DRAFT Tullamarine Landfill Post-closure and Rehabilitation Plan Introduction In accordance with EPA guidelines for the closure and rehabilitation of landfills (EPA 788) this Post-closure and Rehabilitation Plan provides an overview of the principles guiding the rehabilitation process and the major issues to be dealt with. This draft plan will guide the rehabilitation process and provide the basis for assessing progress and success for the rehabilitation project. A draft plan such as this will require regular review as the project progresses. Acceptance of this plan by the major stakeholders (TPI, EPA, Council and community groups), combined with a willingness to review the plan as required, is a public indication of mutual willingness to achieve the best environmental and social outcome for the community surrounding the landfill. Main Principles The overriding principle underpinning the goals of the post-closure and rehabilitation process is: To clean up contamination of the site to the maximum extent achievable and to ensure that all remaining waste is contained to the maximum extent achievable and for the long-term (i.e. until there is no risk of further environmental contamination). Major Issues The following issues arise in the post-closure and rehabilitation of the Tullamarine Prescribed Waste landfill: 1. Clean-up: There are several steps that need to be taken to clean up the site (in accordance with, amongst other requirements, the Groundwater SEPP and EPA Guidelines in Publication 840): i. There are likely to be contaminant “hot spots” within the landfill and these should be removed wherever practical. The first step will be to detect these spots (through investigation of deposit data and subsequent direct testing) ii. There is a large amount of LNAPL within the landfill which must be extracted and rapidly taken off-site for treatment or storage prior to treatment 2. Containment: The successful containment of this waste for the longest period of time depends on utilizing best practice technology combined with diligent monitoring: 1 i. Capping – the cap will be designed and constructed to utilize the best available technology for capping of landfill of this type and with the aim of ensuring total containment of the waste and leachate to the maximum extent achievable. Details of the capping arrangements are in Section 2: Capping. ii. Hot Spots – an important task to minimise risk is to locate contaminant hot spots and remove them where it is safe to do so. A detailed survey of past records of the location of toxic waste batches along with an extensive site survey to locate hot spots will be required as a matter of priority. iii. Leachate management – the most immediate area of concern is the prevention of further leakage of contaminants. This should involve the rapid (but safe) extraction of the LNAPL leachate as well as any other leachate that can be readily extracted in order to minimise the risk of leakage as well as substantially reduce the toxicity of any further leakage that may occur. The extracted leachate should be removed off-site to an appropriate treatment and/or storage facility in accordance with Government policy (as adopted in December 2000) Details of the leachate management system are in Section 3: Leachate Management. iv. Gas management – Details of the gas management system are in Section 4: Gas Management. v. Monitoring – must include: effective monitoring of existing plume and relevant waterways effective monitoring of air quality, where “effective” includes maximum practical continuous monitoring for selected potential gas emissions Details of the monitoring system are in Section 5: Monitoring System. vi. Contingency plans – These must provide practical and proven ways of managing adverse contingencies and must involve more than merely notifying potential “victims” of such contingencies. Details of the contingency plans are in Section 6: Contingency Plans. 2 3. Other Issues: i. Safety during transition – where is the EPA-approved quality control, EIP, etc (check the current terminology) ii. Future uses iii. Landscaping Details of the other issues are in Section 7: Additional Issues. 4. Section 173: A Section 173 should be included in the PAN (which presumably EPA will now issue for the site) or license (in the absence of a PAN) to ensure adequate legal opportunity for the Council and/or community group(s) to obtain legal intervention in the event that TPI fails to adequately and properly rehabilitate the site. 3