Waste Licence: W0011-02

Ballymurtagh Landfill closed for waste acceptance in 2002. The capping of the landfill was complete in 2006. It is located on a previously used open cast copper mines. Today, the landfill is on aftercare and a small recycling centre operates adjacent to the landfill

There have been no complaints arising from the activities at Ballymurtagh for over 20 years.

Groundwater Pollutants Identified:
Copper, Lead, Nickel, Sulphate & Ammonia.

The landfill is located in the area of the old Avoca Mines. Groundwater in the entire area shows excessively high levels of metals, which are detected in the quarterly analysis. At one location, Ammonia from the landfill leachate discharge is also detected. This level has been demonstrated to be decreasing over time.

EPA agreed financial provision is in place. CRAMP & ELRA last agreed by the Agency in 2017

The annual slope stability assessment was last undertaken in 2016. The most recent slope stability assessment report submitted to the Agency was on 03/12/2013 (ref. LR006371). This is a Non- Compliance with Condition 6.17.

The topographical survey for 2021 was not undertaken at the site. This is a Non-Compliance with Condition 6.18. It is noted that a topographical survey for 2022 has been partially undertaken at the site in 2022 in response to the landfill cap breach (ref. INCI022640).

Actions Required:

Comply with Conditions 6.17 & 6.18. With regard to the 2016 slope stability assessment, the Licensee shalloutline how and when the recommendations outlined in the report were implemented.

The Licensee shall ensure all future slope stability assessments shall investigate the slope integrity at bothsurface and subsurface levels.

The landfill gas collection infrastructure has not been maintained and is not fit for purpose – pipelines have sagged and become blocked with condensate and/or disconnected from the flare. This has resulted in a 50% loss of the landfill gas collection network, low volumes of landfill gas reaching the flare, higher volumes of oxygen being drawn into the gas field and difficulties in balancing the gas field and maintaining the run- time of the flare.

This is a Non-Compliance with Condition 3.6

On occasion the flare has been used to drain the pipework of leachate, which poses a risk of over-drawing the gas field and pulling oxygen into the gas collection network.

There are two functioning leachate wells at the site – Condition 6.15.2 requires five wells to be maintained at the site.

This is a Non-Compliance with Conditions 6.15.1 & 6.15.2.

The landfill gas collection system was disconnected from the enclosed landfill gas flare and connected to a low calorific high temperature open flare in 2020.

This was done in the absence of assessing the performance of the landfill gas collection network, and despite the Licensee being aware of issues in the network.

The Licensee failed to submit a Specified Engineering Works (SEW) proposal and obtain the written approval of the Agency prior to undertaking these works. This is a Non-Compliance with Conditions 1.4 and 3.3.1.

While the low calorific high temperature flare is being operated at temperatures around 1,020oC, the Licensee could not confirm the burn chamber residence time during the site visit, to demonstrate compliance with Condition 6.16.3.

The Licensee has undertaken one landfill cap performance assessment report since the licence was granted. The Licensee is required to undertake a landfill cap performance assessment once every three years and report to the Agency on each occasion. The Licensee has not submitted this report to the Agency in three years prior to 31/12/2021.

This is a Non-Compliance with Condition 6.20.

Monitoring of leachate levels is required to be undertaken monthly. Licensee return LR065199 shows the Licensee is undertaking this monitoring on a quarterly basis.

This is a Non-Compliance with Condition 6.1 & Schedule C.3.

Landfill gas balancing records are maintained on a monthly basis. However additional balancing undertaken more frequently at a smaller number of wells is not recorded.

The quality of balancing records does not allow for the interrogation of actions taken during the balancing exercise i.e. the balancing sheets do not record the:

• Existing state of the valve at the wellhead (for example, closed, 10% open, 100% open);
• Changes made to the valve during the balancing event;
• Gas concentrations prior to making changes and after making changes (if applicable);
• Any observations made during the balancing exercise, such as infrastructure repairs needed, condensate draining needed/undertaken, issues/odours noted/addressed

While it is noted the site is visited daily by Council staff, the flare is not connected to an out of hours call out/alarm system.

This is a Non-Compliance with Condition 6.1 & Schedule C.1.1.

The annual VOC monitoring was not undertaken at the landfill in 2021.

Surface water drainage and infrastructure used to divert surface water away from the landfill waste body has not been maintained – these include the:

• Surface water drains and swales (which were not sufficient to divert surface water away from the cap, evident by the cap being wet underfoot, rushes growing and swales had long grass growing in them);
• Landfill cap depressions (allowing ponding of water on the cap); and
• Surface water retention pond (which was overgrown and inaccessible, and fencing around the pond was damaged).

The failure to maintain surface profiles, water collection drainage infrastructure and the storm water retention pond at the site is a Non-Compliance with Conditions 3.17 & 10.4.1.

The failure to demonstrate the integrity of the surface water retention pond is in Non-Compliance with Condition 6.9.

T.E. Labs monitor surface water, groundwater and leachate.

In compliance with Condition 6 of Waste Licence W0011-02, Wicklow County Council is required to carry out environmental monitoring at Ballymurtagh Landfill at such locations and frequencies as set out in Schedule C: Control & Monitoring of the licence.

Schedule C.5 details the requirements for the monitoring of receiving water, Schedule C.4 details the requirements of groundwater monitoring and C.3 the leachate monitoring.

Quarterly reports are submitted in line with the requirements set out in the licence.

Groundwater in the immediate area of the landfill and beyond is heavily polluted from the workings associated with Avoca mines. Specifically, extremely high levels of metals and resulting conductivity are observed along with low pH.

The groundwater-monitoring programme includes monitoring wells:
 Twin Shafts
 G1/04
 G1/05
 G2/05
 RC6
 SW3 (Ballymurtagh Road Adit)
and at five private wells.

Current landfill gas collection infrastructure on the facility

There is a total of 42 vertical wells and 2 pumped condensate knock out pots on the facility. Horizontal and Vertical landfill gas abstraction is employed in the facility. There is one operational installed landfill gas enclosed flare (500 m3/hr).

Leachate Monitoring:

TelLab undertake leachate monitoring on a quarterly basis. Leachate analysis is undertaken at all wells that are not dry.