1. Critical parameters, frequency, cost-efficiency: implementation of Annex II Heijo Scharff FEAD Workshop Implementation of the Landfill Directive Budapest, Hungary, 11 May 2007

2. Contents n Transposition into national regulations n Aspects to solve: Dutch considerations and solutions n Conclusions and recommendations

3. Transposition n Member states have to comply with European regulations. n Translation of the Council Decision into your national language does not result in effective implementation. n Why not?

4. Transposition n It is a very complicated piece of regulation. n It leaves a lot of room for interpretation. n It is insufficiently detailed and specified to result in national regulations that are verifiable, workable or enforceable. n Decisions have to be made at national level in order to obtain enforceable regulation.

5. Dutch considerations Landfill Drinking water well n Waste testing is a reality: it has to be implemented. n Important: goal is to protect soil and groundwater, NOT to know everything of every batch of waste landfilled. n Chosen for the most simple and pragmatic interpretation. n As close as possible to the existing acceptance procedures. n Under development!

6. Testing or not testing? Non-hazardous waste Hazardous waste Landfill for non-hazardous waste Landfill for hazardous waste No Only DOC Yes n Dutch estimate: maximum 15% of wastes will be tested.

7. Cost efficiency n Types of waste that require testing are limited. n Only granular wastes: 80% >40 mm → no test method. n Exclude wastes for which information is available. n Positive list of stable, non- reactive hazardous wastes.

8. Cost efficiency n Limit the number of samples: n Only analyse compiled samples. n Entire batch tested at production site: no compliance test necessary. n Clustering of comparable wastes.

9. Basic characterisation n One basic characterisation suffices, also for more landfills. n 50 (sub)samples compiled into 1 sample for testing = good. n No distinction between waste regularly generated and waste not regularly generated → less mistakes. n Testing is carried out at the size of the batch of waste. n Analysis of all parameters for which limit values exist.

10. Evaluation n Comparison of test results with leaching limit values. n If parameters comply: landfill is allowed. n Additional information required: first 4 compliance tests. n Final decision is based on the average of 5 tests: if all averages comply with all limit values, then the waste can be landfilled.

11. Identification of critical parameters n Chance of exceeding limit value is > 5%: critical parameter. n Critical parameters have to be analysed in the compliance test. n If the compliance tests indicate the parameter is no longer critical, the necessity to analyse stops. n The regular compliance tests (1 out of 10 loads) can however result in new critical parameters.

12. Compliance testing: frequency % of units that exceed Sampling frequency Number of loads to be evaluated together < 5%No testingn.a. 5% < x < 10%1 of 10 loads100 10% < x < 30%1 of 6 loads60 30% < x < 50%1 of 2 loads20 > 50%Every load10

13. Compliance testing: sampling n Sampling procedures have to be simple! n The basis for sampling is a truckload: 5 samples per load. n A compiled sample consists of 50 samples = 10 loads. n Which 10 loads depends on the critical parameter frequency and on the size of the contract.

14. Compliance testing: sampling n First four truckloads after basic characterisation. n Next sample: depends on the critical parameter frequency. n Landfill operator records selection method and selected loads. n Maximum is every truck load and minimum is every tenth truck load or 50 samples every 4,000 tonnes.

15. Compliance testing: analysis n At least one compliance test per type of waste per year. n Clustering → several contracts. n After 10 sampled truck loads or 365 days after the first sample a compiled sample is sent to the laboratory.

16. Compliance testing: clustering n Comparable wastes may be clustered by the landfill operator. n This is judged on nature, origin and basic characterisation. n Same critical parameters based on basic characterisation. n Limits the number and costs of compliance tests. n Practical advantage because of uniform procedures on the landfill: less mistakes.

17. Compliance testing: evaluation n Test results become available after disposal of 10 to 100 loads. n Some disposal of non-compliant batches: inherent to the system. n This is acceptable on the bulk of the waste in the landfill. n Therefore: no immediate action with occasional non-compliance. n Only increase the sample frequency. n When average of last 5 tests exceeds limits: do not landfill.

18. Conclusions and recommendations n If your government has only translated WAC: problem. n Look for solutions close to everyday landfill practice. n Avoid too detailed or stringent regulations: a harmless mistake is (on paper!) immediately an environmental crime. n Avoid most comprehensive testing of everything: too expensive. n We do need more knowledge, so we have to start testing.

19. Thank you very much for your attention