The growth of cities and residential communities and the subsequent consumption of vacant land will necessitate the expansion of existing landfill space or construction of new waste disposal facilities. Properties near operating or closed landfills, once vacant or thought unusable, are currently being developed or protected by environmental regulations (i.e., wetlands, stream floodplains, greenbelts, etc.). Increasingly landfill management will face the responsibility of stretching the usable life of the landfill facility to minimize costs. This "stretching" demands careful analysis of risks associated with landfill operation.

The environmental exposures associated with the disposal of wastes are staggering and increase as the facility ages and approaches designed/permitted capacity. To effectively minimize impacts to the air, groundwater and surface water, landfill management must develop a well-rounded risk management program. XL Environmental Risk Control’s 10 risk management recommendations for landfills can serve as a helpful guide.

1. Know the applicable environmental regulations. Understanding environmental regulations will assist in controlling risks and effectively using the services of environmental consultants when required (and controlling their subsequent costs). Information on environmental regulations is available from a variety of sources including state environmental agencies, other waste facility managers and the Internet. At a minimum, you should have a copy of the state’s solid waste regulations in the landfill office to facilitate review at a moment’s notice.
2. When securing the services of an environmental consultant, carefully define the consultant’s role. Be sure you have an ironclad contract that spells out consultant tasks in detail. Monitor the progress of the consultants to ensure they stay on track, that you are aware of regulatory agency contacts and stay within the monetary budget agreed via contract. Consultants typically interact with the federal, state or local regulatory agencies to ensure their progress on assigned tasks. If landfill management isn’t present when the consultant and regulatory agency negotiate a settlement, the landfill is nevertheless responsible. That’s why landfill management should control the consultant’s activities.
3. Develop and implement an orientation program for contractors/subcontractors entering your site to complete repairs, construction or installations. The orientation program should identify the party responsible for contacting utilities, areas the contractors should refrain from entering, and activities that should not be conducted unless approved by landfill management. If the contractor is supervised by a consultant, be sure the consultant is aware of the program and enforces its provisions. The consultant should also provide landfill management with a daily log of the day’s activities outlining the contractor’s activities.
4. Develop and implement Spill Prevention, Control, and Countermeasure (SPCC) plans, Stormwater Pollution Prevention (SPP) plans and other advanced emergency response programs. Storage tanks (aboveground and underground) can negatively impact surrounding surface water bodies or groundwater aquifers through spills, leaks or catastrophic failure. In addition, lagoons or other impoundments that fail could harm adjacent properties and waterways. Developing spill prevention plans and emergency response plans can mitigate potential financial and environmental impacts.
5. Provide secondary containment and integrity testing for aboveground storage tanks (ASTs). Concrete pads should be provided in the vicinity of the tanks to minimize the impacts of spills or leaks on soils/groundwater during refueling operations. Do not assume that your storage tanks are indestructible because they are new or have passed integrity testing. Tanks must be visually and/or mechanically tested on a regular basis, and secondary structures must be provided to minimize the environmental impacts of a tank failure or accidental release. Always document inspections. A concrete pad installed under and adjacent to the tank (or fuel dispensing area) will minimize impacts of fuel seeping into the soil, groundwater or surface water through spillage. Affix signs as required by state or local regulatory officials. If inventory control is the preferred method, only continuous documentation will highlight lost inventory and a potential leak.
6. Employee training can minimize future environmental and health/safety complications. Employee training in fire extinguisher use, OSHA HAZWOPER first responder techniques, hazardous waste identification, emergency response techniques, general first aid and bloodborne pathogens can minimize landfill disruption, costly remediation costs and workers’ compensation claims. A documented employee training program shows you are serious about maintaining a safe facility, in addition to adhering to OSHA requirements.
7. Establish a Hearing Conservation Program as part of your Health and Safety Program. A component of the program should include personal monitoring to establish workplace noise levels and determine potential employee exposure. Decibel levels in the vicinity of a truck, compactor, backhoe or dozer can exceed 100 dBA’s. Personnel exposed to these levels on a day-to-day basis may experience hearing loss as a result. Conduct training in the use of hearing protection equipment and insist that these be used.
8. If applicable, have a designated Health and Safety Officer (HSO) who can track health and safety training of personnel, monitor activities of consultants on-site, and review Site Specific Health and Safety Plans (SSHASPs). These plans should be prepared when on-site activities take place in areas that present dangerous conditions. HSOs can relieve the Operations Manager from overseeing all construction activities on-site and can halt dangerous practices.
9. Implement a screening program for incoming loads. Individuals at the scalehouse should be able to recognize unacceptable loads. Equipment operators should document a load inspection at least once per week or according to state solid waste regulations. A screening and load inspection program warns potential illegal dumpers that the landfill is proactive about unauthorized wastes entering the landfill. In addition, conducting the inspections/screening will ensure compliance with state and RCRA Subtitle D regulations.
10. Develop a dedicated space for landfill-related records. Segregate incoming waste profile/scalehouse information, compliance monitoring information, vehicular/equipment maintenance, training documentation and landfill personnel records. A sure way to receive a notice of violation (N.O.V.) or OSHA site audit is to have your records in disarray. Make sure records are up to date and in order.