator should meet is that waste deposits should be located
within a particular cell by reference to x, y, z co-ordinates. Within this principle there are a variety of methods that can
be used to identify the specific location within a cell. As an example one option would to 'grid' an individual landfill cell
into a number of zones using a hand held Global Positioning System and assign individual deposits to a particular
zone and a specific waste lift/depth. For hazardous waste monocells (e.g. asbestos) individual deposits need only be
assigned to a specific landfill cell.

7. GLOSSARY OF TERMS
AFTERCARE i) The steps necessary to bring the land to the required standard for
the planned afteruse.
ii) The period after closure prior to the acceptance of surrender

during which maintenance and monitoring work is needed to
ensure that the restored landfill does not cause pollution of the
environment, harm to human health or adverse effects on local
amenities.
AQUIFER A permeable geological stratum or formation that is capable of both

storing and transmitting water in significant amounts. A confined
aquifer is where upper and lower layers are low permeability which
confine the groundwater under greater than atmospheric pressure.
An unconfined aquifer is where the upper surface of a saturated zone
forms a water table within the water-bearing stratum.
ATTENUATION A decrease in concentration caused by any of a variety of

mechanisms, individually or in combination, including, dilution,
adsorption, precipitation, ion-exchange, biodegradation, oxidation,
reduction.
BEST AVAILABLE The most effective and advanced stage of development of activities
TECHNIQUES (BAT) and their methods of operation which indicates the practical
suitability of particular techniques to prevent and where that is not
practicable to reduce emissions and the impact on the environment
as a whole. For these purposes: ‘available techniques’ means
‘those techniques which have been developed on a scale which
allows implementation in the relevant industrial sector, under
economically and technically viable conditions, taking into
consideration the cost and advantages, whether or not the
techniques are used or produced inside the United Kingdom, as long
as they are reasonably accessible to the operator’; ‘best’ means ‘in
relation to techniques, the most effective in achieving a high general
level of protection of the environment as a whole’ and ‘techniques’
‘includes both the technology used and the way in which the
installation is designed, built, maintained, operated and
decommissioned.
BED VOLUME The volume occupied by the voids between solid waste in a landfill.
In a totally saturated system this volume is occupied by liquid.
BIOMASS Term used to refer to the mass of biologically active material

contained in a reactor, such as a landfill or a biological effluent
treatment plant.
BIODEGRADATION The transformation of a substance or chemical by micro-organisms,

resulting in a change in chemical structure.
BIOREACTIVE WASTES Wastes which are capable of undergoing biological degradation.
BUND A small bank of soil or other inert material used to define limits of
cells or phases or roadways. Not a structural embankment which
may be required to retain waste or liquid, but may be a permanent
part of a landfill base, incorporating a liner.
CELL A portion of the landfill surrounding a topographic low point

encompassing all points from which it would collect free draining
liquid. An individual cell would normally be expected to have a
discrete basal leachate collection and extraction system & be
separated from other cells by an engineered bund or sidewall lining
system.
CLOSURE A new and distinct stage in the regulatory ‘life-cycle’ of landfills,

subject to formal legal requirements described in Section 19.1. After
closure, waste cannot be deposited in a landfill or closed part of a
landfill.
COMPLETION Completion is defined as that point at which a landfill has stabilised

physically, chemically and biologically to such a degree that the
undisturbed contents of the site are unlikely to pose a significant
environment risk in the landfill’s environmental setting. At
completion, active aftercare pollution controls (e.g. leachate
management and gas management) and monitoring systems are no
longer required.
CONSTRUCTION QUALITY This is applicable specifically to construction activities and is an

ASSURANCE (CQA) essential tool for the assurance of quality in landfill development.
CQA is required to ensure that the objective of producing a high
quality, practically flaw free structure is achieved.
CONTAMINATION The presence of chemicals in groundwater, watercourses or soils at

concentrations that can be measured and are significantly higher
than background concentrations. (see also Pollution)
CONTROLLED WATERS Estuaries and coastal waters to three nautical miles from the shore,
relevant rivers, canals, lakes and ground waters, as specified in the
Water Resources Act 1991, Part III, Section 104.
DIRECT DISCHARGE As defined in by the Groundwater Regulations 1998 – the

introduction into groundwater of any substance in List I or II without
percolation through the ground or subsoil
DISPERSION Irregular spreading of solutes due to aquifer heterogeneities at pore-

grain scale (mechanical dispersion) or at field scale (macroscopic
dispersion)
EARTHWORKS Engineering work associated with the movement of soils and

materials on a landfill.
EFFECTIVE RAINFALL Total rainfall minus actual losses due to evaporation and
transpiration. Effective rainfall, the balance, may run-off and/or
percolate into the ground or the waste.
ENVIRONMENTAL A non-statutory benchmark of concentration for a substance after

ASSESSMENT LEVEL (EAL) dispersion into the receiving environment, set at a level below which
no harm is likely. It is derived by the methodology given in Appendix
D of IPPC H1.
GROUNDWATER As defined by the Groundwater Regulations 1998 – all water which is

below the surface of the ground in the saturation zone and in direct
contact with the ground or subsoil. NOTE: this differs from ‘ground
waters’ as Controlled Waters (see definition).
HEAVY METALS Elemental metals having a high relative density and properties that
may be hazardous in the environment. The term usually includes the

metals copper, nickel, zinc, chromium, cadmium, mercury, lead,
arsenic, and may include selenium and others.
HOMOGENEOUS Uniform, consisting of parts all of the same kind
HYDRAULIC CONDUCTIVITY The coefficient of permeability describing the rate at which water can
move through a permeable medium.
HYDRAULIC GRADIENT The change in total head with a change in distance in a given
direction. The direction is that which yields a maximum rate of
decrease in head.
INDIRECT DISCHARGE Regulation 1(3) of the Groundwater Regulations 1998 – the

introduction into groundwater of any substance in List I of II after
percolation through the ground or subsoil.
LANDFILL A landfill is a waste disposal site for deposit of the waste onto or into
land and is defined by the Landfill Regulations 2002 with reference to
Regulations 3 and 4.
LANDFORM The profile of the completed surface of a landfill.
LIST I AND LIST II Schedule to the Groundwater Regulations 1998. Repeated from the
SUBSTANCES Groundwater Directive and not necessarily the same as the List I
and II substances noted in the Dangerous Substances Directive.
PERMEABILITY A measure of the rate at which a fluid or gas will pass through a
medium. The coefficient of permeability of a given fluid is an
expression of the rate of flow through unit area and thickness under
unit differential pressure at a given temperature.
POLLUTION (a) As defined by the PPC 2000 Regulations: emissions as a result of

human activity that may be harmful to human health or the quality of
the environment, cause offence to any human senses, result in
damage to material property or impair or interfere with amenities and
other legitimate uses of the environment.
(b) As defined by the Groundwater Regulations 1998: the discharge

by man, directly or indirectly, of substances or energy into
groundwater, the results of which are such as to endanger human
health or water supplies, harm living resources and the aquatic
ecosystem or interfere with other legitimate uses of water,
POLLUTANT Defined by the PPC 2000 Regulations as any substance, vibration,

heat or noise released as a result of such an emission that may have
such an effect referring to (a) above.
PORE WATER Water that is contained within the pore spaces of a soil or rock.
PUTRESCIBLE A substance capable of being readily decomposed by bacterial

action.
A measure of the reduction in solute velocity relative to the velocity of

the advecting groundwater caused by processes such as adsorption
RETARDATION i.e. the movement of the contaminants in the environment is slower
than the movement of the groundwater.

SATURATED ZONE Zone of an aquifer where all fissures and pores contain water (in
other words, the zone below water table).
SETTLEMENT The amount by which a landfill surface sinks below its original level
due to compaction by its own weight, and degradation of the waste.
For example, a tipped waste thickness of 40 m settling by 8 m would
have undergone 20% settlement. (This example is for finished
surface levels only and does not consider the age or rate of
degradation and settlement).
STABILISATION As applied to landfill, this term includes the degradation of organic

matter to stable products, and the settlement of the fill to its rest
level. The process can take many years to complete. The term also
refers to the use of plants and/or geotextiles to prevent soil erosion
from the surface of a landfill or spoil heap.
SURCHARGE To fill a landfill above final contours to allow for subsequent

settlement. For example, if 20% settlement is predicted and a 100 m
finished waste thickness is required, then a surcharge of 25 m of
waste is required, in other words, the total placed waste thickness
would be 125 m.
SUSTAINABILITY Returning the contents of a landfill site to the environment in a

(LANDFILL) controlled manner, at a rate which the environment can accept
without harm, generally using pro-active measures over a limited
timescale to diminish polluting capability, in a way which does not
leave a long term legacy of active monitoring and management.
UNSATURATED ZONE The zone of a stratum which lies above a water table in which the
pore space in the soil is not saturated with water.
WATER RESOURCES Waters that are potentially extractable for industrial, private or public
use
WATER TABLE The planar surface between the saturation and aeration zones, on
which water is at exactly atmospheric pressure. For the purposes of
assessing whether a discharge is direct or indirect, a representative
winter water table level should be employed, based on
hydrogeological records and/or expert opinion

8. REFERENCES
Directives
1 THE COUNCIL OF THE EUROPEAN UNION (1999). Council Directive 1999/31/EC of 26 April 1999 on the Landfill of
Waste, Official Journal of the European Communities L 182/1, 1-26.
2 THE COUNCIL OF THE EUROPEAN UNION (1996). Council Directive 96/61/EC of 24 September 1996 concerning
integrated pollution prevention and control. Official Journal of the European Communities L257, 26-40.
3 THE COUNCIL OF THE EUROPEAN COMMUNITIES (1975). Council Directive 74/442/EEC of 15 July 1975 on
Waste, Official Journal of the European Communities L194, 33-37.
4 THE COUNCIL OF THE EUROPEAN COMMUNITIES (1979). Council Directive 80/68/EEC of 17 December 1979 on
the protection of groundwater against pollution from certain dangerous substances. Official Journal of the European
Communities L 020, 43-48.
5 THE COUNCIL OF THE EUROPEAN UNION (2003) Council Decision 2003/33/EC of 19 December 2002 establishing
criteria and procedures for the acceptance of waste at landfills pursuant to Article 16 of and Annex II to Directive
1999/31/EC, Official Journal of the European Communities, L 11, 27-49.
6 THE COMMISSION OF THE EUROPEAN COMMUNITIES (2001) Decisions 2001/118/EC & 2001/119/EC amending
decision 2000/532/EC as regards the list of wastes. (Amended by Commission Decision 2001/573/EC). Official
Journal of the European Communities, L46, 1-32.
7 COUNCIL OF THE EUROPEAN UNION (1992) Directive 92/43/EEC on the conservation of natural habitats and of
wild fauna and flora. Official Journal of the European Communities L206, pp7-50.
8 COUNCIL OF THE EUROPEAN UNION (2000) EU Directive 2000/60/EC of the European Parliament and the
Council of 23 October 2000 establishing a framework for community action in the field of water policy. Official Journal
of the European Communities L 327, pp1-70.
Legislation
10 The Landfill (England & Wales) Regulations 2002, The Stationery Office, London
11 The Pollution Prevention and Control Act 1999. Chapter 24. The Stationery Office, London.
12 The Pollution Prevention and Control (England and Wales) Regulations (2000). SI 2000 No.1973. The Stationery
Office, London
13 Environmental Protection Act 1990. Chapter 43. The Stationery Office, London
14 The Waste Management Licensing Regulations (1994). SI 1994 No.1056. The Stationery Office, London
15 Water Resources Act 1991. Chapter 57. The Stationery Office, London.
16 The Groundwater Regulations (1998). SI 1998 No. 2746. The Stationery Office, London.
17 The Construction (Design and Management) Regulations (1994). SI 1994 no 3140. The Stationery Office, London.
18 The Town and Country Planning Act 1990. Chapter 8. The Stationery Office, London.
19 Planning and Compensation Act 1991. Chapter 34. The Stationery Office, London.
20 The Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999. SI
1999 No.293. The Stationery Office, London.
21 Town & Country Planning (General Development Procedures) Order 1995 Under revision. The Stationery Office,
London.

22 Planning and Compensation Act 1991. Chapter 34. The Stationery Office, London.
23 The Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999. SI
1999 No.293. The Stationery Office, London.
24 The Conservation (Natural Habitats &c). Regulations (1994). SI 1994 No.2716. The Stationery Office, London.
Government Guidance
25 DEPARTMENT FOR ENVIRONMENT, FOOD & RURAL AFFAIRS: IPPC A practical guide, Edition 4, Defra, London.
26 DEPARTMENT FOR ENVIRONMENT, FOOD & RURAL AFFAIRS: Government Interpretation of the Landfill
(England and Wales) Regulations 2002 (as amended), (November 2005). Defra, London.
27 DEPARTMENT OF THE ENVIRONMENT, TRANSPORT & THE REGIONS et al. (2000). Guidelines for
Environmental Risk Assessment and Management. The Stationery Office, London.
28 Department of the Environment, Transport and the Regions (1994). Planning Policy Guidance Note 23: Planning and
Pollution Control. HMSO, London. Available from the website of the Office of the Deputy Prime Minister.
29 DEPARTMENT OF THE ENVIRONMENT, TRANSPORT AND THE REGIONS (1999). Planning Policy Guidance
Note 10: Planning and Waste Management. HMSO, London. Available from the website of the Office of the Deputy
Prime Minister.
30 DEPARTMENT OF THE ENVIRONMENT, TRANSPORT AND THE REGIONS (1999). Circular 02/99: Environmental
Impact Assessment. HMSO, London.
31 DEPARTMENT OF THE ENVIRONMENT, TRANSPORT AND THE REGIONS (2001) Guidance on the Groundwater
Regulations 1998, Department for the Environment, Food and Rural Affairs, London.
32 Department of the Environment, Transport and the Regions (2000). Planning Policy Guidance Note 11: Regional
Planning. HMSO, London. Available from the website of the Office of the Deputy Prime Minister.
33 NATIONAL ASSEMBLY FOR WALES (1999). Planning Guidance (Wales) Planning Policy The Stationery Office,
London.
34 DEPARTMENT OF THE ENVIRONMENT/ENVIRONMENT AGENCY (1994). Guidance on Good Practice for Landfill
Engineering. Research Report No CWM 106/94. Environment Agency, Bristol.
35 DEPARTMENT OF THE ENVIRONMENT, TRANSPORT AND THE REGIONS (2000). Waste Strategy 2000:
England and Wales. DETR, London.
36 DEPARTMENT OF THE ENVIRONMENT, TRANSPORT & THE REGIONS (1999). A better quality of life: a strategy
for sustainable development in the United Kingdom. (Command number 4345) The Stationery Office, London.
37 DEPARTMENT OF THE ENVIRONMENT, TRANSPORT & THE REGIONS (1994). Planning Policy Guidance Note
23: Planning and Pollution Control. HMSO, London. Available from the ODPM website.
38 DEPARTMENT OF THE ENVIRONMENT, TRANSPORT & THE REGIONS (1999). Planning Policy Guidance Note
10: Planning and Waste Management. HMSO, London. Available from the ODPM website.
39 DEPARTMENT OF THE ENVIRONMENT, TRANSPORT & THE REGIONS (1996): Minerals Planning Guidance Note
MPG07: The Reclamation of Mineral Workings. HMSO, London. Available from the website of the Office of the
Deputy Prime Minister.
40 HEALTH AND SAFETY EXECUTIVE (1997). Safe work in confined spaces. Approved Code of Practice, Regulations
and Guidance. HSE books, Sudbury.

Environment Agency Technical Guidance
GENERIC PPC GUIDANCE

41 ENVIRONMENT AGENCY (2003) IPPC H1 Environment Assessment and Appraisal of BAT. Environment Agency,
Bristol.
42 ENVIRONMENT AGENCY (2002) IPPC H3 Part 1. Horizontal Guidance for Noise Part 1-Regulation and Permitting.
Environment Agency, Bristol.
43 ENVIRONMENT AGENCY (2002) IPPC H3 Part 2 – Horizontal Guidance for Noise Part 2-Noise Assessment and
Control. Environment Agency, Bristol.
44 ENVIRONMENT AGENCY (2002) IPPC H4 Part 1. Draft Horizontal Guidance Note for Odour Part 1 - Regulation and
Permitting. Environment Agency, Bristol.
45 ENVIRONMENT AGENCY (2002) IPPC H4 Part 2. Draft Horizontal Guidance Note for Odour Part 2- Odour
Assessment and Control. Environment Agency, Bristol.
46 ENVIRONMENT AGENCY (2003) IPPC H7 Integrated Pollution Prevention and Control (IPPC) Guidance on the
Protection of Land under the PPC Regime: Application Site Report and Site Protection and Monitoring Programme.
47 ENVIRONMENT AGENCY (2004) IPPC H8: Guidance on the Protection of Land Under the PPC Regime: Surrender
Site Report & Template. Environment Agency, Bristol.
48 ENVIRONMENT AGENCY (2002) M1: Sampling Facility Requirements For Monitoring Of Particulates In Gaseous
Releases To Atmosphere. Environment Agency, Bristol.
49 ENVIRONMENT AGENCY (2004) M2: Monitoring Of Stack Emissions To Air. Environment Agency, Bristol.
50 ENVIRONMENT AGENCY (2002) M8: Environmental monitoring strategy - ambient air. Environment Agency, Bristol.
51 ENVIRONMENT AGENCY (2004) M17: Monitoring of Particulate Matter in Ambient Air around Waste Facilities.
PERMITTING AND WASTE ACCEPTANCE

52 ENVIRONMENT AGENCY (2003) Hazardous Waste. Interpretation of the Definition and Classification of Hazardous
Wastes. Technical Guidance WM2. Environment Agency, Bristol.
53 ENVIRONMENT AGENCY (2006) Landfill permitting regulatory update, Environment Agency, Bristol
54 ENVIRONMENT AGENCY (2001) Regulatory Guidance Note 1, Classification of sites, Environment Agency, Bristol
55 ENVIRONMENT AGENCY (2001) Regulatory Guidance Note 16, Interpretation of the engineering requirements of
Annex 1 to the landfill directive, Environment Agency, Bristol
56 ENVIRONMENT AGENCY (2005) Guidance for Wastes Destined for Disposal in Landfills. Environment Agency,
Bristol.
57 ENVIRONMENT AGENCY (2005) Guidance on sampling and testing to meet landfill waste acceptance procedures.
58 ENVIRONMENT AGENCY (2005) Guidance on the treatment of hazardous and non-hazardous landfill leachate.
Environment Agency, Bristol (In preparation)
59 ENVIRONMENT AGENCY (2000): Strategic Waste Management Assessment 2000 (10 documents covering England
and Wales). WRc, Swindon.

GROUNDWATER
60 ENVIRONMENT AGENCY (2002) The implementation of the EC Groundwater Directive (80/68/EEC) in the United
Kingdom. www.Environment-Agency.gov.uk/search/JAGDAG.
61 ENVIRONMENT AGENCY (2002) Determination of substances for the purposes of the EC Groundwater Directive
(80/68/EEC). www.Environment-Agency.gov.uk/search/JAGDAG.
62 ENVIRONMENT AGENCY (2002) List of substances determined for the purpose of the EC Groundwater Directive
(80/68/EEC). www.Environment-Agency.gov.uk/search/JAGDAG.
63 ENVIRONMENT AGENCY (1998): Policy and Practice for the Protection of Groundwater (2nd Edition). Environment
Agency, Solihull.
64 ENVIRONMENT AGENCY (2002) Regulatory Guidance Note 3 Groundwater protection: locational aspects of landfills
in planning consultation responses and permitting decisions, version 4.0. Environment Agency, Bristol.
65 ENVIRONMENT AGENCY (2003) Hydrogeological risk assessments for landfills and the derivation of groundwater
control and trigger levels. Environment Agency, Bristol.
66 ENVIRONMENT AGENCY (1999) Methodology for the Derivation of Remedial Targets for Soil and Groundwater to
Protect Water Resources. R&D Publication 20. Environment Agency, Bristol.
67 ENVIRONMENT AGENCY (2003) Guidance on the Monitoring of Landfill Leachate, Groundwater and Surface Water.
68 ENVIRONMENT AGENCY (2003) Techniques for the interpretation of landfill monitoring data. Guidance Notes. R&D
Technical Report P1-471, Environment Agency, Bristol.
69 ENVIRONMENT AGENCY/GOLDER ASSOCIATES (UK) Ltd. (2003). LandSim User Manual release 2.5.
70 ENVIRONMENT AGENCY (2001) Guide to Good Practice for the Development of Conceptual Models and the
Selection and Application of Mathematical Models of Contaminant Transport Processes in the Subsurface. National
Groundwater & Contaminated Land Centre report NC/99/38/2, Environment Agency, Solihull.
71 Environment Agency (2003) Improved definition of leachate source term for landfill. Phase I Review of Data from
European Landfills. R&D Report P2- 236. Environment Agency, Bristol.
LANDFILL ENGINEERING GUIDANCE

72 ENVIRONMENT AGENCY (2001) Framework policy for landfill engineering. Environment Agency, Warrington.
73 ENVIRONMENT AGENCY (2001) Guidance for inspecting the construction of landfill liners. Environment Agency,
Warrington.
74 ENVIRONMENT AGENCY (2001) Guidance on the use of geomembranes in landfill engineering. Environment
Agency, Warrington.
75 ENVIRONMENT AGENCY (2001) Guidance on the geophysical testing of geomembranes for landfill engineering.
Environment Agency, Warrington.
76 ENVIRONMENT AGENCY (2001) A methodology for cylinder testing of protectors for geomembranes. Environment
Agency, Warrington.
77 ENVIRONMENT AGENCY (2001) Guidance on non-woven protector geotextiles for landfill engineering. Environment
Agency, Warrington.
78 ENVIRONMENT AGENCY (2001) Guidance on the use of geosynthetic clay liners. Environment Agency, Warrington.

79 ENVIRONMENT AGENCY (2001) Guidance on the use of bentonite enriched soils. Environment Agency, Warrington.
80 ENVIRONMENT AGENCY (2001) A technical note on the design, construction and quality assurance of compacted
clay liners. Environment Agency, Warrington.
81 ENVIRONMENT AGENCY (2001) The use of nuclear density gauges for compliance testing of earthworks on landfill
sites. Environment Agency, Warrington.
82 ENVIRONMENT AGENCY (2003). The likely medium to long-term generation of defects in geomembrane liners. R&D
Technical Report P1-500/1/TR, Environment Agency, Bristol. In preparation
83 ENVIRONMENT AGENCY (2003) Landfill Engineering: Leachate Drainage, Collection And Extraction Services. R&D
Report P1-397. Environment Agency, Bristol.
84 ENVIRONMENT AGENCY (1999) Review and Guidance on the use of Landfill Cover Materials Version 3.6.
85 ENVIRONMENT AGENCY (2005) Technical guidance on capping and restoration of landfills. Environment Agency,
Bristol, in preparation.
86 ENVIRONMENT AGENCY (2003) R&D Technical Report P1-385, The Stability of Landfill Lining Systems Report No
1 Literature Review. Environment Agency, Bristol.
87 ENVIRONMENT AGENCY (2003) R&D Technical Report P1-385, The Stability of Landfill Lining Systems Report No
2 Recommendations. Environment Agency, Bristol.
88 ENVIRONMENT AGENCY (2001) Regulatory Guidance Note 11, Disposal in landfills for non-hazardous waste of:
stable, non-reactive hazardous waste, asbestos wastes and wastes with high sulphate contents, Environment
Agency, Bristol
LANDFILL GAS GUIDANCE

90 ENVIRONMENT AGENCY (2002) Guidance on landfill gas flaring. Environment Agency, Bristol.
91 ENVIRONMENT AGENCY (2004) Guidance on the management of landfill gas. Environment Agency, Bristol.
92 ENVIRONMENT AGENCY (2004) Guidance for monitoring landfill gas surface emissions. Environment Agency,
Bristol.
93 Environment Agency (2004) Guidance for monitoring landfill gas engine emissions. Environment Agency, Bristol.
94 Environment Agency (2004) Guidance for monitoring enclosed landfill gas flares. Environment Agency, Bristol.
95 Environment Agency (2004) Guidance for monitoring trace components in landfill gas. Environment Agency, Bristol.
96 ENVIRONMENT AGENCY (2002) Investigation of the composition and emissions of trace components in landfill gas.
R&D Technical Report P1-438/TR. Environment Agency, Bristol.
97 ENVIRONMENT AGENCY (1999) A framework to assess the risks to human health and the environment from landfill
gas, R&D Technical Report P271 (CWM 168/98). Environment Agency, Bristol. ISBN 1 85 705254 4.
98 ENVIRONMENT AGENCY (2002) GasSim – landfill gas risk assessment tool. R&D Project P1-295. Environment
Agency software model. See www.gassim.co.uk
99 Environment Agency (2004) Guidance on gas treatment techniques for landfill gas engines. Environment Agency,
Bristol.

NUISANCE
100 ENVIRONMENT AGENCY (2002) Internal Guidance for the Regulation of Odour at Waste Management Facilities V3.
101 ENVIRONMENT AGENCY (2002) Internal Guidance for the Regulation of Noise at Waste Management Facilities V3.
CLOSURE, AFTER-CARE AND SURRENDER

102 ENVIRONMENT AGENCY (2005) Regulatory Guidance Note 7 (version 2), Requirements for landfills that stop
operating – closure and aftercare, Environment Agency, Bristol
102A ENVIRONMENT AGENCY (2005) Regulatory guidance frequently asked questions, landfill closure, Environment
Agency, Bristol
103 ENVIRONMENT AGENCY (2003) Guidance on Landfill Completion and Surrender. Environment Agency, Bristol, in
preparation.
104 ENVIRONMENT AGENCY (2000) Internal guidance on the determination of applications to surrender waste
management licences. Environment Agency, Bristol.
105 ENVIRONMENT AGENCY (2006) Policy and Guidance Financial Provision for Landfill, Environment Agency,
Bristol.
ACCIDENTS AND THEIR CONSEQUENCES

106 ENVIRONMENT AGENCY (2004) Review and Investigation of Deep-Seated Fires within Landfill Sites. R&D
Technical Report P1-490 Environment Agency, Bristol.
GENERAL RISK AND IMPACT ASSESSMENT

107 ENVIRONMENT AGENCY (2005) Guidance on assessment of risks from landfill sites. Environment Agency, Bristol,
in preparation.
108 ENVIRONMENT AGENCY (2003) Part B of Application form for the Landfill Sector, Templates for the Completion of
Section 1. Section A – Conceptual Model, Environmental Setting and Installation Design Report, Section B -
Hydrogeological Risk Assessment Report, Section C – Stability Risk Assessment Report, Section D - Landfill Gas
Risk Assessment. Environment Agency, Bristol.
109 Environment Agency (2003) Regulatory Guidance Note 5 Habitats regulations and the landfill regulations, information
and guidance for landfill operators, version 1.2 Environment Agency, Bristol.
110 ENVIRONMENT AGENCY (2003) Habitats Directive: Work Instruction (Appendix 6): Further Guidance applying the
Habitats Regulations to Waste Management Facilities, version 2. Environment Agency, Bristol.
Supporting Technical References

111 ALEXIEW, D., BERKHOUT, H. and KIRSCHNER, R. (1995) On the slope stability of landfill capping seals using
GCLs in Geosynthetic Clay Liners, ed. R.M Koerner, E. Gartung & H. Zanzinger. AA Balkema/Brookfield.
112 AMERICAL SOCIETY FOR TESTING MATERIALS (1994). Standard D5514-94. Standard Test Method for Large
Scale Hydrostatic Puncture Testing of Geosynthetics. ASTM, P.A.
113 BEAVEN, R. (1996). Evaluation of geotechnical and hydrogeological properties of wastes. Engineering geology of
waste disposal, Geological Society Engineering Geology Special Publication No 11. The Geological Society, London.
114 BEAVEN RP AND POWRIE W (1995) Determination of the hydrogeological and geotechnical properties of refuse
using a large-scale compression cell. Vol II pp745-760 of Proceedings of the 5th international Sardinia Landfill
Conference, S. Margeherita Di Pula, Italy. CISA, Cagliari.

115 BENDING, N. and MOFFAT, A.J. (1997). Tree establishment on Landfill Sites. Department of the Environment R&D
report CWM 146/96. Forrest Research. Farnham.
116 BJARNGARD, A. and EDGERS, L. (1990) Settlement of Municipal Solid Waste Landfills. pp 192-205 in
Proc.Thirteenth Annual Madison Waste Conference. Department of Engineering, University of Wisconsin at Madison,
Wisconsin.
117 B.D. BONE, K. KNOX, A. PICKEN, & H.D. ROBINSON (2002) Leachate quality from UK landfills after implementation
of the Landfill Directive: hazardous wastes. pp 590-601 Proceedings: Waste 2002, 24 th – 26th September, Stratford on
Avon, UK.. The Waste Conference Ltd Coventry. ISBN 0-9539301-1-4.
118 BRITISH STANDARDS INSTITUTE (1999). BS 5930: Code of Practice for Site Investigations. BSI, London.
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Guidance for the Landfill Sector

Technical Requirements of the Landfill Directive and Integrated

The Environment Agency. Out there, making your

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Environment Agency Guidance for the Landfill Sector 1

The aims of this document are to:

1 Environment Agency Guidance for the Landfill Sector

Environment Agency Guidance for the Landfill Sector 2

1.1.1 Waste management licensed landfills

1.2 Understanding the Landfill Directive and IPPC

3 Environment Agency Guidance for the Landfill Sector

1.2.1 Relationship with other guidance

1.3 Making an application

- assess the potential environmental impact (section 2)

- the conceptual model of the site;

Environment Agency Guidance for the Landfill Sector 4

1.4 Installations covered by this guidance

Section 5.2 - Disposal of Waste by Landfill

1.4.2 Defining the installation

5 Environment Agency Guidance for the Landfill Sector

1.5 Installation Issues

Recommendations for installation issues

1.6.2 Risk assessment review

Environment Agency Guidance for the Landfill Sector 6

1.6.3 Improvement timescales for existing landfills

1. ‘Good-practice’ requirements, such as, management systems, housekeeping measures to

2. Larger, capital-intensive improvements, such as major changes to landfill gas management

1.7 Key Issues for the landfill sector

1.7.2 Groundwater protection

7 Environment Agency Guidance for the Landfill Sector

1.7.3 Landfill gas management

- barriers to surface emissions and sub-surface migration of landfill gas;

1.7.4 Quality assurance

1.7.5 Integration of pollution control systems

This consideration must also include stability and settlement.

1.7.6 Landfill stabilisation

1.7.7 Sustainable development

1.8 Technical overview

- the landfill life cycle;

Environment Agency Guidance for the Landfill Sector 8

1.8.1 The landfill life cycle

The life cycle of a landfill involves three main phases:

Closure and aftercare are discussed further in Section 2.11.

Article 7 of the Landfill Directive

9 Environment Agency Guidance for the Landfill Sector

For landfill, moves towards sustainable development are achieved by:

- using waste to construct a landform with a beneficial after use;

Special considerations for landfill of hazardous waste

1.8.3 Landfill design and Conceptual Model

The iterative process is likely to include the following:

Environment Agency Guidance for the Landfill Sector 10

Table 1.1 Key factors affecting a landform

11 Environment Agency Guidance for the Landfill Sector

Integration of the design elements

Table 1.2 Potential interactions between design elements

1.9 Landfill permitting

Environment Agency Guidance for the Landfill Sector 12

1.9.2 Permit structure

The structure of the permit template is as follows:

Status Log of the Permit

Other permits and superceded permits

Three tables set out details of:

13 Environment Agency Guidance for the Landfill Sector