The European criteria for acceptance of waste at landfills: Implementation of Council Decision 2003/33/EC in Denmark Ole Hjelmar11 Jesper Holm1, Jørgen G. Hansen2 and Kim Dahlstrøm2 DHI – Water & Environment Agern Allé 5, DK-2970 Hørsholm, Denmark 1 2 Danish Environmental Protection Agency Strandgade 29, DK- 1401 Copenhagen K, Denmark Abstract As part of the implementation of Council Decision 2003/33/EC the Danish EPA is developing the criteria for acceptance of granular waste at landfills adjusted to Danish conditions. The Danish methodology is similar to that used for the Council Decision criteria but the scenarios and conditions, particularly the water balances, are in many respects different from those used in the general European case. In contrast to the Council Decision, the Danish implementation will include development of leaching criteria for some organic components. It is also planned to add an element of sustainability by limiting the necessary aftercare period. Since no results are available yet, the paper focuses on describing the scenarios and conditions. It should be noted that the work described is still in progress and that changes may still occur in the scenarios and preconditions. Keywords: Landfill, Waste, Acceptance Criteria, Implementation, Leaching, Scenarios, Modelling, EU Landfill Directive, Council Decision 2003/33/EC 1. Introduction The Council Decision (2003/33/EC) of 19 December 2002 establishes criteria and procedures for the acceptance of granular waste at landfills pursuant to Article 16 and Annex II of Directive 1999/31/EC on the landfill of waste. The deadline for implementation of these criteria by the individual EU member states was 16 July 2004. Due to the considerable amount of work involved, this deadline proved difficult to meet and the implementation of the Council Decision has been somewhat delayed in several member states, including Denmark. Since the Landfill Directive is a so-called minimum directive, the member states are allowed to set stricter criteria nationally, if they can be justified by specific needs for protection of the environment. Denmark relies almost exclusively on groundwater as a source of drinking water and therefore has a strong need for strict protection of the groundwater quality. It is further Danish policy to promote sustainability in landfilling, particularly in terms of limiting the duration of the necessary aftercare period at landfills. Whereas the concept of sustainability has not been addressed in the EU Landfill Directive and the associated Council Decision, they do, on the other hand, not prevent the pursuit of sustainability within the regulatory framework they define. The Danish Environmental Protection Agency (DEPA) has therefore decided to use the methodology employed by the “Modelling group” of the TAC Subcommittee for the Landfill Directive, adjusted to Danish conditions, to develop the criteria to be implemented by Denmark, thereby attempting to ensure adequate protection of groundwater and surface water bodies and to add an element of sustainability to landfilling. It is expected that several of these criteria will be stricter than those listed in the Council Decision. Current Danish landfill policy requires all new landfills to be located near the coast. This means that also protection of marine waters must be taken into account. This will be incorporated into the development of Danish waste acceptance criteria but it will not be addressed in this paper. Author to whom correspondence should be addressed: oh@dhi.dk, phone: +45 45169405, fax: +45 45169292 This paper discusses the scenarios and the conditions applicable to the Danish situation with respect to the development of leaching-based waste acceptance criteria. It was originally planned also to present the resulting limit values to be implemented in Denmark. Due to the delay of the implementation procedure, this has not been possible, and scenarios and other preconditions may still be subject to change. With some luck it should, however, be possible to present at least proposals for Danish waste acceptance criteria at the time of the WasteEng 2005 conference. 2. The Methodology The methodology used to develop the acceptance criteria in the Council Decision 2003/33/EC has been described in detail by Hjelmar et al. (2001), DHI and ECN (2003) and Hjelmar (2003). It is briefly summarised below. Through a series of scenario-based model calculations a direct relationship is established between the leaching behaviour of mainly inorganic contaminants released from landfilled granular waste, expressed in terms of the results of a leaching test, and the risk these contaminants pose to the quality of downstream groundwater. The approach may best be described in terms of a series of consecutive steps. First a decision is made concerning the primary target or point of compliance (POC), e.g. the quality of groundwater at one or more points downstream of the landfill. Quality criteria are then selected for the groundwater, and the physical characteristics of the landfill and environment scenarios are selected and described. The environment scenario includes the net rate of infiltration and a hydrogeological description of the unsaturated and saturated (aquifer) zones upstream, below and downstream of the landfill. The source of the various contaminants is subsequently described in terms of the flux of contaminants as a function of time (or the liquid to solid ratio, L/S) based on leaching data and the hydraulic scenario defined. The leaching is approximated mathematically as an exponentially decreasing function of L/S, using a component-specific constant, kappa () – see equation (1). Then the migration of the contaminants from the base of the landfill through the unsaturated zone into the groundwater and through the aquifer to the POC is modelled including only reversible, sorption-based contaminant/subsoil interaction processes and using proven and accomplished flow and transport models. Selected Kd-values are used for each contaminant to calculate and incorporate the retardation factors (assuming linear sorption isotherms). Based on these “forward” calculations so-called “attenuation factors” (the ratio between the source peak concentration and the peak concentration as modelled at the groundwater POC) are determined for each contaminant. The principle of the three coupled source and transport models is illustrated in Figure 1. Model 1: The source POC Model 2: Transport in the unsaturated zone Landfill GWT Model 3: Transport in the saturated zone Figure 1. Cross-section showing the principle of three coupled source and transport models used for the forward impact calculation at a landfill scenario. The attenuation factors are then used for a “backwards” calculation of the permissible values of the source term corresponding to the selected groundwater quality criteria for each contaminant at a particular POC. In the TAC calculations the background concentration of the contaminants in the upstream groundwater was not taken into account. The Danish calculations will include consideration of such background concentrations. The final step consists of transforming the resulting source term criteria to a limit value for a specific test. It should be noted that the procedure involves simplifications and generalisations of complex and diverse physical-chemical processes. This may be justified by the need to have an operational and relatively simple system, which can be used for the development of general criteria. If needed, it is always possible to apply other or more sophisticated models and to adapt them to other general or site-specific conditions without changing the principle of the calculations. The Danish implementation of the Landfill Directive and the associated Council Decision will define four main types of landfills: Inert waste landfills, hazardous waste landfills and two subcategories of non-hazardous waste landfills, namely mineral waste landfills and landfills for mixed waste. Leaching criteria will be set only for landfills for inert waste, mineral (non-hazardous) waste, and hazardous waste. A Danish mineral waste landfill will in many respects be comparable to the landfills for non-hazardous waste receiving stable, non-reactive hazardous waste as defined in the Council Decision. 3. Scenario and Calculation/Modelling Conditions 3.1 Selection of targets for protection and contaminants to be included The TAC calculations only considered downstream groundwater quality, and the POCs were located 20 m and 200 m downstream of the edge of the landfill, respectively. In practice, only the POC located 20 m downstream of the landfill was used for the setting of criteria. The Danish calculations will include both groundwater and surface water quality targets. Because of the Danish policy of near-coastal location of landfills, marine water quality will be an important target. However, as already mentioned above, only waste acceptance criteria based on groundwater protection will be discussed in this context. The main Danish groundwater POC is placed 100 m downstream of the landfill. For comparison with the criteria for utilisation of residues and soil, calculations are also carried out for a POC located 30 m downstream of the landfill. In the Council Decision, leaching-based criteria were set for As, Ba, Cd, Cr, Cu, Hg. Mo, Ni, Pb, Sb, Se, Zn, chloride, fluoride, sulphate, DOC, phenol index, and TDS (as an alternative to chloride and sulphate) for waste to be accepted at landfills for inert waste. For landfills for non-hazardous waste receiving stable, non-reactive hazardous waste (from here on referred to as non-hazardous waste landfills) and landfills for hazardous waste, leaching based criteria were set for the same components as for inert waste landfills with the exception of the phenol index. In Denmark, the DEPA plans to include additional criteria for the leaching of those groups of organics for which total content-based criteria have been set for acceptance at inert waste landfills in the Council Decision. Those compounds are BTEX (in the calculations represented by benzene, toluene, and m-xylene), PCB (in the calculations represented by PCB no. 28), mineral oil (only C10 to C25 are considered, in the calculations represented by decane and pentadecane) and PAH (in the calculations represented by naphtalene and fluroanthene). 3.2 Description of scenarios The landfill scenarios used in the TAC calculations are shown in table 1, and the corresponding scenarios specified for the Danish situation are presented in table 2. As can be seen, it is assumed that a typical Danish landfill will be smaller than that anticipated by the TAC, both in terms of height, length and width. The general net rate of infiltration is assumed to be 350 mm/year under Danish conditions as opposed to 300 mm/year for the TAC calculations. In all cases, an active landfill operation period of 30 years is anticipated. The hydraulic scenario for the Danish situation is quite different from that assumed by the TAC. This is mainly due to the fact that in the Danish situation highly permeable top covers, which do not restrict the rate of infiltration, are used for all three types of landfills, and that no collection of leachate takes place after the artificial bottom liner ceases to function. The rate of infiltration of precipitation into all three types of landfills is therefore assumed to remain constant at 350 mm/year in the DK calculations. The TAC calculations also assume a highly permeable top cover for the inert waste landfills, and hence a constant rate of infiltration of 300 mm/year. In the case of non-hazardous and hazardous waste landfills the TAC calculations assume a reduced rate of infiltration of 200 mm during the operation period (30 years). The top is then covered by a composite liner (artificial liner and clay liner), which remains 100 % effective for 30 years. The artificial liner then gradually deteriorates over the next 50 years, after which it has no effect. The clay liner remains effective, and after 80 years it controls the rate of infiltration at 31.5 mm/year (corresponding to a permeability of 10-9 m/s at a gradient of 1 m/m). The resulting assumed rates of infiltration are shown in table 3 for the TAC calculations and in table 4 for the DK calculations. Table 1. Description of landfill scenario conditions and assumptions used in the TAC calculations. Parameter Unit Height of the landfill Length of the landfill Width of the landfill Surface area Volume Porosity of the waste Dry bulk density of the waste Dry weight of the waste Permeability of the waste Hydraulic conductivity of top cover m m m m2 m3 t/m3 t m/s mm/år Inert waste landfill 20 150 150 22500 450000 0.3 1.5 675000 1 x 10-5 > 300 Type of bottom liner Thickness of bottom liner (clay) Permeability of clay bottom liner m m m/s none - Non-hazardous waste landfill 20 200 200 40000 800000 0.3 1.5 1200000 1 x 10-5 variable: (0-200) composite* 1 1 x 10-9 Hazardous waste landfill 20 200 200 40000 800000 0.3 1.5 1200000 1 x 10-5 variable: (0-200) composite* 5 1 x 10-9 *: composite bottom liner (artificial liner + clay liner) Table 2. Description of landfill scenario conditions and assumptions used in the calculation under Danish conditions. m m m m2 m3 t/m3 t m/s mm/år Inert waste landfill 10 100 100 10000 100000 0.3 1.5 150000 1 x 10-5 > 350 Mineral waste landfill 10 100 100 10000 100000 0.3 1.5 150000 1 x 10-5 > 350 Hazardous landfill 10 100 100 10000 100000 0.3 1.5 150000 1 x 10-5 > 350 m m m/s composite* 2 1 x 10-7 composite* 2 1 x 10-9 composite* 5 1 x 10-9 Parameter Unit Height of the landfill Length of the landfill Width of the landfill Surface area Volume Porosity of the waste Dry bulk density of the waste Dry weight of the waste Permeability of the waste Hydraulic conductivity of top cover Type of bottom liner Thickness of bottom liner (clay) Permeability of clay bottom liner waste *: composite bottom liner (artificial liner + clay liner) In the TAC calculations, it is assumed that an inert waste landfill has no bottom liner, and the rate of release of leachate through the bottom of the landfill is hence 300 mm/year. Non-hazardous and hazardous landfills are assumed to be equipped with a composite bottom liner, i.e. an artificial liner on top of a clay liner. The artificial bottom liner is assumed to have an initial efficiency of 99 % and gradually deteriorate to an efficiency of 0 % over a period of 200 years. The efficiency of the clay part of the bottom liner remains intact, corresponding to a permeability of 10-9 m/s (or 31.5 mm/year at a gradient of 1 m/m), and after some time controls the rate of release of leachate. It is assumed that the leachate which is not released through the bottom of the landfill, is collected and managed (treatment and/or discharge). In fact, in the TAC calculations the collection and management of leachate is assumed to continue for as long as it is deemed necessary, i.e. beyond 110 years. Table 3. Assumed water balances over time for landfills for non-hazardous and hazardous waste in the TAC calculations DHI & ECN (2003) and Dijkstra (2004). years Infiltration through top cover mm/year Infiltration through bottom liner mm/year Leachate to be collected and treated and/or discharged mm/year 0 –30 200 Increasing from 2 to 31.5 Decreasing from 198 to 168.5 30 – 60 0 0 0 60 –80 Gradually increasing from 0 to 200 Gradually increasing from 0 to 31.5 Period 80 – 110 31.5 Gradually increasing from 0 to 168.5 110 - 200 31.5 168.5 Comment: No cover during operation, placement of artificial liner after closure Composite bottom liner. The clay liner remains effective, the artificial liner deteriorates over 200 years Continuing leachate collection and management beyond 110 years assumed Table 4. Assumed water balances over time for all three types of landfills in the Danish calculations. years Infiltration through top cover mm/year 0 –a 350 3.5 346.5 a- 350 350 0 Period Infiltration through bottom liner/over side mm/year Leachate to be collected and treated and/or discharged mm/year Composite bottom liner. 99 % effective during 70 years, then Comment: gradual deterioration of artificial liner while overflow occurs a: Time during which active leachate collection and management takes place. a = 60 years for inert waste landfills, 80 years for mineral waste landfills and 100 years for hazardous waste landfills No infiltrationreducing cover In the Danish calculations, the hydraulic situation is the same for all three types of landfills, except for the thickness and permeability of the bottom liner and the stipulated lifetime of the leachate collection system. All landfills, including inert waste landfills, are equipped with composite liners. It is assumed that the artificial liner remains 99 % efficient, corresponding to a rate of release of leachate through the bottom of 3.5 mm/year, for 70 years 60 years for inert waste landfills, for 80 years for mineral waste landfills and for 100 years for hazardous waste landfills. After this period, the collection of leachate is assumed to stop (it is then required to have reached a quality, which is acceptable in the surrounding environment) and a few years later all of the leachate produced will flow over the edge of the liner unless other conduits are constructed. In the scenarios it is assumed that all the leachate produced is released through the bottom or through or over the sides from year 60, 80 and 100, respectively. The water balances for the Danish landfill scenarios are shown in table 4. The resulting relationship between the liquid to solid ratio (L/S) and time is shown in table 5 for the different landfill scenarios for the first 100 years. Table 5. Accumulated L/S as a function of time for the different landfill scenarios for the first 100 years. Time elapsed (years) 1 10 30 60 70 100 Danish scenarios, all landfills 0.023 0.23 0.70 1.4 1.63 2.33 Accumulated L/S (l/kg) TAC scenario for TAC scenario for non-hazardous inert waste landfill and hazardous waste landfills 0.01 0.007 0.10 0.07 0.30 0.20 0.60 0.20 0.70 0.21 1.00 0.31 3.3 The composition of the leachate as a function of L/S A rather crude and simplified description of the release of contaminants as a function of L/S or time is used in both the TAC calculations and the Danish calculations. Waste/waste interactions are neglected and the landfill is regarded as one large column or lysimeter, and it is assumed that the leaching of the contaminants under consideration can be described as an exponentially decreasing function of L/S or time, originally based on a simple continuously stirred tank reactor model (see e.g. Hjelmar et al., 2001). The concentration C of a contaminant in the leachate (or eluate, from a laboratory leaching test) may then be estimated as follows: C = C0 x e-(L/S) where (1) C0 is the initial peak concentration of the contaminant in the leachate (mg/l), L/S is the accumulated liquid to solid ratio corresponding to the concentration C (l/kg), is a kinetic constant describing the rate of decrease of the concentration as a function of L/S for a given material and a given component (kg/l). may be estimated from laboratory leaching data and is for this purpose considered independent of the material/waste in question (this is not actually true as may vary both with material and L/S, and the description of the source term may be improved by using material-specific values over limited L/S ranges). By integrating the above expression, the amount of contaminant, E (in mg/kg), released over the period of time it takes for L/S to increase from 0 l/kg to the value corresponding to C, can be calculated: E = (C0/)(1 – e - (L/S) ) (2) Only a limited number of determinations of are available, and the values used for the inorganic contaminants both in the TAC calculations and the Danish calculations were produced by Albers et al. (1996) based on column leaching tests performed on construction materials. Additional data on phenol and DOC were estimated by ECN (DHI and ECN, 2003). The values are listed in table 6. Improved values adjusted to specific groups of waste and scenarios may, if possible, be applied in the Danish calculations. Leaching curves (C/C0 vs. L/S) for various values of , assuming the CSTR leaching model, are presented in figure 2. Since no values are available for organic compounds (other than phenol and DOC), values have been estimated partly on the basis of theoretical considerations, assuming that the CSTR leaching model is applicable also to organic compounds. It was further assumed that the waste types (inert, non-hazardous and hazardous) may be represented by soils with different contents of TOC (same value used for non-hazardous and hazardous waste). Fugacity calculations for a given compound were then performed for a system under conditions corresponding to those in the unsaturated zone. The starting point was saturated pore water, and the distribution between the water, solid and gas phases was subsequently determined using K d values estimated from TOC and literature values of KOC (the organic carbon/water partitioning coefficient) estimated from the octanol/water partitioning coefficient (KOW), water solubility and Henry’s constant. Pore volume distributions of air and water, V A/Vw, corresponding to 2 (sand) and 0.33 (clay), respectively, were used. The resulting values are shown in table 7. Table 6. List of the values for inorganic components and phenol and DOC used both in the TAC calculations and the Danish calculations. Parameter As Ba Cd Cr Cu Hg Mo Ni Pb Sb Se Zn Chloride Fluoride Sulphate Phenol DOC Average values and 95 % confidence intervals for (kg/l) 0.03 0.05 0.15 0.04 0.50 0.10 0.18 0.03 0.28 0.03 0.05 0.03 0.35 0.04 0.29 0.05 0.27 0.06 0.11 0.07 0.38 0.18 0.28 0.05 0.57 0.07 0.22 0.14 0.33 0.05 0.3 0.17 Number of determinations 44 55 37 82 90 5 76 37 52 33 10 41 45 6 49 Data source Albers et al. (1996) Albers et al. (1996) Albers et al. (1996) Albers et al. (1996) Albers et al. (1996) Albers et al. (1996) Albers et al. (1996) Albers et al. (1996) Albers et al. (1996) Albers et al. (1996) Albers et al. (1996) Albers et al. (1996) Albers et al. (1996) Albers et al. (1996) Albers et al. (1996) ECN (DHI &ECN, 2003) ECN (DHI &ECN, 2003) Kappa (kg/l) 0.1 0.2 0.5 0.8 1 5 10 1 0.8 C/C0 0.6 0.4 0.2 0 0.001 0.01 0.1 1 10 100 L/S (l/kg) Figure 2. The influence of on the shape of the leaching curve, assuming the CSTR leaching model. The calculations were repeated in steps corresponding to the annual rate of infiltration and accounting for the gradual removal of organic contaminant with the pore water to provide C/C 0 as a function of L/S from which could subsequently be determined. Assuming values of fOC for inert waste (fOC = 0.005), mineral waste (fOC = 0.03) and hazardous waste (fOC = 0.03), the values shown in table 7 were calculated for the organic compounds under consideration for use in the model calculations (it is still being considered whether to use one value for all waste types or whether to use two different values for each component as calculated). Only values corresponding to clay properties are shown since they were lower than or equal to those corresponding to sand properties and hence considered most critical in relation to the model calculations. As shown in Figure 2, a lower corresponds to a slower decrease in leachate concentration, and this generally leads to a higher downstream peak groundwater concentration). Table 7. Estimated values of (in kg/l) for organic compounds leaching from waste in Danish scenarios. Compound Benzene Toluene m-xylene Naphtalene Fluoranthene Decane Pentadecane PCB 28 Inert waste (fOC = 0.005) 3.8 1.6 0.74 0.42 0.0052 0.00043 0.0000015 0.0020 Mineral waste (fOC = 0.03) 1.2 0.34 0.14 0.073 0.00086 0.000073 0.00000024 0.00033 Hazardous waste (fOC = 0.03) 1.2 0.34 0.14 0.073 0.00086 0.000073 0.00000024 0.00033 3.4 Transport and groundwater quality parameters Table 8 shows the values of Kd used to describe the contaminant/subsoil interaction in the transport modelling both in the TAC calculations and in the Danish calculations (still subject to change). The same Kd values are used to describe the conditions in the both the unsaturated and the saturated zones. Table 8. Subsoil Kd values (both for the unsaturated and saturated zones), groundwater background concentrations and GW criteria used in the TAC calculations (DHI and ECN, 2003) and proposed for the Danish calculations. The Danish Kd values are still under consideration. Component As Ba Cd Cr Cu Hg Mo Ni Pb Sb Se Zn Chloride Fluoride Sulphate Phenol DOC Benzene Toluene m-xylene Napthalene Fluoranthene Decane +Pentadecane PCB 28 DK 100 2 20 1 100 20 10 20 100 5 5 20 0 2 0 5 0 0.02 0.1 0.2 0.5 40 100 100 Kd (l/kg) TAC 50 2 20 100 14 1 10 50 50 5 5 30 0 2 0 40 0 - GW background conc. (g/l) DK only 0.8 62 0.008 0.09 0.3 0.0011 0.7 0.5 0.05 0.08 0.10 3.0 25 0.5 50 0 Undetermined 0 0 0 0 0 0 0 GW quality criteria at POC (g/l) DK TAC 8 10 700 700 2 4 20 50 100 50 1 1 20 70 10 20 5 10 2 5 10 10 100 100 150000 250000 1500 1500 250000 250000 Undetermined 100 3000 10000 1 5 5 1 0.1 5 -0.01 - In the Danish calculations, the background concentration of the contaminants in the upstream groundwater are taken into account in the determination of the dilution. The background concentrations used are also shown in table 8. The table also shows the groundwater quality criteria set at the POC in both cases. Substantial reductions are seen in the Danish values as compared to the TAC values for Hg, Mo and phenol. Smaller reductions are seen for As, Cd, Cr, Ni, Pb, Sb and chloride, whereas an increase is seen for Cu. 3.5 Transport modelling in the unsaturated and saturated zones The input to the transport model for the unsaturated zone in terms the flux of each contaminant as a function of time is calculated for each type of landfill by combining the information on the flow of leachate out of the landfill (section 3.2) with the information on the composition of the leachate as a function of L/S (section 3.3). For a given scenario, the relationship between L/S and time is easily calculated (e.g. Hjelmar, 1990). A numerical 3 D flow and transport code, MIKE-SHE, in which the modelling of the transport through the unsaturated and the saturated zones is integrated, is applied in the Danish contaminant transport calculations (DHI, 2003). The corresponding TAC calculations were performed using CXTFIT/ECOSAT and HYDRUS 2D for the unsaturated zone and MODFLOW and MT3D for the saturated zone (DHI and ECN, 2003). Since the clay part of the bottom liners under the landfills constitutes the unsaturated zone, the parameter values for the unsaturated zone modelling can be seen in tables 1 and 2. The parameter values used in the model calculations of the transport in the saturated zone both in the Danish and the TAC calculations are shown in table 9. The relatively large differences between the DK and TAC dispersivities may be explained by the fact that in the TAC calculations, high dispersivities were used in the model to ensure the occurrence of total vertical mixing in the aquifer, which was one of the pre-conditions. Total vertical mixing is not assumed in the Danish calculations. Table 9. Parameter values used in the model calculations of transport in the saturated zone in the Danish calculations and in the calculations performed by the TAC (DHI and ECN, 2003). Parameter Width of catchment Length of catchment Distance from water divide to beginning of landfill Distance to POC Net rate of infiltration Thickness of aquifer Upper boundary Fixed hydraulic head at downstream boundary Horizontal hydraulic conductivity Kx = Ky Vertical hydraulic conductivity Kz Effective porosity Longitudinal dispersivity Transversal dispersivity Vertical dispersivity Cell size Number of calculation layers Unit Used in DK m m m m mm/year m m m/s m/s m m m m - 300 250 50 100 (and 30) 350 6 Closed Approx. 5.75 10-4 10-5 0.3 0.45 0.001 0.0005 2 8 Used by TAC 500 600 100 20 and 200 300 Approx. 6 Closed Approx. 4.1 1.4 x 10-4 1.4 x 10-4 0.3 20 4 2 10 6 4. Determination of Attenuation Factors and Limit Values for Leaching Once the attenuation factor (i.e. the ratio between the peak concentration at the bottom of the landfill and the peak concentration at the POC) has been determined for a given contaminant and a given landfill scenario, it can be used to determine the maximum allowable concentration at the base of the landfill. In the TAC calculations, the maximum allowable concentration is found by multiplying the groundwater quality criteria (table 8) by the attenuation factor. In the Danish calculations, where background concentrations are accounted for, the upstream background concentration (table 8) is subtracted from the groundwater quality criteria before it is multiplied by the attenuation factor. To find the actual leaching limit value in terms of released amount (mg/kg), the maximum allowable concentration found above is entered into equation (2) in section 3.3 as C0. Using the appropriate values for L/S and (see Tables 6 and 7), the limit value E corresponding to the L/S value used can be calculated. Denmark has chosen to refer the limit values to L/S = 2 l/kg and to use the batch leaching test EN 12457-1 for compliance purposes. Due to the delayed implementation of the Council Decision in Denmark, actual modelling results and limit values are not yet available. They should, however, be available for presentation at the time of the WasteEng 2005 conference. 5. Conclusion As part of the implementation of the Council Decision 2003/33/EC the Danish EPA has decided to use the methodology employed by the “Modelling group” of the TAC Subcommittee for the Landfill Directive, adjusted to Danish conditions, to develop the waste acceptance criteria to be applied in Denmark. Due to the strong emphasis on groundwater protection in Denmark, some of the Danish acceptance criteria are expected to be more stringent than those developed by the TAC. Since the Danish implementation of the Council Decision has been delayed, actual results of the model calculations are not yet available. Instead, the paper focuses on describing the scenarios and conditions, which are being used in the Danish model calculations. Throughout, they are compared to the scenarios and conditions used in the TAC calculations. Some of the major differences are that a bottom liner for inert waste landfills is prescribed in DK but not by the TAC, and that in contrast to the TAC calculations, no infiltration-reducing top cover is allowed at the Danish landfills. It is furthermore assumed that leachate collection is discontinued for the three landfill types defined in DK (for inert waste, mineral, non-hazardous waste and hazardous waste, respectively) after 60, 80 and 100 years, respectively, at that time producing an overflow of 350 mm/year and requiring the leachate to be acceptable in the surrounding environment. In principle, leachate collection is continued forever for the TAC calculation scenarios for non-hazardous and hazardous waste, producing an annual release of leachate of only 31.5 mm. Another difference is that DK intends to develop leaching criteria for those organic components (BTEX, PCB, mineral oil and PAH) for which total content criteria are required for inert waste landfills in the Council Decision. The Danish POC is located 100 m downstream of the landfill, whereas the TAC in the POC calculations were placed 20 m downstream for most components. In addition, several parameters used in the release and transport calculations, including Kd values, groundwater background concentrations and groundwater quality criteria have been adjusted to Danish conditions. Both the kappa-values used in the source term and the Kd values are still under consideration. The resulting limit values may be expected to differ from the TAC results. 6. Acknowledgement and Disclaimer The work presented in this paper was funded by the Danish Environmental Protection Agency (DEPA) and based on the methodology developed by the Model Group under the TAC Subcommittee for the Landfill Directive, which developed the criteria for acceptance of waste at landfills described in Council Decision 2003/33/EC. As in several other countries, the implementation of the Council Decision into Danish legislation has been delayed, and the iterative process of setting up and adjusting scenarios and conditions and performing model calculations has not yet been fully completed. The work and the data presented must therefore be regarded as preliminary and subject to change. References Aalbers, Th.G., de Wilde, P.G.M., Rood, G.A., Vermij, P.H.M., Saft, R.J., van de Beek, A.I.M., Broekman, M.H., Masereeuw, P., Kamphuis, Ch., Dekker, P.M. and Valejtijn, E.A., 1996, Environmental quality of primary and secondary construction materials in relation to re-use and protection of soil and surface water. RIVM-report no.: 771402007. National Institute of Public Health and the Environment, Bilthoven, The Netherlands. DHI, 2003, MIKE SHE – An integrated Hydrological Modelling System. User Guide. DHI – Water and Environment, Hørsholm, Denmark. DHI and ECN, 2003, Development of acceptance criteria for landfilling. Documentation of the modelling and scenario calculation carried out by DHI and ECN in support of the development of acceptance criteria for landfilling within the TAC Subcommittee on the Landfill Directive. Draft report for the Danish EPA and the Dutch Ministry of the Environment. Dijkstra, J.J.,(2004, Personal communication, ECN, The Netherlands. Hjelmar, O., 1990, Leachate from land disposal of coal fly ash. Waste Management & Research, 8, pp. 429-449. Hjelmar, O., 2003, Environmental performance of waste materials. In Dhir, R.K, Newlands, M.D. & Halliday, J.E. (eds.): Recycling and Reuse of Waste Materials. Proceedings of the International Symposium held at University of Dundee, Scotland, UK on 9-11 September 2003, Thomas Thelford, London, pp. 653-668. Hjelmar, O., H.A. van der Sloot, D. Guyonnet, R.P.J.J. Rietra, A. Brun & D. Hall, 2001, Development of acceptance criteria for landfilling of waste: An approach based on impact modelling and scenario calculations. In: T.H. Christensen, R. Cossu and R. Stegmann (eds.): Sardinia 2001, Proceedings of the Eigth International Waste Management and Landfill Symposium, S. Margharita di Pula, Cagliari, CISA , Vol. III, pp. 712-721, CISA.