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Risk assessment framework for management of the factor 3 rule in the Council Decision 2003/33/EC on waste acceptance criteria

image of Risk assessment framework for management of the factor 3 rule in the Council Decision 2003/33/EC on waste acceptance criteria

EU landfill directive defines three categories of landfills: landfills for inert waste, for normal waste and for hazardous waste. Criteria for which waste may be disposed at each type of landfill are also given. They consist primarily in limit values for the leaching of inorganic components. It is however possible to allow higher limit values for specific waste and components. However, this requires a risk assessment to demonstrate that this represents no additional risks to the environment. This report provides guidance on possible approaches to a risk assessment in cases where deviations from the landfill regulations are considered and to point out key issues to be taken into account. A proposal for an approach to be used in the impact assessment is presented. The focus is primarily on inorganic constituents. The results of this project may be used in the development of national guidelines on deviation from EU landfill criteria.

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Summary and further work

The EU landfill waste acceptance criteria (WAC) are mandatory minimum requirements for wastes to be disposed at specific landfills (i.e. landfill for inert waste, non-hazardous waste receiving stable, nonreactive hazardous waste or for landfills for hazardous waste). WAC for non-hazardous landfills not receiving stable, non-reactive hazardous wastes may be decided at a national level. The so-called factor 3 rule (allowing the WAC to be exceeded by up to a factor of 3) stipulated in Council Decision 2003/33/EC may be applied to the leaching criteria with restrictions for specific components in the waste (not dissolved organic carbon (DOC). The factor 3 rule cannot generally be applied for to other parameters (e.g. BTEX, loss on ignition). The only exception is the TOC content in certain special cases (e.g. soil-like waste to be disposed at landfills for inert waste). It is recommended not to apply the factor 3 rule to the WAC for priority pollutants such as Cd and Hg.

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