Environmental Permitting

Regulations: Inert Waste

Guidance
Standards and Measures for the Deposit
of Inert Waste on Land
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Environment Agency Standards and Measures for the Deposit of Inert Waste on Land 2
Contents
Contents 1

1. Introduction 2

1.1 Aims and Scope of this Guidance 2

2. Technical Overview 5

2.1 Understanding the Site 5

3. Key Issues 6

3.1 Waste Acceptance 6

3.2 Environmental Risk Assessment 11

3.3 Protection of Soil and Groundwater 13

4.0 Techniques for Pollution Control. 14

(The following numbering relates to the Relevant Permit Conditions)

1.3 Finance 14

2.6 Engineering 14

2.7 Waste Acceptance 15

2.8 Closure & Aftercare 16

3.2 Fugitive emissions of substances 17

3.4 Noise and Vibration 18

3.5 Monitoring 18

4.1 Records 20

Appendix A1 21

Annex 1 25

Annex 2 26

Appendix A2 27

Glossary of Terms 28

References 30

1 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
1. Introduction
1.1 Aims and Scope of this Guidance
In “Getting the basics right – how to comply with your environmental permit” (GTBR) we
described the standards and measures that we expect businesses to take in order to control
the risk of pollution to air, land and water from the most frequent situations in waste
management and process industry.

This activity-specific guidance describes the additional standards/measures that we expect

operators depositing inert waste to take.

There are a number of key environmental issues for the deposit of inert waste. When we look
at your application we have to consider whether the proposed operations would meet the
necessary standards. The key issues are set out in section 3 of this guidance. We will need to
agree that your proposals for issues such as waste acceptance are appropriate before we
grant you a permit.

Sometimes, particularly difficult problems arise on issues such as noise or dust. It may then
be necessary to consult the ‘horizontal’ guidance that gives in depth information for particular
topics. Annex 1 of GTBR lists these.

Modern permits and standard rules describe the outcomes (or objectives) we want you to
achieve. They don’t normally tell you how to achieve them. They give you a degree of
flexibility.

The measures given in this guidance are not mandatory unless stated and they may not all
be appropriate for a particular circumstance. It is for you to use those that achieve the
objective – or to meet the objective by other means. If the outcomes are not being met, this
guidance should normally be the first point of call to consider what should be done to redress
the situation.

In response to the application form question regarding Operating Techniques, you should
address, in particular, the main measures you will use to control the issues in this document
as well as the key issues identified in GTBR.

Unless specifically stated, this guidance applies equally to disposal in landfill and recovery on
land. Standards and measures specific to disposal or recovery are identified.

This guidance covers the requirements you need to meet if you are depositing inert waste on
land. You need an environmental permit for a landfill for the disposal of inert waste on land.
You need an environmental permit where you recover inert waste on land, unless what you
do is exempt from the need to hold a permit. Please see our separate guidance on
exemptions.

1.1.1 Disposal

The Landfill Directive applies to waste destined for disposal onto or into land (article 2(g)).
1
What is a waste is defined by the Waste Framework Directive – ‘directive waste’. This
guidance is only relevant to landfills for inert waste and not to other classes of landfill. The
IPPC Directive 2 does not apply to landfills for inert waste.

1
Council Directive 2006/12/EC on waste
2
Council Directive [2008 reference] concerning integrated pollution prevention and control

2 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
Inert waste is defined by the Landfill Directive, article 2(e):
‘Inert waste’ means waste that does not undergo any significant physical, chemical or biological
transformations. Inert waste will not dissolve, burn or otherwise physically or chemically react,
biodegrade or adversely affect other matter with which it comes into contact in a way likely to give
rise to environmental pollution or harm human health. The total leachability and pollutant content of
the waste and the ecotoxicity of the leachate must be insignificant, and in particular not endanger
the quality of surface water and/or groundwater

The management of waste at a mineral extraction site needs to be covered by environmental

permits. There are two principal activities that need a permit. Firstly, the management of
extractive waste, and secondly where applicable, the disposal/recovery of waste framework
directive (WFD) waste. These activities could be covered by a single permit or two permits
each covering a different activity.

Areas of the site used for the deposit of silt washings and other extractive waste are covered
by the Mining Waste Directive, and should be permitted as extractive waste activity.

Areas of the site used for the deposit of WFD waste should be permitted as either a recovery
or disposal activity.

If a landfill permit includes an area currently used for the management of extractive waste
(e.g. silt washings), that permit should be varied to treat it is an extractive waste activity,
otherwise, if the waste is being disposed of, the relevant requirements of the LFD (e.g. waste
acceptance criteria) and landfill tax will apply to it.

If at a later date, WFD waste needs to be imported to that area for disposal or restoration, the
landfill permit can be varied to include it.

1.1.2 Recovery

You need to decide whether you are disposing of the inert waste or recovering it. We have
produced guidance on when an activity may be a recovery operation (Environmental
Permitting Regulations - Regulatory Guidance Series No. LFD1, (reference 4)). You can use
that guidance to help determine whether or not the activity is disposal and so whether the
Landfill Directive applies.

This guidance only considers operations for the recovery of those wastes in Table 1 below.
This list is considered to cover the majority of inert wastes you are likely to use for recovery
on land. You can include other wastes in your application but you would need to justify in your
permit application why such waste is considered to be suitable for recovery.

3 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
Table 1 Wastes that may be used for recovery

Source of waste Kind of waste List of wastes

code
WASTES RESULTING FROM EXPLORATION,
MINING, QUARRYING, AND PHYSICAL AND
CHEMICAL TREATMENT OF MINERALS
Wastes from mineral non-metalliferous Waste overburden 01 01 02
excavation
Wastes from physical and chemical Waste gravel and crushed rocks 01 04 08
processing of non-metalliferous minerals other than those containing
dangerous substances
Waste sand and clays 01 04 09
CONSTRUCTION AND DEMOLITION WASTES
(INCLUDING EXCAVATED SOIL FROM
CONTAMINATED SITES)
Concrete, bricks, tiles and ceramics Concrete 17 01 01
Bricks 17 01 02
Tiles and ceramics 17 01 03
Mixtures of concrete, bricks, tiles 17 01 07
and ceramics
Soil (including excavated soil from Soil and stones including clays, 17 05 04
contaminated sites), stones and dredging silts and topsoil and including soil
spoil and stones from contaminated
sites.
WASTES FROM WASTE MANAGEMENT
FACILITIES, OFF-SITE WASTE WATER
TREATMENT PLANTS AND THE
PREPARATION OF WATER INTENDED FOR
HUMAN CONSUMPTION AND WATER FOR
INDUSTRIAL USE
wastes from the mechanical treatment of Minerals (for example sand, 19 12 09
waste (for example sorting, crushing, stones)
compacting, pelletising) not otherwise
specified
Park and garden waste Soil and stones 20 02 02

4 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
2. Technical overview
2.1 Understanding the site
You must describe the site by developing a conceptual model. We have produced a template
for the development of an environmental setting and installation design (ESID) report that is
part of our guidance on the application form. Although the ESID report has been developed
for landfills it is relevant for recovery operations involving the deposit of inert waste on land.
You should describe the potential hazards and receptors at the site in accordance with our
guidance on Environmental Risk Assessment (reference 6). Some sections of the ESID will
not be applicable to landfills for inert waste or sites for recovery of waste on land but the ESID
will provide a framework for your development of the conceptual model.

For both disposal and recovery activities, you must describe the hydrogeological conditions
around the site, bearing in mind the scale of the operation. This is essential to determine how
sensitive the groundwater is to any potentially polluting substances in the waste. You may not
need to do this for small scale recovery activities as they are unlikely to pose any threat to
groundwater.

The level of detail required to describe the hydrogeological conditions must be proportionate
to the sensitivity of the site and the scale of the activity. For instance if there is a substantial
quantity of cohesive soil or clay underlying the site it will be less critical for you to determine
the exact thickness than if there is only a thin layer of cohesive soil or clay.

We would expect you to undertake a tiered approach to describing the site beginning with a
simple desk study leading, where necessary, to an intrusive site investigation. Where a site
investigation does not adequately describe the site, you will need to undertake further work.
You must provide us with a sufficient understanding of the hydrogeological conditions, or we
may refuse the application. A ‘sufficient understanding’ means that you must provide us with
evidence such that we agree that the site is sufficiently well understood to predict the risks
and the necessary risk management measures.

Recommendations for site investigation

1 Your 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
proposal, the complexity and sensitivity of the geological and hydrogeological environment, and
the proximity of potential receptors which may be affected. Since knowledge of many of these
aspects will only be revealed as the investigation unfolds, any investigation should be phased.
You should have clear identifiable objectives for each phase of the site investigation which
should be re-appraised during and between phases.
2 You should adopt a quality approach for all site investigation activities, as part of the overall
quality approach to design, construction and operation.
3 Your investigations should include both the site and the surrounding areas that will be influenced
by the activity. For areas of the site which lie outside the permanent deposits of waste, reference
should be made to our guidance document H5 which details the site condition report
requirements (reference 8).
4 Your investigations should include the initial design of the monitoring programme, including
where relevant the installation of groundwater and soil gas monitoring points to allow collection
of background/ base readings over the maximum practicable period of time. For example, this
should take into account seasonal fluctuations in groundwater levels.
5 You should undertake an accurate topographic survey (topographical surveys are considered in
more detail in the monitoring section (see under Condition 3.5). You should survey all borehole
positions and other site features such as streambeds, springs, outcrops and exposures.
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).

5 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
3. Key Issues
3.1 Waste Acceptance
Your controls on the acceptance of waste are the most important way of controlling pollution
from activities involving inert waste. You have to give us, as part of the application form, a list
of the waste types you wish to dispose of at your landfill. We will include a list of permitted
wastes as part of the permit.

Your decisions about waste acceptance should take place in advance of the arrival of a load
of waste at the site. The producer (or other holder) of the waste must supply you with the
necessary information to allow a decision to be made about whether the waste can be
accepted.

If this information is not supplied in advance you may be expected to make decisions about
waste acceptability at short notice. This could lead to delays at the weighbridge, or waste
acceptance / rejection without appropriate consideration. Your procedures should include
some form of pre-acceptance approval in order to:
• reduce the incidence of unauthorised waste arriving at the facility and
• minimise delays in processing paperwork at the weighbridge.

Pre-acceptance approval may not always be possible, for example for one-off loads that turn
up at the gate. At sites where this might occur, your procedures must include a mechanism
that allow you to make a decision about whether you can accept such a load.

Where waste from a producer is refused you should tell him why and make a record of this.
Where wastes from a particular producer are being repeatedly refused, you may need to
advise the producer to seek an alternative route for disposal.

The following section describes the information that the producer must supply to you before
you can make a decision to accept the waste for disposal or for recovery on land.

3.1.1 Pre-acceptance requirements

The Duty of Care 3 requires, among other things, that all waste be described adequately to
allow the subsequent holder to deal with it in a way that will not cause pollution of the
environment. This duty applies to all waste transfers between parties including transfers to
operators of disposal or recovery sites. Depending on the circumstances, additional
information may be required:

Disposal: The Landfill Directive sets out specific requirements for characterising the waste
that is destined for landfill. The council decision 4 identifies that:

Basic characterisation is the first step in the acceptance procedure and constitutes a full
characterisation of the waste by gathering all the necessary information for a safe disposal of
the waste in the long term. Basic characterisation is required for each type of waste.

Disposal: The council decision makes it clear that, ‘The producer of the waste or, in default,
the person responsible for its management, is responsible for ensuring that the

3
The Environmental Protection (Duty of Care) Regulations 1991 and the Duty of care Code
of Practice. http://www.defra.gov.uk/corporate/consult/waste-dutyofcare/statutory-
guidance.pdf (Both are currently being reviewed. Revisions expected by October 2009).

4
Council Decision 2003/33/EC on waste acceptance.

6 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
characterisation information is correct’. This means that the producer 5 should be undertaking
the necessary checks to confirm that the waste is inert.

Further guidance on waste characterisation and testing can be found in our ‘Guidance for
waste destined for disposal in landfills’ (reference 10).

In the following sections, the term waste characterisation is used as a generic term
applicable to both recovery and disposal whereas the term basic characterisation applies
only to landfills.

3.1.2 Waste characterisation

The main responsibility for characterising the waste lies with the producer. You should have
procedures describing how you will assess the information provided by the producer to
ensure that when the waste arrives at your site it can be accepted.

Recommendations for waste characterisation

1 The producer must:
• describe the characteristics of the waste
• identify the potential risks to the environment.

2 Testing to establish the waste’s chemical composition is a critical part of the waste
characterisation process (see below for testing requirements). You should keep records of the
characterisation for 2 years (this is a legal requirement for waste destined for landfill).

Disposal Only - Recommendations for waste characterisation

1 The Council Decision requires that for waste going to landfill for inert waste the producer must
also:
• confirm that it is not hazardous and that it is inert,
• identify that the waste is appropriate for a landfill for inert waste,
• identify what treatment method may be appropriate,
• where appropriate (see below), identify the key chemical characteristics (‘critical
parameters’) for future compliance testing and
• identify the key chemical characteristics to allow the operator to undertake on-site
verification testing.

Recovery Only - Recommendations for waste characterisation

1 For recovery where appropriate, the producer’s characterisation must also:
• identify that the waste is suitable for the use to which it is to be put,
• identify the key chemical characteristics to allow the operator to undertake on-site
testing to confirm that the waste is acceptable.

5
For the purposes of this guidance the term ‘producer’ also means ‘secondary producer’, that
is, it is the person planning to dispose of or recover the waste.

7 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
There are two general sources of waste:

• Waste regularly generated by the same process, and

• Wastes that are not regularly generated.

The nature of the waste generation will determine how the waste can be characterised

Waste regularly generated by the same process

These are wastes produced by a single facility or process that can be characterised in detail.
The producer can undertake a range of tests to demonstrate the consistency of the waste.
Once this has been done, a reduced suite of tests, representing the key variables of the
waste stream, can be applied to confirm that the waste remains within defined limits (see
compliance checking below). The frequency of compliance checking should also be
determined based on the variability of the source material.

It is unlikely that many inert wastes will fall into this category. For example, we consider that
most excavations be regarded as ‘one off’ waste generations.

A very large scale excavation taking place over a long period may be regarded as a regularly
generated waste with an initial waste characterisation and subsequent compliance testing
throughout the period the waste is received.

There will be recycling facilities that treat construction, demolition and excavation wastes and
generate regular waste streams that are recovered or disposed of. The characterisation
requirements of these wastes will differ according to the variability of the waste accepted and
generated. For instance, a waste stream of ‘fines’ is likely to be more variable in chemical
composition than a secondary aggregate and so the compliance checking required will be
different. If the variability is such that the waste can fall outside what is acceptable for the
landfill (the inert waste acceptance criteria), or would not be suitable for use, a different
disposal or recovery route should be found for the waste.

Wastes that are not regularly generated

These wastes are those that do not regularly arise from the same process or facility. This may
apply to inert wastes like;
• excavated soil from a building development,
• excavated soil from a ‘cut-and-fill’,
• waste arising from street-works.

For wastes generated on a ‘one-off’ basis the producer cannot describe the waste through a
separate process of identifying the general characteristics and variability and then subsequent
checking to ensure the waste remains the same (compliance checking). Individual waste
streams will need to be characterised (and possibly tested – see below) as part of waste
characterisation.

Where the source of the waste is judged to be of consistent quality (for example, sub-soil from
a green field development) fewer substances may need to be identified than for a less
consistent source (for example, street-works). We have produced guidance on sampling and
testing waste to ensure that an adequate number of samples are taken to show consistency
(reference 11).

8 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
3.1.3 Waste testing

Cases where testing is not required

1 The producer does not need to test inert waste destined for disposal or recovery for waste
characterisation where the waste is:
• a single stream (only one source) of a single waste type and;
• on a list of wastes not requiring testing (the table in the Council Decision, section 2.1.1).
Different wastes contained in the list may be accepted together, provided they are from
the same source

2 Testing is not required only where there is confidence that the waste is not contaminated. If
there is a reasonable doubt, testing must be undertaken.

3 The restriction to a single source is because it is the knowledge of where the waste comes from
that gives you confidence, along with other evidence, that it is not contaminated.

Disposal Only - Cases where testing is not required

1 Testing of a specific waste stream is also unnecessary where we have agreed that all the
necessary information for basic characterisation is known and has been duly justified by the
waste producer (Council Decision, paragraph 1.1.4(b)). See guidance in reference 10.

3 Where testing is not required for waste characterisation it is also not required for compliance
testing (see below).

Disposal only -Cases where testing would be required

1 For wastes that do not meet the above criteria the producer must test the waste to determine its
chemical characteristics and to show that the waste will not have a detrimental impact on the
environment in the long term.

Disposal Only - Cases where testing would be required

1 For landfills this testing must:
use either BS EN 12457 Part 2 or Part 3 6 . We would advocate use of the part 3 (2 stage) test for
all basic characterisation.
demonstrate compliance with the Waste Acceptance Criteria detailed in the Council Decision,
section 2.1.

Recovery Only - Cases where testing would be required

1 For waste for recovery, testing will only be necessary where there is a suspicion of
contamination of the waste or where the recovery site is in a sensitive location as determined by
the risk assessment.

2 The responsibility for testing for waste characterisation lies with the producer but this
responsibility can be fulfilled in discussion with you.

3 If a waste destined for disposal does not require testing in accordance with the Council
Decision, it will not need testing where it is to be submitted for recovery. If a waste destined for
disposal does need testing in accordance with the Council Decision, some form of screen
testing may be appropriate for waste submitted for recovery.

6
EN12457, parts 1 – 4, ‘Leaching — Compliance test for leaching of granular waste materials
and sludges’. http://www.environment-agency.gov.uk/static/documents/Briefing_-
__12457_test_-_March_09.pdf

9 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
Recovery: An example of the type of procedure that could be developed might include; a
tiered system, with a basic screen test which then identifies the need for further testing. These
can be the producer’s own waste testing procedures or can have been supplied by the
operator to fulfil part of the necessary pre-acceptance information.

Producers would instruct their analytical laboratories to carry out a basic screening test, which
contains routine determinands. Additional analysis should be carried out where, the
concentration of certain substances in the screening test exceed a specified limit. Appendix 2,
table A gives an example of substances that could be included in the screening test. Then, for
example, where the toluene extractable matter (TEM) concentration exceeds the screening
test limit, the additional testing in table B for total petroleum hydrocarbons (TPH) and
polycyclic aromatic hydrocarbons (PAH) could be undertaken. Further analysis may be
necessary for Benzene, Toluene, Ethylbenzene, and Xylenes (BTEX) on the basis of this
additional testing.

3.1.4 Compliance checking

Compliance checking is required to periodically check waste that is regularly generated by the
same process. As stated above it is considered unlikely that many inert wastes will be
regularly generated by the same process.

Where waste is regularly generated, the waste acceptance requirements can be limited to
checking that nothing has changed since the initial waste characterisation; that is, checking
only for the key variables.

Those wastes which do not require testing to characterise the waste do not require testing for
compliance but other checks, such as that the source remains the same, will still be required.

Disposal Only – Compliance testing

1 For landfills for inert waste the compliance testing (for wastes that require testing) must include
the same leaching test that was used to characterise the waste (BS EN 12457, Part 2 or 3).

2 Having identified through waste characterisation testing which substances are likely to present
the greatest risk, subsequent testing can be carried out to check for the presence of those
specific substances.

3 For regularly generated wastes, it is the compliance testing that will be the ongoing check that
the waste remains as identified in the waste characterisation. This formal check must take place
at least once per year.

4 Unless the waste is very consistent, we recommend that procedures should be in place to
conduct simple screening tests to demonstrate the consistency of the waste (see the above
example under waste characterisation).

3.1.5 Waste treatment for disposal

The Landfill Directive requirement for treatment prior to deposit applies only to wastes
destined for landfill. It does not apply to waste being recovered on land.

10 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
We have produced guidance on pre-treatment 7 and a fact sheet specific to the treatment of
inert waste 8 . Where treatment is not technically feasible, the waste producer (or holder) must
include the reasons in the waste description passed on with the load so that the operator
knows why the waste has not been treated.

Treatment is intended to reduce the amount of waste that goes to landfill and enhance its
recovery (by allowing its re-use or recycling). Sources of advice on waste reduction, recovery
and treatment are listed in the fact sheet.
Inert wastes are often suitable for recycling, for example as aggregate or engineering fill
material. Possible treatments include physical crushing, sorting or screening to make it
suitable for use. The unusable residues from this type of treatment can be landfilled as a
treated waste subject to it meeting appropriate waste acceptance criteria.

Separating different materials, either by keeping them separate as they are produced
(segregation) or by separating them after they are mixed with other materials (sorting) is an
acceptable treatment. This is as long as all the segregated or sorted materials are not then
sent to landfill for disposal. Any waste remaining after these treatments can be landfilled as a
treated waste.

3.2 Environmental Risk Assessment

3.2.1 Scope of a risk assessment for inert waste

You must submit an environmental risk assessment with the application for a permit for a
landfill for inert waste or a recovery operation using inert waste.

We have produced generic environmental risk assessment guidance in our document H1

(parts 1 and 2) – reference 6. This guidance adds to that and provides some specific
requirements for the use and disposal of inert waste to land.

Your risk assessment may need to consider the following:

• the acceptance of waste that is not inert;
• noise from plant and equipment;
• dust emitted to air;
• suspended matter in surface water;
• mud on public roads and highways;

You must consider the stability of the waste mass in your risk assessment.

3.2.2 The Groundwater Directive and Regulations

We do not expect the Groundwater Regulations to apply to landfills for inert waste or the
recovery of inert waste (see our guidance on hydrogeological risk assessment for landfills and
the derivation of groundwater control and trigger levels – LFTGN 01 9 ).

Your risk assessment must however still consider the risk to groundwater from waste that
may not be truly inert.

3.2.3 Describing the risk

7
Treatment of non-hazardous waste for landfill, Environment Agency, February 2007
http://publications.environment-agency.gov.uk/pdf/GEHO0207BLWJ-e-e.pdf
8
Factsheet for the treatment of inert waste, Environment Agency, 2007
http://publications.environment-agency.gov.uk/pdf/GEHO0707BMYL-e-e.pdf
9
Available at: http://environment-
agency.gov.uk/static/documents/Business/hyrogeological_0403.pdf

11 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
Assessing the risk

Your risk assessment must consider the chance of accepting waste that is not inert (non-
inert), for example, contaminated soil, or non-inert waste concealed within a load of waste
that appears to be inert.

When you have identified the chance of non-inert waste being accepted, you should predict
what the likelihood is of that waste causing pollution or harm. You should adopt a source-
pathway-receptor approach. Our H1 guidance on environmental risk assessment shows how
to describe the risk. (reference 6).

Your risk assessment must include the possible effect of accidents, for example fuel spills,
run-off to surface water.

Pollution control measures in the risk assessment

Your operational procedures to reduce the risk of the acceptance of non-inert waste are a key
element in the assessment of the risk. For example, your procedures for the refusal to accept,
uplift, re-load and remove non-inert waste. Guidance on procedures for waste acceptance
can be found in section 3.1 above.

The level of risk assessment

We would normally expect you to provide a qualitative assessment of the risk from the deposit
of inert waste to land. You should develop a table, such as that in part 1 of our H1 guidance,
with supporting information in the form of plans and cross sections to provide a detailed
understanding of the site’s setting and sensitivity (see the section on understanding the site
above). The adequacy of the risk management measures (waste acceptance procedures) are
an essential part of the risk assessment process.

You may need a more detailed and quantitative risk assessment for a landfill for inert waste.
You are unlikely to have to provide such a high level of detail for a recovery activity, although
it may be necessary in some circumstances.

Disposal Only – Level of risk assessment

1 You are likely to have to produce a quantitative environmental risk assessment for a landfill for
inert waste where:
• you propose to reduce the specification of the Landfill Directive, Annex 1 geological
barrier on the basis of an assessment of risk to water; and
• the receiving environment is particularly sensitive, for example below the water table in
a major aquifer or with a direct pathway to sensitive surface water.

Where you have to develop a quantitative environmental risk assessment for a landfill for inert
waste, the following provides guidance as to what we might expect to see in your assessment
2 A LandSim (version 2.5), or similar, hydrogeological risk assessment (HRA) can be undertaken
using WAC values for the inert waste (in mg/l) as a source term (‘input parameter’). This should
seek to demonstrate that adequate attenuation is present for normal operations where the waste
acceptance criteria are met. A source term using the waste acceptance criteria values is likely
to be conservative since not all waste will be close to all, or perhaps any of the WAC limits. Also,
the laboratory leaching tests will only provide an indication of the bulk leaching behaviour of the
inert waste.

3 The HRA using a source term based on WAC values can be used to assess how likely the
waste is to cause pollution. This will allow an assessment of the sensitivity of the site with
reference to certain contaminants above the WAC limits. This will help determine whether the
attenuation provided is adequate and help refine your waste acceptance procedures. If the HRA
suggests an unacceptable risk to groundwater, the standard of the geological barrier or
operators waste acceptance procedures will need to be revised.

4 A ‘back calculation’ can be undertaken to see what emissions from the waste would have to be

12 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
Disposal Only – Level of risk assessment
to cause pollution. This would allow a view to be taken as to how likely that level of
contamination would be. This assessment may indicate that levels above the WAC limits would
not cause pollution. However, this does not mean higher levels can be accepted it simply gives
us confidence that the statutory WAC leaching limit values will provide a high level of
environmental protection. We have produced guidance on this approach in, ‘Remedial Targets
Methodology – hydrogeological risk assessment for land contamination 10 .

3.3 Protection of soil and water

Recommendations for rain water, surface water and groundwater

1 You should plan water management at the site to take into account the meteorology, hydrology
and hydrogeology of the site.

2 You should design the surface water drainage system to cope with predicted storm events.

Protection of soil and water

1 You do not need a leachate collection and sealing system at sites for either the recovery or
disposal of inert waste.

2 You do not need an engineered cap at sites for either the recovery or disposal of inert waste.

We have produced separate guidance on the Landfill Directive requirements for the protection
of soil and water RGS No. LFD1. (reference 4)

Disposal only- Recommendations for geological barriers

1 The geological barrier must provide a barrier to the movement of contaminants i.e. it must
possess purifying powers (be able to attenuating potential releases from the waste).

2 The geological barrier must extend along the base and all the way up the sides of the landfill
site. Your design must demonstrate the stability of any side-wall geological barrier.

3 The geological barrier must be equivalent to a mineral layer a minimum of 1m thick with
permeability no greater than 1 x 10-7 m/s.

4 Where the natural geology cannot provide the necessary attenuation, the geological barrier can
be artificially enhanced. The artificially established geological barrier must be a minimum of 0.5
m thick.

5 Where an appropriate quantitative risk assessment can demonstrate that the landfill poses no
potential hazard to soil, groundwater or surface water, the requirements for the geological
barrier may be reduced accordingly. In some circumstances it is possible that no geological
barrier will be necessary.

6 You should follow Appendix 1 for the engineering requirements for the installation of a
geological barrier at landfills for inert waste.

10
Available at: http://publications.environment-agency.gov.uk/pdf/GEHO0706BLEQ-e-
e.pdf?lang=_e

13 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
4. Techniques for pollution
control
This section aligns with your permit and provides additional guidance from that contained in
‘Getting the Basics Right’. The condition numbers are typical but it is possible that the
relevant condition has a different number in your permit.

Condition 1.3 Finance (disposal only)

Condition 1.3.1 identifies the financial provision agreement made by the operator of a landfill
for inert waste 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.

Condition 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 Directive, article 10.

Financial Provision
Financial Provision for landfills for inert waste 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 (reference 14).
Updated guidance on Financial Provision is shortly to be published.

Costs
Article 10 of the Landfill Directive relates to charges, rather than directly to the aftercare
period, which is covered by Article 8. Article 10 requires that provision be made for, ‘at least’
30 years.

You 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 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.

Adequate provision must be made for post-closure aftercare and for response to any
unforeseen incidents.

Condition 2.6 Engineering (Disposal only)

This condition requires you to submit to us construction proposals for new cells and other
infrastructure. Where you are depositing waste for recovery the requirement for construction
quality assurance (CQA) will apply to the construction of monitoring boreholes, if these are
needed.

The requirements for engineering a geological barrier only apply to landfills for inert waste
and only where it is necessary to artificially construct a geological barrier.

Where the landfill is not constructed in discrete cells, the condition will require the operator to
submit generic construction proposals for the geological barrier with the requirement for a
periodic review of the proposals.

14 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
Disposal Only - Recommendations for construction quality assurance for the
geological barrier
1 You should follow Appendix A1 for the construction quality assurance requirements for the
installation of a geological barrier at landfills for inert waste

You will need to provide construction quality assurance for any:

• surface water drainage system;
• groundwater monitoring boreholes;
• gas monitoring boreholes.

It is essential that monitoring infrastructure is correct built and documented if we are to have
confidence in the monitoring information provided. Whilst 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 us and
• the design, construction and testing are well documented to provide an audit trail.

Your CQA procedures for monitoring infrastructure should follow the guidance given in
references 12 and 13.

Recommendations for construction quality assurance

1 You should submit CQA plans sufficiently in advance of the programmed work to allow us to
consider the proposals.

Four weeks is considered a reasonable minimum time for approval to be gained for a
construction design and CQA plan.

You should discuss your programme of works with us to agree a programme of submission and
approval for CQA plans.

2 You should submit a validation report which 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.

Condition 2.7 Waste Acceptance

You are responsible for ensuring that the waste accepted at the site, meets the requirements
of the permit. If there is no pre-acceptance or one-off load approval, the load must not be
accepted.

15 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
Recommendations for waste acceptance
1 You must visually inspect each load of waste delivered to the site before (unless this is
impractical) and after unloading. All documentation shall be checked (for example, the waste
description 11 ).

2 You must only accept waste at the site if it is the same as that which is described in the
accompanying basic characterisation documentation (this may include the acceptance of one-off
loads and the allowance for small amounts of other materials 12 in loads arising from construction
and demolition). If this is not the case, the waste must not be accepted.

3 Ensure that any testing (including a visual inspection) for on-site verification confirms that the
quality of the waste is consistent with the quality shown by waste characterisation and
compliance tests.
4 Samples you have take periodically for on-site verification testing shall be kept for a period of at
least 1 month.

5 You should visually inspect all waste at the point of deposit using staff who are:
- aware of the waste description for each load they are inspecting
- familiar with the wastes permitted for deposit

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 then you should ensure that the
load of waste is:
- reloaded on to the delivery vehicle
- removed to a designated quarantine area.

The waste should not be accepted at the site.

Condition 2.8 Closure & aftercare (disposal only)

You are required by this condition to maintain a closure and aftercare management plan
through out the life of the landfill. This is a requirement of the Landfill Directive (Article 13).

Closure is an ongoing process between the time when the site is ‘closed’, i.e. has ceased
accepting waste for disposal and ‘definite closure’, i.e. when we agree that the site may enter
the aftercare phase.

We have produced separate guidance on landfill closure in our RGS No. LFD1 (reference 4).

Disposal Only - Recommendations for the closure and aftercare management plan
1 Monitoring plays a vital part in determining the performance of the landfill against any
assumptions made. You should consider the following factors:
- generation of landfill gas;
- potential for leachate or gas to be generated in future;
- physical stability of the waste and associated structures;
- surface water and groundwater monitoring.

2 You should review the Site Closure Plan 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.
You should keep the plan updated as material changes occur.

11
The duty of care requires that a waste description is transferred when waste is passed between one
holder and another. See The Environmental Protection (Duty of Care) Regulations 1991 and the Duty of
Care Code of Practice. http://www.defra.gov.uk/environment/waste/legislation/duty.htm (Both are
currently being reviewed. Revisions expected by October 2009).
12
‘Other materials’ includes metals, plastic, soil, organics, wood, rubber, etc consistent with
the footnote to the table in the Council Decision, Annex 1, paragraph 2.1.1

16 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
Conditions 3.2 Fugitive emissions of substances

You should comply with the guidance on ‘Fugitive and diffuse emissions’ in ‘Getting the
Basics Right’. For the deposit of inert waste, particular care should be given to the following.

Particulate matter

Recommendations for particulate matter control – dust

1 You should have procedures 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 Your site design should minimise the area left unrestored. Restoration should take place as
soon as possible following the end of waste deposit.

3 You should extend surfaced site roads as far as possible to the tipping face and should make
them available for as long as possible. You should maintain surfaced site roads and keep them
in a clean condition.

4 You should control the movements of site traffic including restrictions on routes and speeds.

5 You should locate wheel washers far enough from the site entrance to allow any residual debris
to be deposited within the site.

6 You should provide dust suppression including the availability of ‘bowsers’ and water supplies.

Mud on the road

Recommendations for preventing mud on the road

1 Your management system 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 them
leaving the site;
- maintenance (for example 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, you should erect
warning signs on the highway to inform users of the potential hazard following approval by the
highway authority.

3 You should employ road sweepers immediately to clean the affected area.

17 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
Condition 3.4 Noise and vibration
You should comply with the guidance on ‘Noise’ in ‘Getting the Basics Right’. Within this
sector, particular care should be given to the following.

Recommendations for noise and vibration control

1 You should ensure regular maintenance of the access roads to repair ‘pot-holes’; this serves to
significantly reduce noise generated by empty vehicles.

Condition 3.5 Monitoring

Condition 3.5.1 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 of the
permit.

Site specific requirements will be set in schedule 4, based on the technical assessment of the
application.

Condition 3.5.2 requires records to be maintained of the monitoring you undertake.

Condition 3.5.3 requires topographical surveys to be undertaken at certain times. This is to

define levels, for example the base of a new area for waste deposit.

Monitoring is required at all sites for disposal and may be necessary at recovery sites
depending on the scale of the operation and the potential for risk to the environment.

Recommendations for monitoring

1 You should design your monitoring systems to:
• show that the environmental protection is working as intended;
• show that the permit conditions are being fulfilled (in particular waste acceptance); and
• provide information that can be included in an application to surrender the permit.
2 Where monitoring is required, you must have a monitoring programme as part of your
management system for the site.
3 You must derive the frequency and locations for monitoring from the risk assessment. This
frequency of monitoring and the frequency for reporting data will be specified in the permit.
4 Your management systems must ensure that field monitoring and sampling are undertaken in
accordance with a quality control system, by appropriately trained staff.

5 Any laboratory analyses must be carried out by a competent laboratory in accordance with a
recognised quality control standard (for example, ISO 9000, EMAS). We have produced,
‘guidance on monitoring landfill leachate, groundwater and surface water’ 13 that provides more
detail for surface water and groundwater monitoring.

Recommendations for surface water monitoring

1 You must undertake surface water monitoring up and down gradient of the site where there is a
pathway from the activity to the surface water. This is to track changes in surface water quality
that may be attributed to the site.

13
Available at: http://www.environment-
agency.gov.uk/static/documents/Business/report_1_533191.pdf

18 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
Recommendations for groundwater monitoring
1 You must undertake groundwater monitoring up and down gradient of the site where there is a
pathway from the activity to the groundwater. The risk assessment may also have identified
what are the most important potential contaminants to consider. This should inform the
monitoring programme. Where monitoring is required, it will be to confirm that the site is not
having an impact on groundwater quality.

2 Groundwater monitoring is unlikely to be necessary at a site where there is a thick unsaturated

zone (for example, greater than 10 metres depending on the likely attenuation in the
unsaturated zone), but is likely to be required where the site is close to or below the water table.

3 Your management system must identify when a significant change in groundwater quality has
occurred so that it can be reported. This will be based on background groundwater quality
obtained prior to the start of operations, or groundwater up gradient of the site. Our ‘guidance on
the monitoring of landfill leachate, groundwater and surface water’ (reference 12) provides more
detail. The technical guidance on monitoring groundwater is relevant to the monitoring of both
recovery and disposal sites.

Recommendations for gas monitoring

1 Gas management and collection will not be required by the permit as it is unlikely that methane
will be produced at sites for the disposal or recovery of inert waste.

2 The permit will normally require you to monitor within the waste for methane, carbon dioxide,
oxygen and atmospheric pressure to confirm that biodegradable waste has not been accepted
at the site. Such monitoring will not be required for small scale recovery operations.

3 Your gas monitoring programme must provide confidence that the deposited waste is not
generating methane and / or elevated carbon dioxide.

4 The need for and frequency of monitoring will depend upon the quantity of waste, the depth of
the deposits and the morphology of the site.

5 You should monitor at permanent boreholes and not use searcher bars (also known as spike
tests). However spike tests may be used:
• where the waste is less than 4 m deep;
• during operations as an early warning of the receipt of biodegradable waste;
• to provide additional information for the surrender application.
6 Sites (or parts of sites) where the maximum final depth of waste is less than 4 metres will not
normally require permanent in-waste gas monitoring boreholes.

7 You should install monitoring boreholes within the waste at a frequency of no less than 2
boreholes per hectare with a minimum of 4 boreholes per site. The location of boreholes needs
to be considered with reference to the practicalities of access and after use of the site.

8 You should raise the boreholes with the waste or retro-drill them as soon as practically possible
after any phase of the site has reached its final level. You can consider mobilisation costs and
ground conditions when deciding what is practically possible. Our guidance on the management
of landfill gas 14 should be used for the design of gas monitoring boreholes (based on the design
of the external monitoring borehole for landfills for non-hazardous biodegradable waste).

9 Surface emissions monitoring (for example, flux box monitoring) will not be necessary though
you can consider walkover surveys.

14
Available at: http://www.environment-
agency.gov.uk/static/documents/Business/lf_tgn_03_888494.pdf

19 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
Recommendations for surveys
1 You should undertake topographical surveys at least annually.
2 We may agree to reduce the frequency at which you produce plans in the aftercare phase where
there is no evidence of settlement at the site. For sites for recovery where no significant change
in levels is identified after the first annual survey, you will not normally need to give us future
surveys.

Disposal Only - Recommendations for surveys

1 The Landfill Directive specifies the information that must be recorded during the operational and
aftercare phases. The permit will require a plan to identify the area of the site filled and the
remaining capacity. Other issues can be provided as part of an annual report.

Permits for disposal or recovery will include conditions to ensure that monitoring continues
after the deposit of waste ceases.

Recommendations for aftercare monitoring

1 Monitoring information is important to confirm that the waste is stable physically and chemically.
One of the objectives of monitoring is to demonstrate that permit conditions are being complied
with. You can use information that demonstrates in particular that the conditions on waste
acceptance were complied with in support of an application to surrender the permit. Your
records of the waste accepted during the operation of the site are also essential evidence that
the site will not cause pollution.
2 The evidence that you have gathered through monitoring during the operational life of the permit
must be supplemented by a short period of monitoring (methane, carbon dioxide and water)
after the closure of the site. Where the information from the operational period is good, you will
only need a short period of ‘aftercare’ monitoring before you can make an application for
surrender.
3 We would expect two years of aftercare monitoring that indicates no problems, at an appropriate
frequency (for example, quarterly) to be sufficient.

Condition 4.1 Records

Condition 4.1.1 sets out the basic record keeping requirements.

Disposal Only - Recommendations for record keeping

1 The Landfill Directive requires the landfill operator to keep a register of the quantities and
characteristics of the wastes deposited at the site (Article 11). This record can provide the
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 List of waste code, the
SIC code and appearance of the waste.
- waste origin. Where practicable the source of the waste should be recorded.
-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.

Where you believe that the identification of a specific waste producer is commercially sensitive,
then you should record this within the register and include a simple justification summary.

20 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
Appendix A1
Engineering requirements for the development of a
geological barrier at a landfill for inert waste
CQA Requirements

Condition 2.6 of the permit template for landfills for inert waste requires the operator of the
site to submit construction proposals for the development of new cells to the Environment
Agency. At landfills for inert waste, this requirement will cover the construction and quality
assurance of the geological barrier across the base and sides of the landfill.

For a landfill for inert waste, it will usually be acceptable for a single set of construction
proposals to cover the construction of the geological barrier for the whole site. It will however
be necessary to periodically review these proposals to ensure they remain appropriate. As a
minimum, this should be in line with the hydrogeological risk assessment review every 4
years.

The geological barrier will be provided by suitable selected in situ or imported materials. The
operator’s CQA plan must set out how he will ensure that suitable material is used in
construction of the geological barrier. The overriding requirement for the CQA plan is to
demonstrate that suitable material has been used.

The confidence required in the design of the geological barrier must relate to the sensitivity of
the environment surrounding the site. The level of quality assurance to ensure the suitability
of the materials used and construction method will be related to the aquifer type below the
geological barrier. It is not considered necessary to have full-time independent CQA
supervision of engineering works at inert sites however the level of CQA supervision will be
greater in more sensitive locations.

The objective of the third party CQA supervision will therefore be to confirm that appropriate
procedures are implemented at the site, and to provide assurance that only suitable materials
and construction methods are used. Where necessary the CQA Engineer will provide
adequate training to allow site staff to follow any such procedures and ensure that an
auditable system of record keeping is implemented to demonstrate compliance with the CQA
plan. The following are the minimum requirements to be included in the CQA plan;

• Production of a method statement for the construction and placement of the

geological barrier.
• Training of site staff on the requirements of the CQA plan including record keeping
and procedures for site specific material selection.
• Criteria for rejection of any materials not deemed suitable for the geological barrier.
• Where there are specific design criteria, such as minimum shear strength, the CQA
plan must clearly set out how these are to be assessed with clearly defined
acceptable limits.
• Any conformance testing must be carried out by the CQA engineer.
• Level of CQA supervision. The following are the minimum acceptable levels:
• For a non-aquifer site the CQA engineer must inspect the site before
construction and then after the barrier materials have been emplaced prior to
any waste deposit in that area
• For a minor aquifer site, in addition to the requirements for a non-aquifer site,
the CQA engineer must carry out 1 visit per 10,000m³ of barrier material laid
or 1 visit per 2 weeks of engineering works
• For a major aquifer site, in addition to the requirements for a non-aquifer site,
the CQA engineer must carry out 1 visit per 5,000m³ of barrier material laid or
1 visit per week of engineering works.

21 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
 • The CQA engineer must be appropriately qualified and have at least 6 months
experience of earthworks on landfill sites. The CQA engineer must be supervised by
a chartered engineer/geologist with 5 plus years experience.
• Details of the records to be kept and methods of reporting

Further specific requirements for in-situ and artificial geological barriers, record keeping and
reporting are set out below.

In-situ Geological Barriers

Where the operator intends to use in-situ materials as the geological barrier, the suitability of
the material will be identified as part of the site assessment. Sufficient information should be
obtained as part of the site investigation to enable the depth and properties of the in-situ
material to be characterised.

The CQA plan for in-situ geological barriers should include:

• Details of the site investigation data that show the material is suitable for use as a
geological barrier and that it meets any specific design criteria.
• Details of procedures that will allow the CQA engineer to demonstrate that the actual
material is consistent with the site investigation data, and ensure the material meets
the requirements for the site geological barrier. As a minimum, this may be a visual
assessment by the CQA engineer for sand lenses or other discontinuities that may
affect either the permeability or stability of the geological barrier.
• The minimum required depth should be confirmed by the CQA engineer by trial pit /
hole. This frequency should be agreed on a site specific basis.

Artificial Geological Barriers

Where there is no suitable in-situ material the geological barrier will need to be constructed
and placed across the base and sides of the landfill. The materials used for the geological
barrier can either be on-site materials, such as overburden, or imported waste materials that
are selected on the basis of their physical and chemical properties as set out below.

Where on-site materials are to be used, the operator should demonstrate that these materials
are suitable for use as a geological barrier. It is not necessary to demonstrate that these
materials are chemically suitable, however the operator should demonstrate that the material
is physically suitable.

If the operator proposes to use any waste materials in the geological barrier it must be
demonstrated that this material is suitable both physically and chemically as detailed below.

Where the operator proposes to reduce the thickness of the geological barrier to 0.5metres,
this may also require a reduction in the permeability of the geological barrier to provide
equivalent environmental protection. In these cases, the suitability of the material to be used
must be demonstrated by a field trial supervised by the CQA Engineer. The level of
conformance testing will depend on the sensitivity of the site as detailed below.

Material Selection

Physical Properties

Only cohesive materials that are capable of achieving the required permeability when placed
in accordance with the CQA method statement should be used. The flow chart enclosed as
Annex 1 can be used as an empirical guide to determine their physical suitability. Depending
on the sensitivity of the site, further testing may be required to demonstrate that the required
permeability is met.

22 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
Chemical Properties

To ensure the selected waste materials are suitable from a chemical point of view, the
following criteria will be used:

• Any physically suitable waste coded 15 17 05 04 and 20 02 02, listed in the Council
Decision, paragraph 2.1.1 may be used and will not require testing. However, the
waste must be either from a single source, or from a single waste stream of a single
waste type, and there must be no suspicion of contamination or doubt that the waste
meets the definition of inert waste.
• Suitable cohesive wastes that conform to the limit values listed in the Council
decision, paragraph 2.1.2 may be used in the geological barrier at sites in non-aquifer
or minor aquifer strata. This waste will already have been tested as part of the Waste
Acceptance Criteria, and therefore will not require further retesting. This means that
reliance will be placed on the agreed waste acceptance criteria for the site.
• Paragraph 2.1.2 waste will not be classed as suitable for use in the geological barrier
at sites in major aquifer strata unless there has been a specific risk assessment
carried out with regard to List I substances (that is, above the minimum reporting
1
value , or above the limit of determination of the WAC testing)

The CQA plan for the construction of an artificial geological barrier should include:

• Details of how compliance with the construction method will be recorded by site staff
so that the records can be audited by the CQA Engineer or Inspector.
• Details of CQA procedures to ensure that any material used in the geological barrier
is physically and chemically suitable. These procedures should ensure that any waste
materials used in the geological barrier are subject to continual assessment by the
site operator. This is to detect any material that is physically unsuitable and to
observe signs of chemical contamination that may be evidenced by changes in
appearance or odour, or physical contamination by other wastes.
• If the thickness of geological barrier is to be reduced to 0.5m, details of a field trial,
under CQA supervision, to verify the construction method and demonstrate the
thickness and equivalent permeability of the geological barrier.
• The depth of emplaced geological barrier must be demonstrated by either trial pit/
hole or survey. If trial pits / holes are used the number should be agreed on a site
specific basis with a higher frequency in the more sensitive locations.
• On sites in a Major Aquifer, permeability testing will be required at a minimum
frequency of 1 test per cell or 4 tests per hectare whichever is greater. The
permeability testing should be carried out by the CQA Engineer and can either be in
situ (eg falling head, soak-away test as described in Annex 2, or another agreed
methodology) or in the laboratory to BS1377.

Site Records

Records will be maintained at the site of all geological barrier construction activities, and
shall include the following:

• A site diary to be maintained by site staff detailing works carried out, CQA visits, non-
compliances and remedial actions.
• The identity (source, quantity, dates of delivery) of all waste material used in the
geological barrier.
• The results of any chemical testing on geological barrier material.
• Dates and times during which geological barrier construction is undertaken.

15
The List of Waste (England or Wales) Regulations 2005, available at:
http://www.opsi.gov.uk/si/si2005/uksi_20050895_en.pdf

23 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
 • Details of any unsuitable materials including source of material, reasons that it was
considered unsuitable and action taken.
• The progressive construction of the geological barrier will be marked on a plan.
• Thickness of the barrier as placed, either by records of the location and depth of the
trial pits, or isopachyte survey plans.

Validation Report

The validation report highlights the method of construction has resulted in a geological barrier
that meets the requirements of Annex 1 to the Landfill Directive.

Where construction of the geological barrier is on a cell by cell basis a validation report will be
submitted as each cell is completed. Where the geological barrier is being constructed on a
continuous basis a validation report will be prepared by the third party CQA consultant and
submitted every six months. The validation report will include the following:

• Confirmation that the material used in construction the geological barrier was
physically and chemically suitable.
• Confirmation that the construction method and CQA procedures for site staff set out
in the CQA plan were followed.
• The results of any specific post waste acceptance testing on geological barrier
material to demonstrate suitability.
• The results of any conformance testing and field trials on geological barrier material
to demonstrate suitability.
• Dates and times of geological barrier construction.
• Details of any unsuitable materials including source of material, the reasons that it
was considered unsuitable and action taken.
• Site plan showing progressive barrier construction.
• Records of periodic visual inspections by CQA personnel.
• Confirmation and records showing that the specified thickness of geological barrier
has been placed.

24 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
Annex 1
Flowchart for selection of suitable material for the
construction of a geological barrier

Source
material

Does visual
Yes examination
indicate stones
over 125mm

Unsuitable
material
No

Yes Can water be seen

to ooze from the
material?

Unsuitable
material
No

Can the material be

rolled into a sausage
No 3mm thick without
crumbling?

Unsuitable
material Yes

Yes Can a finger be

pushed over 10mm
into a lump of the
material? (ie
minimum shear
strength of 40 kN/m²)
SUITABLENo
MATERIAL
Unsuitable
material

25 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
Annex 2
Example of proposed methods to test acceptable
permeability
1. Scrape a smooth flat surface 50mm below the surface of the layer to be tested

2. Drive a 100mm internal diameter U100 cutter and tube 15mm into the smoothed area of
the geological barrier.

3. Fill the tube to a depth of 50mm with water, record the time and seal the tube to minimise
evaporation.

4. After 24 hours remove the cover and measure the depth of any remaining water. The
level should be recorded along with observations of ground conditions around the ring.

If there is no water remaining the liner is too permeable and additional material may be
required to meet the requirements of the Landfill Directive, Annex 1.

26 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
Appendix A2
Example of substances that could be assessed for waste
to be recovered
Table A
Parameter Symbol

Cadmium (total) Cd
Chromium (total) Cr
Copper (total) Cu
Lead (total) Pb
Nickel (total) Ni
Zinc (total) Zn
Arsenic (total) As
Mercury (total) Hg
Chloride Cl
Cyanide (total) CN
Phenol (Monohydric) Ph
Sulphate SO4
Toluene Extractable Matter TEM
Dissolved Organic Carbon DOC

Table B
Parameter

Total petroleum hydrocarbons TPH

Polycyclic aromatic PAH
hydrocarbons

Table C
Parameter

Benzene, toluene, Ethylbenzene, BTEX

and Xylenes

27 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
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 the
restored landfill does not cause pollution of the environment, harm to
human health or adverse effects on local amenities.

Closed The point at which waste ceases to be accepted for disposal at a landfill

Closure A distinct stage in the regulatory ‘life-cycle’ of a landfill, subject to formal

legal requirements described in Section 2.2. Closure is a process that
occurs after the site is closed, but before it is definitely closed and can
enter the aftercare phase.

Construction This is applicable specifically to construction activities and is an essential

quality tool for the assurance of quality in landfill development. CQA is required to
assurance (CQA) ensure that the objective of producing a high quality, practically flaw free
structure is achieved.

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

Disposal Disposal is defined as any waste management operation serving or

carrying out the final treatment and disposal of waste.

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).

Indirect Regulation 1(3) of the Groundwater Regulations 1998 – the introduction

discharge into groundwater of any substance in List I of II after percolation through
the ground or subsoil.

Inert Waste ‘Inert waste’ means waste that does not undergo any significant physical,
chemical or biological transformations. Inert waste will not dissolve, burn
or otherwise physically or chemically react, biodegrade or adversely affect
other matter with which it comes into contact in a way likely to give rise to
environmental pollution or harm human health

Landfill A landfill is a waste disposal site for deposit of the waste onto or into land
and is defined by the Landfill Directive, article 2.

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.

28 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
 A measure of the rate at which a fluid or gas will pass through a
Permeability 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 EP Regulations 2007: 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 EP Regulations 2007 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.

Recovery A waste recovery operation is one where the principal objective is that the
waste serves a useful purpose in replacing other materials which would
have had to be used for that purpose, thereby conserving natural
resources.

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.

Water Resources Waters that are potentially extractable for industrial, private or public use

29 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
References
Legislation
1 The Environmental Permitting (England and Wales) Regulations 2007 SI 3538. The Stationery
Office, London. http://www.opsi.gov.uk/si/si2007/uksi_20073538_en_1

Government Guidance
2 DEPARTMENT FOR ENVIRONMENT, FOOD & RURAL AFFAIRS: Environmental Permitting:
Environmental Permitting Core Guidance, March 2008
http://www.defra.gov.uk/environment/epp/documents/ep-core-guidance.pdf
3 DEPARTMENT FOR ENVIRONMENT, FOOD & RURAL AFFAIRS: Environmental Permitting:
Environmental Permitting Guidance, The Landfill Directive, March 2008
http://www.defra.gov.uk/environment/epp/documents/landfill-guidance.pdf

Environment Agency Regulatory Guidance

4 ENVIRONMENT AGENCY (2008) Environmental Permitting Regulatory Guidance Series No. LFD1. Understanding
the Landfill Directive for Environmental Permitting. http://www.environment-
agency.gov.uk/static/documents/Business/lfd_1__2005780.pdf

Environment Agency Technical Guidance

Generic guidance
5 ENVIRONMENT AGENCY (2008) Environmental permitting regulations, standards and measures,
getting the basics right - how to comply with your environmental permit, Environment Agency,
Bristol http://publications.environment-agency.gov.uk/pdf/GEHO0209BPHU-e-e.pdf
6 ENVIRONMENT AGENCY (2008) H1 Environmental Risk assessment:
Part 1, Simple assessment of environmental risk for accidents, odour, noise and fugitive
emissions.
Part 2, Assessment of point source releases and cost-benefit analysis. Environment Agency,
Bristol.
HTTP://WWW.ENVIRONMENT-AGENCY.GOV.UK/STATIC/DOCUMENTS/BUSINESS/H1_PART1__2002365.PDF
7 ENVIRONMENT AGENCY (2008) H3 Guidance for Noise. Environment Agency, Bristol.
HTTP://WWW.ENVIRONMENT-
AGENCY.GOV.UK/STATIC/DOCUMENTS/BUSINESS/IPPC_H3_PART_2_1916903.PDF
8 ENVIRONMENT AGENCY (2003) H5 Guidance on the Protection of Land: Application Site Report and Site
Protection and Monitoring Programme. Environment Agency, Bristol.
HTTP://WWW.ENVIRONMENT-
AGENCY.GOV.UK/STATIC/DOCUMENTS/BUSINESS/H5_SCR_GUIDANCE_2099540.PDF
9 ENVIRONMENT AGENCY (2004) M17: Monitoring of Particulate Matter in Ambient Air around Waste
Facilities. Environment Agency, Bristol. http://publications.environment-agency.gov.uk/pdf/GEHO1105BJXU-
e-e.pdf?lang=_e

Guidance on waste acceptance and treatment

10 ENVIRONMENT AGENCY (2005) Guidance for Wastes Destined for Disposal in Landfills.
Environment Agency, Bristol. http://www.environment-
agency.gov.uk/static/documents/Business/faq_v3__oct_07_1899623.pdf

11 ENVIRONMENT AGENCY (2005) Guidance on sampling and testing to meet landfill waste
acceptance procedures. Environment Agency, Bristol. http://www.environment-
agency.gov.uk/static/documents/Business/sampling_and_testing_1069398.pdf

30 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
Water monitoring guidance
12 ENVIRONMENT AGENCY (2003) Guidance on the Monitoring of Landfill Leachate, Groundwater
and Surface Water. Environment Agency, Bristol. http://www.environment-
agency.gov.uk/static/documents/Business/report_1_533191.pdf

Landfill gas guidance

13 ENVIRONMENT AGENCY (2004) Guidance on the management of landfill gas. Environment
Agency, Bristol.
HTTP://WWW.ENVIRONMENT-AGENCY.GOV.UK/STATIC/DOCUMENTS/BUSINESS/LF_TGN_03_888494.PDF

Financial provision guidance

14 ENVIRONMENT AGENCY (2006) Policy: Financial Provision for Landfill, Environment Agency,
Bristol. http://ams.ea.gov/ams_root/06/6_04_waste_management_licensing/20_06.doc

Risk assessment guidance

15 ENVIRONMENT AGENCY (2003) Hydrogeological risk assessments for landfills and the derivation
of groundwater control and trigger levels. Environment Agency, Bristol. http://www.environment-
agency.gov.uk/static/documents/Business/hyrogeological_0403.pdf

31 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land
Would you like to find out more
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or about your environment?

Then call us on
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email
enquiries@environment-
agency.gov.uk

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32 Environment Agency Standards and Measures for the Deposit of Inert Waste on Land