Inspections cover Bawnard Landfill and associated discharge locations, general site conditions, lagoon liner and perimeter fencing
Historic plant for Tanning and Fellmongering, plus related landfill
John Ronan & Sons group operated a small landfill (c.1ha) which is located c.4km east of the factory site. This site which is included in the IPC application is leased from a farmer. The only wastes accepted, aside from restoration and road maintenance inert fill, were from the tannery. Some 3000t tonnes per annum were placed in the site. This comprises c.2000t solid waste (trimmings, sweepings, waste wool, hooves, horns, and similar), and c.1000t sludge from the waste water treatment plant.
The licence transfer request (Ref. LT00196) for the licence to be transferred to Crag Arklow Limited was accepted by the EPA on the 4th August 2021.
Surface water emission point previously at site (EFF1) is no longer operational. There were no aqueous discharges to the Avoca River in 2021. Biannual-monitoring of onsite surface water monitoring points continued
A Quantitative Risk Assessment and Natural Monitored Attenuation Programme for the site was submitted and accepted by the EPA in 2012. This includes biannual monitoring completed on stormwater, groundwater and leachate to confirm the natural attenuation of the legacy pollutant plumes at the site.
The licensee changed its name in 2017 from Holfeld Plastics Ltd. to Avoca River Park Ltd.
The site is a closed landfill site with an operational bring centre
Tank 1 is a covered lagoon area that stores collected surface water runoff from the main site yard and green waste processing area. Tank 2 is an above ground storage tank containing a combination of leachate collected from the main landfill body via the leachate collection and pumping system and overflow water from Tank 1.
All water within Tank 1 is transferred to Tank 2 before being transported off site for treatment at the Clare Co. Co. Wastewater Treatment Plant
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.
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).
The 1996 Waste Management Act provided for local authorities to identify sites within their jurisdictions at which waste disposal or recovery activities had been carried on, to assess any risk of environmental pollution and to identify remedial measures.
As well as municipal landfills, this included unregulated waste disposal sites. However, this requirement was generally not actioned as there was no national standard for the local authorities to follow in assessing risk and in identifying the necessary remediation works. That deficit was addressed in 2007 with the publication by the EPA of a code of practice for environmental risk assessment of unregulated waste disposal sites.
The legal obligations on local authorities for landfills were expanded in 2008.1 In addition to having to register sites they themselves had operated in the period between July 1977 and March 1997 (at which time the EPA became responsible for licensing and regulating landfill operations) and to carry out an environmental risk assessment, local authorities now had to make applications to the EPA for approval and authorisation of any proposed remediation works.
At July 2020, the total number of identified landfill sites was 611.
This included 117 sites licensed and regulated by the EPA since March 1997, and which it continues to monitor — consisting of 64 sites operated by local authorities and 53 operated privately.
494 unregulated sites registered by local authorities on a web-based register established by the EPA.
Over 70% of the sites are former local authority-operated landfills.
Around 21% were privately operated sites, while just over 8% were illegal dump sites.
Landfill sites on the Section 22 register, as at 31 December 2019
Assessment
The environmental risk assessment of the sites on the Section 22 register involves three progressive stages.
Tier 1 assessment — development of a conceptual site model and risk assessment — this allows for the categorisation of sites into low, moderate and high risk. Tier 2 assessment — more detailed site investigations and testing. Tier 3 assessment — refinement of the conceptual site model and completion of a quantitative risk assessment for all moderate and high risk sites.
On completion of the three-tier risk assessment process, local authorities are required to prepare remediation plans to address the risks identified for a site.
Quantity of waste at facility: Approximately 147,784 tonnes. 106,000 m3
Killycronaghan historic landfill is not owned by Monaghan County Council (landowner is a local farmer)
The site is located almost 7km north-east of Clones on privately owned land and covers an area of 9ha.
The site is surrounded by agricultural lands and is bounded by the Kilgormly river to the south-east, east and north, and by the Magheramey river to the north-west.
There are poultry houses adjacent to the north-east of the site and three dwellings within 500m of the site boundary, the nearest of which is located 230m from the north-eastern boundary.
The landfill was operational from 1970 to circa 1984 and comprises of approximately 147,784 tonnes of municipal solid waste (MSW).
An appropriate assessment of the activity was carried out as it was determined that there is a hydrological connection between the closed landfill and one SPA site and two SAC sites, the nearest of which is located 16.2km south-west of the closed landfill.
Post remedial works, Monaghan County Council intend to use the site for low intensity grazing.
The risk assessment has categorised the site as High risk (Class A) with high scoring pollutant linkages identified as: – Leachate migration into groundwater, and, via groundwater, to surface waterbodies; – Migration of leachate, via groundwater, to Surface Water Body Protected Areas; – Migration of leachate, via surface water drainage/runoff, to surface water bodies; – Human health exposure pathway of off-site lateral migration of landfill gas into nearby buildings; and – Vertical landfill gas migration.
The Technical Commitee notes that the Tier 1 and Tier 2 assessment determined the overall risk score for the closed landfill as high due partly to the risk of migration of landfill gas into the adjacent buildings i.e. the poultry houses, located to the north east, and the farm buildings, situated to the east of the site. The TC further notes that modelling showed that landfill gas will continue to be generated for several years although in minimal quantities. As landfill gas monitoring is carried out in the existing groundwater monitoring boreholes, the TC considers it prudent that monitoring is carried out in the additional boreholes to be installed for groundwater monitoring as required under condition 3.1(i).
The TC notes the high-risk classification of the site is partially due to the risk to the groundwater aquifer from the migration of leachate from the waste body. The TC also notes that the site investigations determined that the groundwater table likely transects the waste body and that groundwater monitoring results show that leachate is having a deleterious effect on groundwater quality.
The site investigations carried out as part of Tier 1, 2 and 3 assessments established the following facts: – the closed landfill has been capped with soil but the cap allows rainfall to infiltrate into the waste body; – the landfill is unlined; – there is migration of landfill leachate into groundwater; – the landfill is contributing to a deterioration in groundwater quality; – the waste material is deposited in a single infill area tending west to east in the centre of the site and between approximately 150m in length and 130m in width; – the average thickness of the waste body is 5m and there is a layer of leachate contaminated sands and gravels below waste; – the groundwater table appears to be intersecting the waste body; – leachate seepage was observed near the centre of the site; – landfill gas is being generated; – there are two wells present on-site. The Council believes these to be old methane wells;
