ANNEX

CRITERIA AND PROCEDURES FOR THE ACCEPTANCE OF WASTE AT LANDFILLS
Appendix A

SAFETY ASSESSMENT FOR ACCEPTANCE OF WASTE IN UNDERGROUND STORAGE
1.

SAFETY PHILOSOPHY FOR UNDERGROUND STORAGE: ALL TYPES
1.1.

The importance of the geological barrier
Isolation of wastes from the biosphere is the ultimate objective for the final disposal of wastes in underground storage. The wastes, the geological barrier and the cavities, including any engineered structures constitute a system that together with all other technical aspects must fulfil the corresponding requirements.
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1.2.

Site-specific risk assessment
The assessment of risk requires the identification of:
- the hazard (in this case the deposited wastes),
- the receptors (in this case the biosphere and possibly groundwater),
- the pathways by which substances from the wastes may reach the biosphere, and
- the assessment of impact of substances that may reach the biosphere.
Acceptance criteria for underground storage are to be derived from, inter alia, the analysis of the host rock, so it must be confirmed that no site-related conditions specified in Annex I to the Landfill Directive (with an exemption of Annex I(2), (3), (4) and (5)) are of relevance.
The acceptance criteria for underground storage can be obtained only by referring to the local conditions. This requires a demonstration of the suitability of the strata for establishing a storage, i.e. an assessment of the risks to containment, taking into account the overall system of the waste, engineered structures and cavities and the host rock body.
The site specific risk assessment of the installation must be carried out for both the operational and post-operational phases. From these assessments, the required control and safety measures can be derived and the acceptance criteria can be developed.
An integrated performance assessment analysis shall be prepared, including the following components:
1. geological assessment;
2. geomechanical assessment;
3. hydrogeological assessment;
4. geochemical assessment;
5. biosphere impact assessment;
6. assessment of the operational phase;
7. long-term assessment;
8. assessment of the impact of all the surface facilities at the site.
1.2.1.

Geological assessment
A thorough investigation or knowledge of the geological setting of a site is required. This includes investigations and analyses of kind of rocks, soils and the topography. The geological assessment should demonstrate the suitability of the site for underground storage. The location, frequency and structure of any faulting or fracturing in surrounding geological strata and the potential impact of seismic activity on these structures should be included. Alternative site locations should be considered.
1.2.2.

Geomechanical assessment
The stability of the cavities must be demonstrated by appropriate investigations and predictions. The deposited waste must be part of this assessment. The processes should be analysed and documented in a systematic way.
The following should be demonstrated:
1. that during and after the formation of the cavities, no major deformation is to be expected either in the cavity itself or at the earth surface which could impair the operability of the underground storage or provide a pathway to the biosphere;
2. that the load-bearing capacity of the cavity is sufficient to prevent its collapse during operation;
3. that the deposited material must have the necessary stability compatible with the geo-mechanical properties of the host rock.
1.2.3.

Hydrogeological assessment
A thorough investigation of the hydraulic properties is required to assess the groundwater flow pattern in the surrounding strata based on information on the hydraulic conductivity of the rock mass, fractures and the hydraulic gradients.
1.2.4.

Geochemical assessment
A thorough investigation of the rock and the groundwater composition is required to assess the present groundwater composition and its potential evolution over time, the nature and abundance of fracture filling minerals, as well as a quantitative mineralogical description of the host rock. The impact of variability on the geochemical system should be assessed.
1.2.5.

Biosphere impact assessment
An investigation of the biosphere that could be impacted by the underground storage is required. Baseline studies should be performed to define local natural background levels of relevant substances.
1.2.6.

Assessment of the operational phase
For the operational phase, the analysis should demonstrate the following:
1. the stability of the cavities as in section 1.2.2;
2. no unacceptable risk of a pathway developing between the wastes and the biosphere;
3. no unacceptable risks affecting the operation of the facility.
When demonstrating operational safety, a systematic analysis of the operation of the facility must be made on the basis of specific data on the waste inventory, facility management and the scheme of operation. It is to be shown that the waste will not react with the rock in any chemical or physical way, which could impair the strength and tightness of the rock and endanger the storage itself. For these reasons, in addition to wastes that are banned by Article 5(3) of the Landfill Directive, wastes that are liable to spontaneous combustion under the storage conditions (temperature, humidity), gaseous products, volatile wastes, wastes coming from collections in the form of unidentified mixtures should not be accepted.
Particular incidents that might lead to the development of a pathway between the wastes and the biosphere in the operational phase should be identified. The different types of potential operational risks should be summarised in specific categories. Their possible effects should be evaluated. It should be shown that there is no unacceptable risk that the containment of the operation will be breached. Contingency measures should be provided.
1.2.7.

Long-term assessment
In order to comply with the objectives of sustainable landfilling, risk assessment should cover the long-term. It must be ascertained that no pathways to the biosphere will be generated during the long-term post-operation of the underground storage.
The barriers of the underground storage site (e.g. the waste quality, engineered structures, back filling and sealing of shafts and drillings), the performance of the host rock, the surrounding strata and the overburden should be quantitatively assessed over the long-term and evaluated on the basis of site-specific data or sufficiently conservative assumptions. The geochemical and geohydrological conditions such as groundwater flow (see sections 1.2.3 and 1.2.4), barrier efficiency, natural attenuation as well as leaching of the deposited wastes should be taken into consideration.
The long-term safety of an underground storage should be demonstrated by a safety assessment comprising a description of the initial status at a specified time (e.g. time of closure) followed by a scenario outlining important changes that are expected over geological time. Finally, the consequences of the release of relevant substances from the underground storage should be assessed for different scenarios reflecting the possible long-term evolution of the biosphere, geosphere and the underground storage.
Containers and cavity lining should not be taken into account when assessing the long-term risks of waste deposits because of their limited lifetime.
1.2.8.

Impact assessment of the surface reception facilities
Although the wastes taken at the site may be destined for subsurface disposal, wastes will be unloaded, tested and possibly stored on the surface, before reaching their final destination. The reception facilities must be designed and operated in a manner that will prevent harm to human health and the local environment. They must fulfil the same requirements as any other waste reception facility.
1.2.9.

Assessment of other risks
For reasons of protection of workers, wastes should be deposited only in an underground storage securely separated from mining activities. Waste should not be accepted if it contains, or could generate, hazardous substances which might harm human health, e.g. pathogenic germs of communicable diseases.
2.

ACCEPTANCE CRITERIA FOR UNDERGROUND STORAGE: ALL TYPES
2.1.

Excluded wastes
In the light of sections 1.2.1 to 1.2.8, wastes that may undergo undesired physical, chemical or biological transformation after they have been deposited must not be disposed of in underground storage. This includes the following:
1. wastes listed in Article 5(3) of the Landfill Directive;
2. wastes and their containers which might react with water or with the host rock under the storage conditions and lead to:
  - a change in the volume,
  - generation of auto-flammable or toxic or explosive substances or gases, or
  - any other reactions which could endanger the operational safety and/or the integrity of the barrier.
Wastes which might react with each other must be defined and classified in groups of compatibility; the different groups of compatibility must be physically separated in the storage;
3. wastes that are biodegradable;
4. wastes that have a pungent smell;
5. wastes that can generate a gas-air mixture which is toxic or explosive. This particularly refers to wastes that:
  - cause toxic gas concentrations due to the partial pressures of their components,
  - form concentrations when saturated within a container, which are higher than 10 % of the concentration which corresponds to the lower explosive limit;
6. wastes with insufficient stability to correspond to the geomechanical conditions;
7. wastes that are auto-flammable or liable to spontaneous combustion under the storage conditions, gaseous products, volatile wastes, wastes coming from collections in the form of unidentified mixtures;
8. wastes that contain, or could generate, pathogenic germs of communicable diseases (already provided for by Article 5(3)(c) of the Landfill Directive).
2.2.

Lists of waste suitable for underground storage
Inert wastes, hazardous and non-hazardous wastes, not excluded by sections 2.1 and 2.2 may be suitable for underground storage.
The appropriate agency may produce lists of wastes acceptable at underground storage facilities in accordance with the classes given in Article 4 of the Landfill Directive.
2.3.

Site-specific risk assessment
Acceptance of waste at a specific site must be subject to site-specific risk assessment.
The site-specific assessments outlined in section 1.2 for the wastes to be accepted at an underground storage should demonstrate that the level of isolation from the biosphere is acceptable. The criteria have to be fulfilled under storage conditions.
2.4.

Acceptance conditions
Wastes can be deposited only in an underground storage securely separated from mining activities.
Wastes that might react with each other must be defined and classified in groups of compatibility; the different groups of compatibility must be physically separated in the storage.
3.

ADDITIONAL CONSIDERATIONS: SALT MINES
3.1.

Importance of the geological barrier
In the safety philosophy for salt mines, the rock surrounding the waste has a two-fold role:
- it acts as host rock in which the wastes are encapsulated;
- together with the overlying and underlying impermeable rock strata (e.g. anhydrite), it acts as a geological barrier intended to prevent groundwater entering the landfill and, where necessary, effectively to stop liquids or gases escaping from the disposal area. Where this geological barrier is pierced by shafts and boreholes, these must be sealed during operation to secure against ingress of water, and must be hermetically closed after the underground landfill ceases to operate. If mineral extraction continues longer than the landfill operation, the disposal area must, after the landfill has ceased operating, be sealed with a hydraulically impermeable dam which is constructed according to the calculated hydraulically operative pressure corresponding to the depth, so that water which may seep into the still operating mine cannot penetrate through to the landfill area;
- in salt mines, the salt is considered to provide total containment. The wastes will only make contact with the biosphere in the case of an accident or an event in geological time such as earth movement or erosion (for example, associated with sea-level rise). The waste is unlikely to change in storage, and the consequences of such failure scenarios must be considered.
3.2.

Long-term assessment
The demonstration of long-term safety of underground disposal in a salt rock should be principally undertaken by designating the salt rock as the barrier rock. Salt rock fulfils the requirement of being impermeable to gases and liquids, of being able to encase the waste because of its convergent behaviour and of confining it entirely at the end of the transformation process.
The convergent behaviour of the salt rock thus does not contradict the requirement to have stable cavities in the operation phase. The stability is important, in order to guarantee the operational safety and in order to maintain the integrity of the geological barrier over unlimited time, so that there is continued protection of the biosphere. The wastes should be isolated permanently from the biosphere. Controlled subsidence of the overburden or other defects over long time are acceptable only if it can be shown, that only rupture-free transformations will occur, the integrity of the geological barrier is maintained and no pathways are formed by which water would be able to contact the wastes or the wastes or components of the waste migrate to the biosphere.
4.

ADDITIONAL CONSIDERATIONS: HARD ROCK
Deep storage in hard rock is here defined as an underground storage at several hundred metres depth, where hard rock includes various igneous rocks, e.g. granite or gneiss, it may also include sedimentary rocks, e.g. limestone and sandstone.
4.1.

Safety philosophy
A deep storage in hard rock is a feasible way to avoid burdening future generations with the responsibility of the wastes since it should be constructed to be passive and with no need for maintenance. Furthermore, the construction should not obstruct recovery of the wastes or the ability to undertake future corrective measures. It should also be designed to ensure that negative environmental effects or liabilities resulting from the activities of present generations do not fall upon future generations.
In the safety philosophy of underground disposal of wastes, the main concept is isolation of the waste from the biosphere, as well as natural attenuation of any pollutants leaking from the waste. For certain types of hazardous substances and waste, a need has been identified to protect the society and the environment against sustained exposure over extended periods of time. An extended period of time implies several thousands of years. Such levels of protection can be achieved by deep storage in hard rock. A deep storage for waste in hard rock can be located either in a former mine, where the mining activities have come to an end, or in a new storage facility.
In the case of hard-rock storage, total containment is not possible. In this case, an underground storage needs to be constructed so that natural attenuation of the surrounding strata mediates the effect of pollutants to the extent that they have no irreversible negative effects on the environment. This means that the capacity of the near environment to attenuate and degrade pollutants will determine the acceptability of a release from such a facility.
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Gas formation may occur in deep storage in hard rock due to long-term deterioration of waste, packaging and engineered structures. Therefore, this must be considered in the design of premises for a deep storage in hard rock.
Words in Appendix A section 1.1 omitted (31.12.2020) by virtue of The Waste (Miscellaneous Amendments) (EU Exit) Regulations 2019 (S.I. 2019/620), regs. 1(2)(b), 15(8)(a); 2020 c. 1, Sch. 5 para. 1(1)
Words in Appendix A section 2.2 substituted (31.12.2020) by The Waste (Miscellaneous Amendments) (EU Exit) Regulations 2019 (S.I. 2019/620), regs. 1(2)(b), 15(8)(b); 2020 c. 1, Sch. 5 para. 1(1)
Words in Appendix A section 4.1 omitted (31.12.2020) by virtue of The Waste (Miscellaneous Amendments) (EU Exit) Regulations 2019 (S.I. 2019/620), regs. 1(2)(b), 15(8)(c); 2020 c. 1, Sch. 5 para. 1(1)