With limited resources, owners and operators of small municipal solid waste landfills (MSWLFs) often face challenges balancing operational costs with compliance needs. The numerous compliance requirements can be difficult to track and monitor, and it can be easy for day-to-day tasks to fall through the cracks. To avoid regulatory penalties and enhance operational excellence, it’s beneficial to evaluate your permit compliance regularly during the landfill operational phase.
Top 5 compliance areas for MSWLFs to check up on
As defined by the Land Disposal Program Flexibility Act of 1996 (LDPFA)
, small MSWLFs are those that receive fewer than 20 tons of municipal solid waste per day. Small landfills are regulated by EPA and owners and operators should routinely evaluate compliance in several key areas. Check to see if your program has the below components in place.
1. Stormwater management
- Prevent surface run-on (non-contact stormwater) from contacting waste and becoming leachate by diverting stormwater away from the landfill cell or disposal unit.
- Prevent runoff which has contacted waste (contact stormwater) from leaving the landfill cell or unit.
- Verify contact and non-contact stormwater is conveyed to applicable stormwater or leachate management facilities.
- Ensure landfill operations are not compromised by poor surface drainage.
- Minimize leachate generation through preventing surface water from entering the waste mass by maintaining positive drainage in active areas of the landfill (to the extent practicable).
- Avoid surface water contamination from contact stormwater or leachate breakouts by installing appropriate drainage controls.
- Minimize soil loss and erosion from borrow sources and completed landfill areas by implementing best management practices (BMP) called for in your Storm Water Pollution Prevention Plan (SWPPP).
- Install BMPs to control sediment discharge and surface water contamination.
- Provide water storage for site use.
- Clean and maintain stormwater ditches and ponds.
2. Working face
- Keep working face as small as safely possible to limit the amount of blowing litter and the amount of daily cover that must be placed.
- Ensure orderly truck movement and unloading.
- When practical, manage multiple waste streams within the same working face.
- Employ effective waste placement and compaction:
- Compacted waste provides stable surface, prevents litter escape, inhibits odor release, reduces fire risk, displaces air, increases the rate of onset of anaerobic conditions, aids stormwater runoff, provides good base for applying cover soil, and consumes less air space.
- Maintain a sloped working face to minimize stormwater infiltration into waste and becoming leachate.
3. Daily and intermediate cover
- Daily cover
- Apply six inches of soil or approved alternative daily cover (ADC) daily. This minimizes erosion, controls odors, prevents scavenging, reduces fire risk, improves appearance, and minimizes contamination runoff.
- Remember, waste will still be visible when six inches of daily cover is applied.If you don’t see waste after applying daily cover, you are likely applying too much daily cover.
- Intermediate cover
- Remember intermediate cover is required on areas where waste has not been placed within 30 days.
- Keep in mind that construction and demolition (C&D) landfills must cover waste on a monthly basis.
- Stormwater that contacts intermediate cover can be managed as non-contact stormwater.
4. Erosion control
- Inspect your cover for erosion and implement necessary maintenance activities.
- Protect and stabilize the side slopes to reduce erosion and sediment deposited at the toe of slopes.You can do this by conducting temporary seeding; constructing diversion berms; tracking side slopes; or applying erosion control blanketing.
- Make use of temporary containment berms to divert stormwater run-on (non-contact stormwater) from the waste disposal area.
5. Litter control
- Assess your current methods for controlling litter. You can manage litter in several ways, including enforcing tarped loads, waste handling practices, portable litter screens, litter fencing, select tipping areas, daily cover, and by restricting operating hours in periods of high winds.
- Collect litter at regularly scheduled intervals or after periods of high winds. Increase the frequency of daily cover applications.
While there are multiple compliance areas to be aware of, confirming your operations account for the above factors will go a long way toward maintaining compliant operations.
Compliance flexibility for “approved states”
The EPA provides compliance flexibility for MSWLFs in “approved states.” For example, Colorado is an approved state, while Wyoming is not. The additional flexibility includes alternative frequencies for daily cover; frequencies of methane monitoring; infiltration layers for final cover; and means for demonstrating financial assurance. These flexibilities allow owners and operators in these states the opportunity to reduce their operational costs while still protecting human health and the environment.
Need assistance reviewing your permit compliance?
If you're experiencing issues and are unsure how to implement the necessary corrective actions, Trihydro can assist. Every landfill has unique permit conditions and our team has experience evaluating and designing compliance programs to meet custom needs. We can review permits for possible amendments and identify ways to streamline your compliance efforts.
Solid Waste Engineer