Develop and maintain management plans

You must manage your operations to prevent or minimise pollution from the activities authorised by your permit.

Your permit requires you to manage and operate your facility by following a written management system. It will help you identify and minimise the risk of pollution from:

  • operations
  • maintenance
  • accidents
  • incidents
  • non-conformances
  • closure

You do not need to send your written management system to the Environment Agency, but they may audit it as part of their compliance assessment.

Your permit also requires you to operate your facility using the methods described in your operating techniques. These are the appropriate measures you will use to manage and operate your facility to prevent or minimise emissions.

Operating techniques may be part of your written management system or separate documents. The Environment Agency normally refers to them as management plans. Once the Environment Agency approves them, they will incorporate these operating techniques into your permit. They are enforceable – they avoid the Environment Agency imposing prescriptive permit conditions.

Operating techniques provide flexibility. Your permit allows you to agree changes to them in writing with your local Environment Agency officer.

For landfills for hazardous or non-hazardous waste you must provide your plans for managing:

Where your risk assessment confirms a need, you must also provide plans for managing:

Your plans must show how you will control the risks from your site. If your risk assessment suggests that the likelihood of an emission is low and you do not need to manage it, you do not need a plan.

Read guidance on management plans for landfills for inert waste.

The Environment Agency accepts that you may include details in one plan or application document that are relevant to another plan. Where you are relying on information presented elsewhere, you can provide a reference to the relevant document.

Manage leachate

You must develop a plan for managing leachate for landfills for hazardous or non-hazardous waste. The plan must show how you will:

  • collect, store and treat leachate at your site
  • monitor the leachate
  • dispose of leachate off site
  • recirculate leachate within the site, where appropriate

You must explain how you will manage leachate from the initial development of the site until the leachate achieves its completion criteria. Read leachate completion criteria in section 16 of landfill for deposit for recover: aftercare and permit surrender.

You must include:

  • site-specific action levels which are below the specified compliance limit
  • an appropriate water balance calculation to predict the volume of leachate produced over time
  • adequate provision for storing and, where applicable, treating leachate to keep levels below the compliance limit, based on your water balance calculations
  • the procedures and responsibilities to install, operate, maintain and monitor the leachate control measures
  • your procedures to inspect, maintain and service each element of the leachate collection, control and discharge system, including supplementary processing and treatment equipment and how you will minimise potential emissions of landfill gas and odour
  • procedures for extreme weather events, for example high rainfall and freezing temperatures
  • how you will account for climate change, for example wetter winters and drier summers
  • your procedures and the infrastructure you will use to recirculate leachate within the site, where appropriate

Where you want to recirculate leachate read manage leachate.

You must set out what you will do when you:

  • have abnormal results in the monitoring data
  • identify operational problems or failures in the leachate control system during routine inspections or the maintenance programme
  • have leaks or spills of leachate

You must periodically review your plan to make sure it is up to date. Your leachate extraction and monitoring infrastructure and procedures must be fit for purpose.

Manage landfill gas

You must develop a plan for managing landfill gas for landfills for hazardous or non-hazardous waste.

Your plan must:

  • bring together all the ways you will manage gas that you considered during your initial risk assessment and proposed operational controls
  • estimate gas production – use probabilistic models such as GasSim to estimate gas production, screen out risks and inform air dispersion modelling of emissions to air
  • set out performance criteria for gas control measures
  • show the design objectives and principles for how you will control gas – show the procedures and responsibilities for operation, maintenance and monitoring
  • demonstrate that your control measures meet the requirements and objectives for managing gas
  • set out the procedures for managing changes and reviewing the performance of the gas control system

Your landfill gas management system must be specific to your site. It must:

  • prevent migration and uncontrolled emissions of landfill gas
  • minimise the impact on local air quality
  • minimise the contribution to climate change
  • control the release of odours
  • minimise the risk of accidents
  • prevent harm to human health

You must describe how you will control landfill gas, including:

  • landfill development – details for containment (lining and capping) and the phasing of landfill development and operation
  • emission standards – based on the outcome of your risk assessment
  • collection system – how you will collect landfill gas from the waste, from initial development of the site through the aftercare phase, including details of the layout of the collection system
  • condensate management – how you will manage condensate from the gas control system
  • inspection, maintenance and servicing – for each element of the gas collection and control system, utilisation and flaring plant and supplementary processing and treatment equipment
  • utilisation, flaring and treatment – how you will manage the collected landfill gas, including methods such as supplementary processing, utilisation, flaring and methane oxidation

Monitor and sample landfill gas

You must have a monitoring and sampling process that includes:

  • a schedule for specific data collection and frequency of monitoring at all stages of operation
  • a drawing showing the construction and location of monitoring points in relation to the site, surrounding area, geology and phasing of operation
  • a description of your measurement techniques and sampling strategy
  • an analysis and testing schedule
  • a method for storing, retrieving and presenting data
  • the background, action and emission limit values against which you will evaluate collected data
  • how you will interpret, review and report the data
  • how you will give the results of your monitoring and data interpretation to the Environment Agency

Your monitoring and sampling process may be part of your landfill gas management plan.

See more information on monitoring and sampling.

The Environment Agency will use your monitoring data to verify compliance with your landfill gas management plan and permit conditions.

Review your landfill gas management plan

You must:

  • periodically review your landfill gas management plan and gas risk assessment
  • where required by your permit, send data showing your annual methane generation rate to your local Environment Agency officer
  • plan for managing landfill gas at low concentrations when commercial gas generation rates drop
  • use the current version of GasSim to set appropriate measures for your gas collection efficiency
  • plan the technology you will use at different stages of your landfill’s gas production, based on the proportion of gas you can successfully collect

The technology you use must:

  • minimise uncontrolled methane emissions
  • efficiently combust recoverable gas

As soon as methane production rates from your site start to fall, you must review your risk assessment. You must decide whether you still need active gas collection or if there is a more appropriate way to manage gas for your site.

You must consider the type and integrity of the capping in any risk-based assessment of passive gas control by bio attenuation.

As gas production rates fall you need to look at other forms of treatment. Read an evidence report on methane oxidation techniques to help you decide on appropriate methods to control emissions when gas production at your site is declining.

Manage accidents and incidents

You must provide a plan for managing accidents and incidents for landfills for hazardous or non-hazardous waste.

Check Environment Agency advice on managing accidents at landfills for inert waste.

Your process must include the potential hazards your landfill may cause. These include:

  • air getting into the waste and the gas extraction and collection system, and causing a fire
  • waste slippage and other stability issues
  • failure of a basal or side wall liner
  • failure of the capping layer (where applicable)
  • incompatible wastes coming into contact
  • release of leachate to an uncontained area
  • overfilling of tanks or lagoons
  • emission of treated leachate before adequately checking its composition
  • vandalism
  • extreme weather conditions, such as flash floods or freezing temperatures blocking leachate, gas and condensate pipes

You must include procedures for each incident scenario and clearly state:

  • the name of the person or position that has overall responsibility for managing the incident
  • who you will notify and contact – for example, regulators and emergency services, including phone numbers and contact names
  • what actions you will take and who will do them
  • how you will liaise with local authority emergency planning units and set up contingency plans for evacuation if you need to evacuate surrounding buildings
  • the monitoring you will carry out
  • reporting parameters – what you must report and who you will report it to
  • completion parameters – what criteria identifies the end of the emergency
  • how you will review your emergency response and the performance of your accident plan

You must train all site based staff on how to implement the response for each incident scenario.

Landfill gas accident and incidents

Your landfill gas management plan must cover how you will manage potential accidents and incidents that might lead to:

  • loss of power supply or failure of the gas extraction, treatment, flare or utilisation plant (where necessary to prevent pollution, you must consider the need for a back-up power supply)
  • migration or other uncontrolled emissions of landfill gas
  • explosion or fire within the gas extraction, treatment, flare or utilisation plant
  • an impact on local air quality
  • release of odours
  • harm to human health

You must identify failure scenarios for each component of your gas management system. You must assign appropriate actions for elements of the gas control system at specific locations.

Your gas plan must explain what you will do when you:

  • have abnormal results in the monitoring data
  • identify operational problems or failure of the gas control system during routine inspections or maintenance
  • have a reported event, for example a complaint

In an emergency, you must notify the Environment Agency immediately – call the incident hotline on 0800 80 70 60. You may also need to notify other appropriate authorities, such as the local authority or the Health and Safety Executive.

Where you need to take remedial action, you must include an appropriate remediation timescale in your accident and incident plan. For example, start enhanced monitoring protocols within 24 hours or incorporate additional collection wells within 7 days (in the case of sacrificial pin wells).

Manage other emissions

The Environment Agency will normally impose compliance limits in your permit to control emissions:

  • to groundwater
  • of landfill gas
  • to surface water

If your activities are producing emissions of substances that are not controlled by emission limits in your permit, you must create an emissions plan. Your permit will normally state that where it does not specify a limit, you must control emissions below background concentrations.

Manage fire

You must provide a plan for managing the risk of fire for all landfills for non-hazardous waste.

To minimise the risk of fires, you must:

  • keep your site secure to prevent unauthorised access to the operational areas
  • place, compact and cover waste promptly and in well-defined cells
  • cap completed areas promptly
  • prevent air getting into the waste and gas extraction and collection systems
  • monitor for signs of fires or potential fires

You must not accept hot or reactive waste. Your waste acceptance procedures must detail how you will do this.

You must develop a fire plan to minimise the risk of fires and explain how you will deal with:

  • surface and sub-surface fires
  • fires at other locations around the site

Your plan must identify the techniques you will use to control and extinguish fires. You must identify any sources of water you will use.

You must:

  • extinguish fires as soon as possible
  • notify the Environment Agency within 24 hours if you discover a fire – call the incident hotline on 0800 80 70 60

Manage surface and groundwater

Where your risk assessment confirms a need, you must provide a plan for managing surface water for all landfill sites. You must prevent surface water from areas outside the landfill entering the waste. You must channel this water away from all construction works or operational and post-closure phases.

Your plan must set out how you will manage rainwater, surface water and groundwater. These may be separate documents. You must base your plan on a site-specific risk assessment. Where it’s needed, you must send your water plan to the Environment Agency with your application.

Your water plan must consider the local weather, hydrology and hydrogeology.

Your surface water plan must be part of your engineering design and site restoration plan.

Where your risk assessment confirms that you will need to abstract groundwater, for example to construct basal and sidewall engineering, you may need to drain this to surface water.

Where you need to maintain groundwater levels below natural levels in the long term, you will need an abstraction licence.

You must design your surface water management systems to achieve recognised industry best practice. See the industry code of practice for guidance on the design of surface water management systems.

You must, where applicable:

  • carry out water balance calculations based on accurate data for the site location – you must account for seasonal variations and likely changes in rainfall pattern caused by climate change
  • treat rainwater that has not come into contact with the waste to remove suspended solids before you use or discharge it
  • install a temporary cap on non-operational areas and install a permanent cap and restore completed areas (including flanks) as soon as practicable
  • confirm how you will collect and remove surface water from capped areas
  • design your surface water drains on the landfill to accommodate settlement
  • design your surface water drainage system to cope with predictable storm events
  • design your surface water storage system to provide sufficient capacity

You must, where applicable, design your groundwater management system to:

  • control groundwater and prevent it entering the landfill
  • prevent the direct discharge of hazardous substances to groundwater
  • accommodate calculated flows
  • avoid clogging drainage layers
  • accommodate discrete spring flows
  • accommodate anticipated settlement and overburden
  • allow CCTV inspection, jetting and maintenance

Surface water discharges

Where you carry out a water discharge activity at your landfill, you must assess the risk from that discharge. Your permit application must include the volume of water you intend to discharge and whether it will contain hazardous chemicals or elements.

The Environment Agency will include limits on the quality of the discharge in your permit.

Protect habitats

Where your risk assessment confirms a need, you must describe how you will prevent your activity having an impact on habitat sites. You can refer to other plans where they include measures to prevent impacts on habitat sites, such as your dust or surface water plans.

Manage odour

At landfills for non-hazardous waste, or where your risk assessment confirms a need at a landfill for hazardous waste, you must provide a plan for managing odour emissions. Odour is a common cause of complaints for biodegradable waste landfills.

Odour is often caused by:

  • trace components escaping from landfill gas, for example hydrogen sulphide or free fatty acids
  • odorous waste
  • putting biodegradable waste in an unsuitable place or using unsuitable covering

You must keep a record of specific odorous waste you accept in your landfill. This must include:

  • how the waste was treated before landfill to limit odours
  • the distinction between odorous waste that will have an immediate impact, and waste that may cause odour complaints because of aerobic or anaerobic conditions within the landfill

You must regularly review your odour risk assessment. Your assessment must include the effect of odour on receptors and the different mitigation options.

Your assessment must include:

  • point sources, such as flares
  • linear or area sources, such as tipping faces and cracks in the cap
  • temporary situations, such as gas well installation or gas control maintenance and downtime

You must:

  • only dispose of gypsum-based waste and other high sulphate bearing materials (such as plasterboard or contaminated trommel fines) in sites or cells where no biodegradable waste is accepted
  • only tip odorous waste in specific areas
  • define the weather conditions that indicate that odorous waste may lead to complaints
  • assess the potential for odours when you excavate waste or remove covers or temporary caps, for example when you install gas wells
  • keep tipping areas as small as possible
  • cover waste promptly
  • cap the waste with a temporary or permanent cap as soon as possible
  • make sure landfill gas control systems are well constructed, operated and maintained
  • consider point source emissions when you select and assess the control systems, such as emissions from landfill gas flares
  • install active landfill gas extraction as soon as possible to minimise uncontrolled emissions of landfill gas
  • use enclosed leachate storage and treatment if there is a risk of odours
  • seal leachate sumps, wells and side wall risers, while keeping access for monitoring and maintenance

If you cannot reduce odour to an acceptable level, the Environment Agency may stop you taking strongly odorous waste, or waste that may result in unacceptable odours at your site.

Your odour plan must include procedures to manage:

  • waste inputs
  • waste disturbed by digging or drilling
  • odorous waste
  • leachate and leachate treatment systems
  • landfill gas

You must implement an effective landfill gas management plan.

Check the odour management guidance to find out how to comply with your environmental permit.

Other plans

You must develop other plans to manage emissions from your site if your risk assessments confirm that you need them. You must submit these to the Environment Agency with your permit application.

Manage litter

You must provide a plan to prevent litter escaping from landfills for hazardous or non-hazardous waste. Litter is any wind-blown material except particulate matter, such as dust.

To manage litter you must:

  • keep incoming waste covered or contained before it is deposited
  • where necessary, have an emergency tipping area to allow lightweight waste to be discharged in a secure enclosure during windy weather
  • compact waste when it is deposited
  • cover waste after it is deposited
  • minimise the size of the active tipping area
  • have adequate plant for depositing, compacting and covering waste
  • have an adequate supply of daily and intermediate cover material
  • carry out daily meteorological monitoring
  • make sure vehicles fully discharge at the tip face to prevent any waste staying in the vehicle and being released later
  • consider closing the site to specific or all waste types during windy weather

To prevent litter accumulating within or escaping from your site, you must:

  • assess the risk of the prevailing wind direction and strength, and the proximity of receptors when you design the filling development and sequence
  • install permanent and mobile litter fences around the active tipping area
  • consider installing temporary bunds immediately next to the tipping area
  • carry out regular inspections and collect litter around the site boundary and beyond – specifically ditches, haul roads and water courses
  • employ extra temporary staff to collect litter, if inspections and monitoring show this is needed

Manage mud

You must provide a plan to prevent mud escaping for all landfill sites. You must prevent vehicles carrying mud off your site.

Methods to prevent mud escaping include:

  • effective wheel and body cleaners to remove mud and debris from vehicles before they leave
  • regular maintenance of wheel wash equipment, for example water changes for wet systems
  • adequate supervision of wheel washing to make sure the equipment is used correctly
  • keeping main site roads free of mud
  • having a sufficient distance of surfaced site roads between haul roads and wheel wash facilities

You must monitor the public highway and your site road between the final wheel wash and the public highway.

If you regularly deposit mud on the public highway this is an unauthorised deposit of waste.

Manage dust

You must provide a plan to prevent dust escaping if your risk assessment confirms you need one. Particulate matter (such as dust) may be caused by:

  • depositing waste
  • traffic on site roads during dry weather
  • site preparation and restoration activities
  • wind-blown surface emissions
  • carriage of dust off site on vehicles

You must:

  • keep unrestored areas to a minimum – you must cap cells or phases as soon as possible after the end of waste disposal
  • extend surfaced site roads as far as possible to the tipping face and keep them available for as long as possible
  • maintain surfaced site roads and keep them clean
  • control site traffic, including restrictions on routes and speeds
  • put wheel washers far enough from the site entrance to allow any residual debris to be deposited within the site
  • suppress dust using bowsers and water – you may only use leachate to suppress dust if you follow an approved management plan

Your dust plan must consider:

  • how long particles may remain airborne
  • how far particles may travel
  • deposition rates
  • human health impacts

Your dust plan must consider how you can reduce the emission of fine particles that are biologically active. Biological aerosols (also called bio-aerosols) may consist of biological organisms suspended in air. These aerosols can affect organisms by infection, allergy, toxicity, pharmacological and other processes. Degrading waste is most likely to form bio-aerosols when it is disturbed.

Where your risk assessment suggests that dust may cause pollution, you must develop a particulate matter monitoring programme for the particulate matter you are likely to create. Where hazardous substances are likely, you must develop environmental assessment levels.

Check how to control and monitor emissions of dust, mud and litter.

You must review your monitoring programme to determine the appropriate frequencies and parameters for your site.

Managing dust at landfills for hazardous waste

Hazardous fine-grained materials may become wind-blown dust.

You must carry out a risk assessment on covering and wetting. This must take account of the specific waste types and receptors. You must consider alternative treatment to reduce the risk of dust.

Asbestos fibres are dangerous for humans. When you accept asbestos, you must monitor for asbestos fibres up and downwind of the asbestos cell during and after deposit. Your permit will specify compliance limits for asbestos fibres next to asbestos cells and at the permit boundary. Check how to monitor and report your performance to meet your permit conditions.

Manage pests

You must provide a plan for managing pests for all landfill sites where your risk assessment confirms you need one. To manage pests you must:

  • manage your site effectively – promptly deposit, compact and cover waste in well-defined cells, and install a temporary cap on completed areas
  • not leave previously covered waste exposed
  • arrange regular visits by pest control contractors or fully trained staff
  • inspect and treat areas where rats live, for example sewers, culverts and drains

You must have procedures to prevent or limit the acceptance of fly-infested waste. You must bury waste promptly and cover it with appropriate material to reduce the risk of infestation. You must also consider fly infestation where you need to excavate waste as part of engineering works.

Manage birds

You must provide a plan for managing birds for all landfill sites where your risk assessment confirms you need one. You must have procedures in place to minimise the impact of scavenging and roosting birds.

You must consider:

  • deposits of excrement and scraps of food on mobile plant and vehicles on-site that might reduce driver visibility and damage nearby property
  • bird-strike damage to aircraft
  • pathogens being introduced to nearby water bodies, crops and animals
  • alien species being introduced to sensitive local habitats

If your site is near a safeguarded aerodrome or military airfield you must provide a plan that describes how you will prevent birds from accumulating at your site. If you have already provided this information to the local planning authority the Environment Agency will accept the same information.

To control birds, you must adopt good landfill practice. You may also need to use bird scaring techniques. These include:

  • flying birds of prey over the site
  • bird kites to mimic birds of prey
  • shell crackers containing flares and bangers
  • rope bangers
  • gas cannons
  • scarecrows – fixed or mobile
  • amplified recordings of species-specific bird distress calls
  • electronic sounds imitating calls of distress
  • bird corpses or dummies

You must maintain a record of the techniques you use to comply with your permit as part of your performance monitoring system.

Manage noise

You must do a noise impact assessment for your landfill site if your risk assessment confirms you need one. Use your assessment to help you write a plan to describe how you will prevent or minimise noise emissions.

You must design and maintain landfill gas engine and flare compounds to minimise noise emissions.

Landfill cover

You must provide a plan for covering your deposited wastes for landfills for non-hazardous waste. You must provide a plan for landfills for hazardous wastes where you accept waste that may be windblown, for example litter or asbestos fibres.

Your plan must confirm how you will cover the waste to manage environmental risks during the lifetime of your site. You may include cover management in other documents, for example your dust or amenity plan.

Landfill cover must:

  • prevent wind-blown litter or dust
  • prevent odours causing a nuisance off site
  • deter scavenging birds from the site or the air above it
  • deter scavenging animals
  • prevent pests from being attracted to or infesting the site
  • prevent flies from infesting the site
  • minimise the risk of fire at the site
  • make sure the visual appearance of the site is not seriously detrimental to the locality

Landfill cover: reuse

You can reuse cover material if the objectives of cover are met.

Where you reuse cover material, your plan must show how you will do this without damaging it.

You may be able to use some sheet materials several times before they are damaged or contaminated.

Landfill cover: availability

You must:

  • provide evidence that the cover material you plan to use is available
  • provide details of where you will stockpile cover material on your site
  • specify the type and source of material you plan to use when your preferred material is not available
  • specify the expected delivery time from the supplier and the trigger level of stored material so you can place a further order

Landfill cover: suitability

You must review the suitability of cover material based on:

  • permeability – remove any low permeability materials you have used for landfill cover before you apply the next layer of waste
  • combustibility – include details of risks associated with storing and using any cover material that can easily catch fire
  • dust – assess cover materials in the condition you will use them on site and show how you will contain any dust
  • chemical contamination – include details of how you will make sure the cover materials will not include levels of contamination that could cause pollution
  • ease of applying – include details of the methods you will use to apply and remove the cover materials
  • pests, flies and odour – assess if the material will minimise pests, flies and odour

You must make sure the cover materials are suitable for vehicle traction. Consider how:

  • vehicles will access the tipping area and working face
  • you will make sure vehicles do not damage the integrity of the cover

Your cover plan must specify each cover material you intend to use. You must include the properties of the cover material and what you will do to make sure it does not pollute the environment or harm human health.