Landfill operators must demonstrate that their operation is in compliance with their EPA licence.
The risk posed by a landfill needs to be evaluated so a licence holder can develop a suitable monitoring program to attest to compliance. Monitoring programs must be endorsed by an environmental auditor and set a frequency for audits.
Small landfills may present a negligible environmental risk. If the site is low risk, then it is likely that the audit frequency set by the auditor will be greater than three years. If the site bears a risk, it is likely the licence holder will need to undertake annual audits to ensure that risks are managed appropriately.
The auditor-endorsed monitoring program and site audits are designed to address long-term non-compliances that may not be readily identifiable. To best manage the long-term risks of landfill sites, the monitoring program should set out an appropriate set of actions to identify and minimise potential risks. This will ensure long-term environmental impacts are identified early and are continually monitored.
EPA appoints environmental auditors pursuant to section 53S of the Environment Protection Act 1970.
The responsibility for compliance with the licence conditions rests with the licence holder. It is a requirement (for landfill licence holders) that third parties are engaged to review compliance. This is done through an auditor verified monitoring program. The monitoring program will specify how frequently environmental audits are to be undertaken to assess the impact, if any, of the landfill upon the receiving environment. The audit findings may translate into a need for additional work, equipment or monitoring to confirm that a site is operating in accordance with the licence.
New landfill cell construction
A licence-holder must not commence construction of a new cell without EPA approval. Please refer to the Landfill licensing guidelines (publication 1323) for a full description of the EPA approval process for new cell design and construction. This includes the construction verification process by an environmental auditor.
Variations during cell construction may arise due to unforeseen events, such as accessibility of certain construction materials, improvement in available technology or unforeseen construction/geotechnical difficulties. Please refer to the Landfill licensing guidelines for full description of the procedure required for obtaining approvals for cell variations during construction.
Landfill Gas Monitoring Guideline
All landfill licences and Post Closure Pollution Abatement Notices require that every practical measure is taken to ensure gas action levels (Table 6.4 of the landfill BPEM) for fugitive emissions of landfill gas are met.
If exceedances are noted during monitoring, you must notify EPA within 24 hours of the exceedance (except where surface emissions exceedances have been rectified within 24 hours). Corrective actions must be taken in line with section 6.7.1 of the landfill BPEM.
To ensure that landfill gas fugitive emissions monitoring is undertaken to the appropriate standard, you will need to follow the methods detailed in the Landfill gas fugitive emissions monitoring guideline (publication 1684).