LANDFILL WASTE ACCEPTANCE CRITERIA: SAMPLING AND TESTING 2004

K. LEWIN*, J. ELLIS* AND J. GRONOW *WRc plc, Frankland Road, Blagrove, Swindon, UK, SN5 8YF Environment Agency, Block 1 Government Buildings, Burghill Road Westbury-on-Trym, Bristol, UK, BS10 6BF

SUMMARY: This paper provides an update on the developments that have taken place since a similarly titled presentation at Waste 2002. At the time the EU waste acceptance criteria had not been published and the UK approach to regulating the scheme had not yet been devised. Here we address some of the issues that are currently being faced, often for the first time, by waste producers and landfill operators. Now that a range of generic wastes have been subjected to testing against the waste acceptance criteria, we highlight the key variables which pose challenges for the continued landfill disposal of certain types of wastes and outline how leaching behaviour tests can assist decisions about treatment to generate wastes that are compliant with the landfill waste acceptance criteria. 1. LANDFILL WASTE ACCEPTANCE CRITERIA THE UK SCHEME The Landfill Directive (1999/31/EC) requires the separate disposal of waste to landfills for inert, non-hazardous and hazardous wastes and set out the concept of waste acceptance criteria (WAC) for the different classes of landfill. Council decision document 2003/33/EC provided acceptance criteria to be applied to granular wastes by member states. These included limit values for inert waste, stable, non-reactive hazardous wastes and hazardous wastes for organic matter, as well as limits on the leachability of a range of predominantly inorganic parameters. The latter were to be applied to eluates generated at liquid to solid ratio of 2 litres/kilogram (L/S2) and/or L/S10 from the EN 12457 series of compliance leaching tests for granular wastes (CEN 2002a) and/or initial C0 eluate concentrations from the upflow percolation test prEN 14405 (CEN 2003). Hjelmar et al. (2002) outlined the background to the development of the landfill waste acceptance criteria. The decision document stated that acceptance criteria for monolithic wastes and PAH limit values for granular wastes were to be set at member state level. The waste acceptance criteria (WAC) as they are to be applied in the UK were published in 2004 in amendments to the landfill regulations. Draft guidance on the use of waste testing methods and the application of the WAC compliance scheme was provided by the Environment Agency (2003a). At the time of writing this paper, draft limit values for monolithic wastes were being considered by Defra prior to being issued for consultation. The limit values for granular and

monolithic wastes are not presented here, but the test methods, compliance parameters and principles of the scheme are summarised in Table 1. The UK government is implementing the ban on codisposal, i.e. requiring the separate disposal of non-hazardous and hazardous wastes in landfills for non-hazardous and hazardous wastes respectively, in July 2004. The timescales for introduction of the full WAC at all classes of landfill site have not yet been finalised. This is likely to occur on a site-by-site basis as they are permitted under IPPC, with an overall introduction date for full WAC for hazardous waste landfills at July 2005. 2. THE WASTE PRODUCERS OBLIGATIONS 2.1 Questions Faced with a raft of new legislation and guidance, many waste producers are grappling with a range of questions that need urgent answers such as: is my waste non-hazardous or hazardous? have I reviewed the management options for my waste streams? if my waste must be landfilled and it is a hazardous waste, does it meet the landfill waste acceptance criteria for hazardous waste or stable, non-reactive hazardous waste? if it is a nonhazardous waste, does it meet the landfill acceptance criteria for inert waste now, or is it likely to meet the criteria for stable, non-reactive hazardous wastes in the future? is the waste leachability consistent or erratic with varying operational conditions? how can I be sure that the waste sample is representative of my waste stream? if my dataset shows that I fail the waste acceptance criteria what tests can I use that might highlight potential landfill pre-treatment options to deliver WAC compliant wastes?

These are all issues that need to be addressed when undertaking the level 1 basic (comprehensive) characterisation that the landfill regulations require of the waste producer. 2.2 Assigning the correct waste status hazardous or non-hazardous The European Waste Catalogue (2000) as amended lists wastes by industry sector and defines them as hazardous (absolute or mirror-entry hazardous/non-hazardous) or non-hazardous wastes, according to their known hazard characteristics. The Hazardous Waste Directive (1991) lists the 14 hazardous properties H1-H14, which include irritant, harmful, toxic, carcinogenic, mutagenic and ecotoxic hazardous properties. Under Duty of Care arrangements producers of absolute hazardous waste are required to declare the relevant hazard properties (either from prior knowledge or testing) before off-site treatment or disposal. The options for producers of mirror-entry hazardous/non-hazardous wastes depend on whether the hazard assessment and subsequent testing confirms the presence or absence of dangerous substances or hazardous properties. Mirror-entry wastes that are shown by testing to be hazardous must be treated as for absolute hazardous waste. Where absence of dangerous substances/hazard properties can be demonstrated the wastes can be handled and disposed as non-hazardous wastes. Detailed guidance on the hazard assessment of wastes is provided by the Environment Agency (WM2, 2003b).

Table 1 UK landfill waste acceptance criteria: generic values and principles Granular wastes(1)
Classes of waste for which WAC have been set

Monolithic wastes(2)

inert waste, stable, non-reactive hazardous waste (and non-hazardous waste disposed with them), and hazardous waste.

stable, non-reactive hazardous wastes and hazardous wastes.

Test methods for leachability limit values

BS EN 12457-3 (3) compliance test for granular materials on wastes <4mm in particle size. Limit values for eluate concentrations generated at liquid-tosolid ratio 10 litres/kilogram dry waste (L/S10). As, Ba, Cd, Cr, Cu, Hg, Mo, Ni, Pb, Sb, Sb, Se, Zn, Cl, F, SO4, TDS (total dissolved solids) and DOC (dissolved organic carbon) in mg/kg at L/S10 l/kg. Eluate pH and electrical conductivity (EC) should also be determined

NEN 7341:1995 (Dutch tank test) Limit values for cumulative eluate concentrations generated in mg/m2 from the first 4 stages of the test Limit values have also been set for the full 8-stage (64 day) test for characterisation purposes. As, Ba, Cd, Cr, Cu, Hg, Mo, Ni, Pb, Sb, Sb, Se, Zn, Cl, F and SO4.in mg/m2. Eluate DOC concentration, pH and EC should also be determined

Determinands with leachability limit values

Limits on organic matter

Total organic carbon (TOC) limits: 3%, 5% and 6% w/w for inert, stable, nonreactive hazardous (SNR-haz) and hazardous waste landfills respectively. Or LOI (loss-on-ignition at 550C) of 10% for hazardous wastes instead of the TOC limit. BTEX, PCBs and PAHs. Leachability of phenol index at L/S10. Acid/base neutralisation capacity to be evaluated by the landfill operator for SNR-haz and hazardous wastes.

TOC and LOI limits for input wastes to the treatment plant prior to conversion to a monolith: 6% TOC and/or 10% LOI (both stable, non-reactive hazardous and hazardous wastes).

Additional determinands (inert waste) ANC/BNC

Principle

The limit values are maximum values requiring compliance with all parameters in all samples for the compliance monitoring period. The choice of scale of sampling is crucial and must be agreed by waste producer and landfill operator. If the scale is defined as an individual load, this means that the landfill operator must not accept any load of waste that has average concentrations that exceed the limit values. The waste producer must ensure that the average concentration of all loads of wastes generated under normal and worst-case operational conditions will meet the limit values for the appropriate class of landfill.

(1) Landfill (England and Wales) (Amendment) Regulations 2004 (2) Defra is expected to consult on these values in summer 2004. (3) BS EN 12457-3 generates eluates at L/S2 and L/S2-10 (cumulative L/S10). The single step L/S10 test BS EN 12457-2 is allowed where BS EN 12457-3 is not technically possible. (Environment Agency, 2003).

For absolute hazardous wastes there may be sufficient knowledge of hazard properties to base the hazard assessment on available information. However, most absolute and mirror-entry wastes will require sampling and testing to declare the relevant hazard or demonstrate the absence of hazards for handling or disposal as a hazardous or non-hazardous waste respectively. Classification as hazardous or non-hazardous waste must be undertaken before a review of waste management options can be undertaken or before compliance with landfill waste acceptance criteria can be ascertained. 2.3 Assigning the correct landfill class testing against WAC 2.3.1 Requirements Once the full WAC have been introduced, hazardous wastes must be treated and comply with (i.e. be consistently lower than) the WAC for hazardous waste landfills or the WAC for stable, non-reactive hazardous (SNR-haz) wastes. The following options are available for wastes that have been identified as non-hazardous: non-hazardous wastes which are destined for mono-cells with stable, non-reactive hazardous wastes must comply with the SNR-haz WAC; non-hazardous wastes which are destined for inert waste landfills must comply with the inert WAC; other non-hazardous wastes can be accepted at non-hazardous waste landfill without testing against WAC for the foreseeable future provided they comply with Sch1 Para 1 of the amended Landfill Regulations (2004). Waste producers would be advised to pre-empt the introduction of WAC for non-hazardous wastes by comparing the quality of their wastes with the WAC for other classes of site (especially the SNR-haz WAC) and taking appropriate action.

2.3.2 Consistent or erratic wastes Knowledge of the consistency of the waste quality is essential before determining whether the waste is fit for landfill. This could be obtained over a long period of compliance monitoring using the WAC testing results. However, this carries the risk of WAC failure for one or more determinands and potential loss of landfill disposal route. Alternatively a focused screening exercise as part of the waste producers characterisation programme can be carried out over a shorter period of time to demonstrate whether the waste is consistently compliant or whether the waste quality is erratic. If compliance against WAC is tested under worst-case as well as average operational conditions, technical modifications to the operational process (including the feedstock) can be introduced to generate a waste stream that is consistently WAC-compliant. In the face of international competition, UK industry should seize the opportunity for the costs of such waste characterisation to be shared. This can be organised as a joint testing programme of generic industrial wastes coordinated on an anonymous basis by the appropriate trade association. To obtain best value from such an exercise the sampling programme must be well thought out and sufficient time must be allowed, not only for the testing to be undertaken and interpreted, but also for any process modifications to be carried out well ahead of WAC introduction and for the Agency to list the wastes as acceptable for the site(s) in question.

Where waste is not being landfilled directly but is being treated at a third-party plant, it will be the responsibility of the treatment plant operator (the secondary waste producer) to ensure that the treated residues are consistently WAC compliant. A draft European standard prEN 14899 (CEN 2004) provides guidance on the preparation of a sampling plan for waste testing and is supported by a series of technical reports. In all cases the quality of the results of the testing programme are dependent on the decision-making process followed to collect the samples in the first place. For example, are worst-case or representative samples needed? Do samples need to be collected over a period of time under known operational conditions to allow the impact of feedstock changes, shift patterns, plant operational factors to be assessed? What is the scale of sampling? A sister paper (Turrell et al. 2004) describes the practical issues related to waste sampling both for characterisation and compliance. 2.3.3 Examples of WAC testing The lead authors and their organisation have been conducting the compliance leaching test in its published and draft format for a number of years. Table 2 summarises the results of WAC compliance testing for a selection of wastes. To secure continued landfill disposal, a hazardous waste only needs to be treated to meet the hazardous waste acceptance criteria. However, if treatment of hazardous waste in Table 2 is also targeted at reducing the levels or leachabilities of those parameters which exceed the SNR-haz waste criteria then the option for disposal within a cell for stable, non-reactive hazardous wastes at a non-hazardous waste landfill becomes available. Hence the leachability of Pb and Cl (and TDS) poses a serious challenge for continued landfilling of MSW incineration air pollution control residues as a hazardous waste after July 2005, and the leachability of Zn and Hg also needs to be reduced before the residues could be landfilled as SNR-haz waste. Non-hazardous wastes do not currently have to meet quantitative waste acceptance criteria and therefore exceedance of hazardous waste acceptance criteria is not relevant. However treatment to meet the inert WAC may result in the waste meeting a different end-use specification enabling diversion of the waste from landfill to an alternative route, e.g. external reuse, or it may highlight the feasibility of on-site closed-loop recycling. For example, reduction of sulphate leachability from the blast furnace slags would allow landfilling as an inert waste, but a large proportion of this residue stream is already reused as an aggregate. In addition, it is suggested that within ten years the WAC for stable, non-reactive hazardous wastes may be applied to all non-hazardous wastes and therefore wastes shown to exceed hazardous waste acceptance criteria on Table 2 may ultimately require further treatment not only to meet the hazardous WAC, but also the more stringent SNR-haz WAC. This has particular implications for non-hazardous organic wastes (such as sewer grits and screenings) that will require some type of thermal treatment or digestion to reduce the organic carbon level to below 5% w/w. This will ultimately generate a completely different residue for landfill disposal or the uptake of a non-landfill management option. 2.3 Role of characterisation 2.3.1.Basic requirements Assigning the hazard status of a wastes and the correct class of landfill are fundamental aspects of the level 1 basic (comprehensive) characterisation requirements under the landfill regulations. Another requirement is to check whether waste can be recovered or recycled.

Table 2 Indicative performance of example waste streams against the UK landfill waste acceptance criteria (leachability at L/S10 l/kg, total organic carbon and loss on ignition) Type of waste EWC code/status# 19 01 11 (M) 19 01 12 (NH) Parameters exceeding inert WAC Cu, Mo, Pb, Sb, Cl, SO4, TDS, phenol index, DOC As, Ba, Cu, Cr, Hg, Mo, Ni, Pb, Sb, Zn, Cl, F, SO4, TDS, DOC Mo, Sb, Se, F, SO4, Cr, Mo, Ni, Pb, Se, Cl, F, SO4 As, Cr, Mo, Sb, Se, F, SO4 SO4 phenol index (alkali phenolic sands), F, DOC Cd, Ni, Pb, Sb, Zn, SO4, phenol index, DOC, TOC phenol index, DOC, TOC Zn, phenol index, TOC Cu, Mo, Sb, Se, F, phenol index, DOC, TOC Cd TOC, DOC Parameters exceeding SNRhaz WAC Pb, Sb, DOC Parameters exceeding haz WAC Pb

MSW incineration bottom ash MSW incineration APC residue Sewage sludge incineration fly ash Cement kiln bypass dust Coal fly ash Blast furnace slag Foundry sands (chemically bonded) Water treatment residue (potable)

19 01 07 (H)

Hg, Pb, Zn, Cl, TDS

Pb, Cl, TDS

19 01 13 (M) 19 01 14 (NH) 10 13 12 (M) 10 13 13 (NH) 10 01 02 (NH) 10 02 01 (NH) 10 02 03 (NH) 10 09 07 (M) 10 09 08 (NH) 19 09 02 (NH)

Sb

Cr, Pb, Se, SO4 Mo, Se

SO4

Sewer grits* Sewage screenings* Refractory bricks (carbon)

19 08 99 (NH) 19 08 01 (NH) 16 11 01 (M) 16 11 02 (NH)

DOC, TOC, LOI TOC F, TDS, DOC, TOC

DOC, TOC, LOI TOC, LOI F, TDS, DOC, TOC, LOI

Notes: # Hazardous (H), non-hazardous (NH) or mirror entry (M) * Chambers et al., 2004. Italic font: parameters with inconsistent behaviour with respect to the WAC

Therefore testing to demonstrate WAC compliance is probably not the only type of compliancedriven characterisation programme that the producer may wish to undertake when reviewing the management options available for his waste. However, if landfill disposal is the only available option, at least in the short term, and a sampling and testing programme has demonstrated that certain parameters consistently fail the leachability WAC, then the waste producer should consider other characterisation tests. These may help to increase his understanding of the leaching behaviour of the waste and therefore the treatment options that could be considered to ensure WAC compliance. As competition for hazardous waste landfill capacity increases it will be in the waste producers interest to demonstrate a high quality dataset supported by good technical knowledge of how and when the samples were obtained. The landfill operator is less likely to reject a waste stream with a low risk of WAC failure than that from a waste producer who has little understanding of what operational or feedstock factors may make the difference between WAC failure and compliance. 2.3.2 Toolbox of characterisation tests CEN Technical Committee 292 on waste characterisation has advocated the use of a toolbox approach to characterisation and has provided guidance (ENV 12920, CEN 1998) on how to select the most appropriate leaching test and how to ensure that the test provides the required information. Background to the test methods is outlined in Annex C of guidance on Sampling and Testing provided by the Environment Agency (2003a). In addition, a sister paper (Graham and Lewin, 2004) provides more detail of the practical application of these types of tests through two case studies. Examples of these leaching behaviour tests include: pH dependence leaching test, prEN 14429 (CEN 2002b): the leachability of many of the WAC metals is primarily controlled by waste pH. The series of compliance leaching tests for granular wastes (BS EN 12457) is conducted at natural pH (i.e. the final eluate pH is at, or close to, the same pH as the waste). By obtaining a leaching profile for each metal over the pH range from 4-14 it is possible to demonstrate the impact of adjusting the pH of the material outside its normal pH domain and to identify a range of pH values where compliance with the relevant WAC can be obtained. By identifying this window for each parameter (including those which are compliant at natural pH) it is frequently possible to identify a potential pH treatment window for the waste as a whole. upflow percolation test, prEN 14405 (CEN 2003): cumulative leaching of column-packed waste allows leachability to be assessed from low liquid to solid ratios typical of wastes before and soon after landfilling (L/S 0.1-1) up to higher liquid to solid ratios which typify longer-term leaching and which are more comparable to compliance tests (e.g. L/S 2-10). A column of waste is tested providing data which can be related to the monofill or stockpile situation at natural pH and can indicate the liquid to solid ratio which might be considered in treatment processes involving controlled flushing or residue-washing, particularly where pH dependence is not an issue. maximum availability leaching test (NEN 7341): this provides the potential leachable fraction that can be released under worst case environmental conditions and thus can be the source term for risk assessments based on leaching to the aqueous environment. Information on relative timescales for exhaustion of the contaminant supply can be obtained by comparing

the results of sequential flushing (increasing liquid to solid ratios) with availability, assuming no change in pH conditions is likely to occur. In many cases the leaching behaviour tests may indicate that a single treatment option will not be sufficient to generate a WAC compliant waste. A multi-phased treatment process may be required to remove highly-soluble as well as pH-dependent parameters, but the data will enable bench-scale or field-trials to be better focused. 3. THE ROLE OF THE LANDFILL OPERATOR The landfill operator is effectively the regulator of the WAC compliance scheme, risking breach of his permit conditions if he is found to have accepted wastes that exceed the appropriate limit values for his class of site. The landfill operator needs to be sure that all wastes arriving at his gate, including those that have been generated under worst-case as well as normal operating conditions at the waste producers plant, will comply with the WAC and therefore with the conditions of his site permit. Even if the snap-shot sample he takes for the purposes of preparing a quotation appears to be WAC compliant, he is dependent on the quality of the characterisation dataset provided by the waste producer and knowledge that it does not simply relate to best-case waste quality. Both parties will increasingly seek a partnership approach. In particular it will be very important to agree the scale of sampling, such that the landfill operator does not risk sampling a hot-spot within any load when a representative sample will be required to obtain an average concentration of the whole load for comparison with the waste acceptance criteria (Turrell et al, 2004). As the organic content of landfilled wastes decreases, particularly at hazardous waste landfills, the landfill operator will continue to need to use information on the buffering capacity and pH of wastes to effectively manage the loading ratios of the chemical reactor. If wastes of very different pH values and buffering capacity (acid neutralisation capacity) are deposited together, the more extreme wastes will tend to swamp the porewater conditions around the moderate wastes. This will compromise any leachability predictions based on natural pH, such as those from the WAC compliance test BS EN 12457. Figure 3 shows the very different profiles that are exhibited by some generic wastes. For example, APC residues and bottom ashes from MSW incineration could be deposited together at hazardous waste landfills if the latter exhibited hazardous properties. The ranges of natural pH values are close (pH 12-13) but the ANC values (9-12 and 2-4 mol/kg at pH 4, respectively) and leaching characteristics are very different. As part of his risk assessment and leachate quality predictions, the landfill operator would be advised to obtain an ANC/BNC and pH dependent leaching profile over the full relevant pH range for his landfill, both of which can be obtained using the pH dependence leaching test prEN 14429 (CEN 2002b). 4. CONCLUSIONS Sampling and testing to demonstrate compliance with the landfill waste acceptance criteria is a strong driver for embarking on a waste testing programme. However, with increasing pressure to divert waste from landfill to more sustainable and/or less expensive management options, other testing requirements will be required. The use of a carefully prepared sampling plan in line with

Figure 3 Examples of acid neutralisation capacity and pH profiles of generic wastes

14 extreme pH (high) and ANC (high) 12

10

APC (various)
8

pH
6

moderate pH, poorly buffered

Eluate pH recorded at 0 mol/kg during pH dependence test prEN 14429 (zero acid addition) = natural waste pH = pH of eluate from BS EN 12457 compliance leaching test.

CKD
4

F-sand SSI PFA

-5 0

BFS MSW IBA

BOS
extreme pH (low ) and ANC (high) 15

5 ANC mol/kg 10

prEN 14899 can help to ensure that all the objectives for sampling can be met, rather than needing to take a piece-meal approach. An ad hoc sampling programme will inevitably extend the timescales (and potentially the costs) for testing, something that the waste producer will seek to avoid as deadlines approach for the acceptance of WAC-compliant waste to landfill. ACKNOWLEDGEMENTS The authors would like to thank those waste producers who gave permission to use their data on an anonymous basis and to acknowledge funding from the Environment Agency and the Environmental Services Association Research Trust (ESART) under contracts EP0230 and 689198:005:F/010 respectively. The views expressed are those of the authors alone. REFERENCES CEN (1998) ENV 12920. Characterisation of waste Methodology guideline for the determination of leaching behaviour of waste under specified conditions. CEN/TC292/WG6. May 1998. CEN (2002a) BS EN 12457. Characterisation of waste leaching - compliance test for granular waste materials and sludges. Part 2: single stage batch tests at liquid to solid ratio 10 l/kg with particle size below 4mm. Part 3: two stage batch tests at liquid to solid ratios 2 and 8 l/kg with particle size below 4mm.CEN TC292/WG2. October 2002. CEN (2002b) prEN 14429. Characterisation of waste leaching behaviour tests influence of pH on leaching with initial acid/base addition. CEN TC292/WG6. April 2002.

CEN (2003) Draft prEN 14405. Leaching behaviour test upflow percolation test. CEN TC292/WG6. November 2003. CEN (2004) prEN 14899. Sampling of liquid and granular waste materials including paste-like materials and sludges - Part 1: framework for preparation of a sampling plan. CEN/TC292/WG1. January 2004. Chambers, B, Graham, A, Howles, D and Lewin. K, (2004). Options for the use of sewage screenings and grit. WRc Waste Research Limited report for Thames Water Landfill Tax Committee. ENTRUST Project no. 395069.020. European Council (2003) Decision 2003/33/EC of 19th December 2002 establishing criteria and procedures for the acceptance of waste at landfills pursuant to Article 16 and Annex II of Directive 1999/31/EEC on the landfill of waste. Official Journal of the European Communities L11 16.1.2003. NEN 7341 (1995) Leaching characteristics of solid (earth and stony) building and waste material. Leaching tests. Determination of the availability of inorganic components for leaching. ICS 13.030-70, 91.00. NEN. March 1995. NEN 7345 (1995) Leaching characteristics of soil and stony building and waste materials. Leaching tests. Determination of leaching of inorganic components from building and monolithic waste materials with the diffusion test. NEN. January 1995. Environment Agency (2003a). Guidance on the sampling and testing of wastes for waste acceptance procedures. Consultation Draft December 2003. Environment Agency (2003b). Hazardous waste. Interpretation of the definition and classification of hazardous waste. Technical Guidance WM2. ESART (2004) A practitioners guide to testing waste for onward reuse, treatment or disposal acceptance. Lewin, K, Turrell, J and Ellis, J. Environmental Services Association Research Trust. Hjelmar, O., van der Sloot, H.A., Guyonnet, D., Rietra, R.P.J.J., Brun, A. & Hall, D.H. (2002) Development of Acceptance Criteria for Landfilling of Waste: An approach based on impact modelling and scenario calculations. Proc 7th International Landfill Symposium, Sardinia, CISA, Cagliari. Landfill (England and Wales) (Amendment) Regulations 2004. Draft for consultation. Turrell, J, Lewin, K Ellis, J. A developing framework for waste sampling and testing. Waste 2004, Integrated Waste Management and Pollution Control, Stratford-upon-Avon, 28-30 September 2004. Graham, A and Lewin, K. Landfill waste acceptance testing: case studies. Waste 2004, Integrated Waste Management and Pollution Control, Stratford-upon-Avon, 28-30 September 2004.

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