Levin Site Rpt 14 June 2017.pdf

19 June 2017

Horowhenua District Council
Private Bag 4002
File ref: 1/4/HDC
LEVIN 5540
6009, 6010, 6011, 6012, 102259
HSS

Attention Gallo Saidly, Paul Gaydon & Ryan Hughes

Dear Sirs,

LEVIN LANDFILL COMPIANCE INSPECTION – 6 FEBRUARY 2017 TO 1 JUNE 2017

Routine  site  inspections  of  the  Levin  Landfill  (landfill)  were  carried  out  on
14  February  2017  and  12  May  2017  by  Horizons  Regional  Council  (HRC)  Consents
Monitoring  Officers.  These  inspections  were  undertaken  to  assess  the  onsite  operations
related  to  landfill  cover,  leachate  and  stormwater  management  and  to  view  recent
improvements  made  to  the  leachate  and  landfill  gas  (LFG)  collection  system.  This
compliance  assessment  does  not  assess  the  monitoring  data  contained  in  the  landfill
quarterly  or  comprehensive  reports.  A  subsequent  report  will  be  drafted  following  a  full
review of this information.

The attached report relates to the above site visits, it also draws on a number of proactive
and  reactive  odour  assessments  undertaken  to  verify  a  number  of  odour  complaints
received by HRC  in  relation  to  the  landfill.  The  overall assessment  period covered by  this
report  is  6  February  to  1  June  2017.  The  attached  report  provides  an  assessment  of  the
relevant conditions for this reporting period.

As  a  result  of  this  assessment  the  landfill  has  been  given  an  overall  Comply  –  Full  for
consent  6009,  Comply  for  consents  6010,  6012  and  102259  and  a  Significant  Non  –
Compliance for consent 6011.

Please note that since the Levin Landfill is at the time of this invoice not complying with the
conditions of its resource consents, the compliance monitoring charges are 100% of the full
charge as detailed in the attached cost sheet.

Please  find  attached  a  copy  of  Horizons  Regional  Council’s  Compliance  Assessment
Guidelines for your reference.

If you have any queries about the attached report, please contact me on Freephone 0508
800 800, or via email [email address].

Kind regards,

Hamish Sutherland
SENIOR CONSENTS MONITORING OFFICER

COMPLAINCE REPORT
LEVIN LANDFILL

Resource Consents
6009, 6010, 6011, 6012 & 102259

Reporting Period
6 February to 1 June 2017

19 June 2017

Prepared By

Hamish Sutherland
SENIOR CONSENTS MONITORING OFFICER

Reviewed By

Pita Kinaston
TEAM LEADER CONSENTS MONITORING

2

EXECUTIVE SUMMARY
This  compliance  report  assesses  compliance  against  resource  consents  6009,  6010,  6011,  6012  and
102259  which  are  held  by  Horowhenua  District  Council  (HDC)  for  the  operation  of  the  Levin  Landfill
(landfill),  situated  on  Hokio  Beach  Road.    The  assessment  period  covered  by  this  report  is  from  6
February 2017 to 1 June 2017.  During this period Horizons Regional Council (HRC) Consents Monitoring
Officers  have  undertaken  two  site  inspections  on  14  February  2017  and  12  May  2017  respectively.
These  inspections  were  undertaken  to  assess  the  onsite  operational  conditions  for  the  landfill,
specifically  conditions  related  to  capping/cover,  leachate  management,  stormwater  management  and
odour.

In  addition  to  the  site  inspections  outlined  above  HRC  have  undertaken  a  number  of  proactive  and
reactive odour assessments, in response to odour complaints, related to the landfill.  These complaints
have  primarily  been  from  a  complainant,  at  one  address,  who  shares  a  mutual  boundary  with  the
landfill.

In  determining  whether  an  odour  is  objectionable  (and  therefore  non-compliant  with  Condition  3  of
resource  consent  6011)  HRC  consents  monitoring  officers  consider  the  FIDOL  factors,  which  are
Frequency, Intensity, Duration, Offensiveness  and Location.    To assess the complaints  HRC has had to
establish  these  factors  with  respect  to  the  landfill.    In  doing  this  HRC  has  worked  with  the  primary
complainant  requesting  they  keep  an  odour  diary.    This  odour  diary  has  been  used  by  HRC  in
conjunction with its own observations and assessments to determine the Significant Non – Compliance
status against Condition 3.  This approach is consistent with best practice in assessing odour as per the
Ministry  for  the  Environment  Guidelines  titled,  “Good  Practice  Guide  for  Assessing  and  Monitoring
Odour”, dated 2016.

As a result of the inspections and assessments outlined above the following compliance  gradings have
been allocated;

Discharge Permit 6009 – discharge solid waste to land = Comply – Full.

Discharge Permit 6010 – discharge landfill leachate onto and into land = Comply

Discharge Permit 6012 – divert stormwater from around the Levin landfill = Comply

Discharge  Permit  102259  –  discharge  stormwater  to  land  and  potentially  to  groundwater  via
ground soakage = Comply

Discharge  Permit  6011  –  discharge  landfill  gas,  odour  and  dust  to  air  =  Significant  Non -
Compliance

3

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SCOPE OF REPORT
This compliance report assesses the Levin Landfill (Landfill) against resource consents 6009, 6010, 6011
and 102259.  This report covers an assessment period of 6 February 2017 to 1 June 2017.  In completing
this  report  two  site  inspections  have  been  undertaken  on  14 February  2017  and  12  May  2017.    In
conjunction with this HRC has undertaken various assessments to determine compliance with resource
consent 6011 which governs the Landfills discharges of landfill gas, odour and dust to air.

This report does not assess the quarterly or comprehensive monitoring reports required by the above
consents.  This information will be reviewed and covered in a subsequent report.

BACKGROUND
The  Levin  Landfill  is  located  on  Hokio  Beach  Road  in  the  Horowhenua  District,  4  kilometres  west  of
Levin.    The  landfill  site  is  located  in  undulating  sand  country  surrounded  by  pastoral  farming  land,
3 kilometres  from  the  coast  and  6  kilometres  from  State  Highway  1.    The  site  is  approximately
72 hectares in area.

The  Hokio  Stream  (the  single  outlet  for  Lake  Horowhenua)  runs  in  close  proximity  to  the  northern
boundary of the landfill site as it flows west to the sea over a distance of approximately 2.5 kilometres.
There are a number of rural residences located to the north-east of the landfill site and the small coastal
settlement of Hokio Beach is located approximately 1.5 kilometres to the north-west.  The Ngatokowaru
marae  (Ngati  Pareraukawa,  Ngati  Raukawa)  is  located  approximately  500  metres  north-east  of  the
landfill property, while the Kawiu marae (Muaupoko) is on the northern shore of Lake Horowhenua.

The  original  resource  consents  were  granted  to  Horowhenua  District  Council  (HDC)  in  1998.    These
covered the closed landfill and the new lined landfill.

In  2004  the  then  Parliamentary  Commissioner  for  the  Environment  (the  Commissioner),  received
complaints  from several members of the local community expressing concern about  the management
and associated environmental effects of the Levin Landfill.  The commissioner suggested a review was in
order.  Between 2004 and 2007 there was a lot of to and fro between HDC and Horizons and the various
consultants that were employed in relation to these concerns.

5

The Commissioner had originally indicated that their formal investigations would be postponed until the
consent review had been completed; however, given delays in progressing the review, in July 2007 the
new  Commissioner  decided  to  commence  an  investigation  and  prepare  a  report  for  the  benefit  of  all
parties in an aim to resolve the matters at hand.

The Commissioner’s  report  acknowledged that Horizons had made  a decision to publicly  notify a new
consent  review  which  would  supersede  previous  negotiations  between  Horizons  and  HDC.
Notwithstanding the proposed review, the Commissioner considered that there was significant merit in
releasing  their  findings  at  that  particular  time  given  the  concerns  of  the  local  community  and  the
importance of the outcome of the proposed review.

The  Parliamentary  Commissioner  for  the  Environment  report  (August  2008)  and  supporting  technical
assessment  undertaken  by  Tonkin  and  Taylor  (dated  25  March  2008)  included  key  recommendations
which were taken into consideration by the Commissioner in forming their final recommendations.

The  report  provided  guidance  for  the  review  of  the  landfill’s  resource  consents  including
recommendations  on  compliance  monitoring  by  Horizons  and  the  monitoring  and  operation  of  the
landfill by HDC, including liaising with the Neighbourhood Liaison Group.

A  formal  review  was  initiated  which  was  completed  by  2010  and  resulted  in  the  current  resource
consent conditions under the following resource consents.

Resource
consent  Nature of resource consent
number
6010/1
Discharge of landfill leachate onto and into land
6009/1
Discharge of solid waste onto land
6011/1
Discharge of landfill gas, odour and dust to air
7289/1
Discharge of liquid waste onto and into land
102259/1
Discharge  of  stormwater  to  land  and  potentially  to  groundwater  via
soakage

Recently a further review of the relevant resource consent conditions was completed; however, this is
subject to an appeal therefore the current resource consent conditions apply.

6

MONITORING CARRIED OUT / REQUIRED
The assessment period covered by this report is 6 February 2017 to 1 June 2017.  During this assessment
period  two  site  inspections  have  been  undertaken  by  HRC  to  determine  compliance  with  the  on  site
operational  conditions  of  resource  consents  6009,  6010,  6011  and  102259.    These  inspections  were
undertaken on 14 February 2017 and 12 May 2017.  In particular these inspections were to assess the
on  site  management  of  conditions  related  to  capping/cover,  leachate  management,  stormwater
management, litter and odour.

Over  the  above  assessment  period  HRC  Consents  Monitoring  Officers  have  undertaken  a  series  of
reactive  and  proactive  odour  assessments.    These  assessments  have  been  undertaken  on  a  property
that shares a mutual boundary with the Landfill.  Eight completed assessment forms are available and
have been used to determine the presence of odour beyond the consented Landfill boundary and the
intensity and nature of that odour with respect to location.

In conjunction with the odour assessments outlined above HRC has provided the residents who reside at
the property adjoining the Landfill an odour diary.  This report has used this odour diary to determine
the frequency and regularity of odours leaving the consented Landfill boundary and covers a period of
6 February 2017 to 12 May 2017.

7

GENERAL  CONDITIONS  APPLICABLE  TO  DISCHARGE  PERMIT  6009  –
DISCHARGE SOLID WASTE TO LAND
1.
This permit does not authorise the disposal of liquid waste to land at the Levin Landfill.

Liquid waste is defined as:

Septic tank waste, grease trap waste, sewage and any material that contains free liquids.

The presence of free liquids may be determined by either of the following methods, whichever is
most practicable at the time:

i.
The “Paint Filter Test”; or

ii.
Material which may be loaded, transported and deposited at the landfill without the risk
of  free  liquid  seeping  from  the  material,  and  without  the  risk  of  having  the  deposited
material  flow  under  gravity  down  any  slope  on  the  landfill  shall  be  deemed  to  not
contain free liquids.

During the 14 February 2017 site inspection several separate loads were brought to the landfill and were
inspected.    All of these  loads were  deemed to not  contain free  liquids as per condition (1)(ii).    At the
time of this inspection the landfill operation was complying with this condition.  Comply-Full.

2.
The  Permit  Holder  shall  take  all  practicable  measures  to  avoid  the  discharge  of  waste  from
within the landfill to surrounding land. To this end, the Permit Holder shall ensure:

a.
The amount  of refuse exposed at  any one time is confined in dimension to 800 square
metres of tipping face; and

At the time of my inspections the active tipping face was around 35 meters by 20 meters which is less
than the consented area above.  Comply-Full.

b.
Exposed refuse is covered at the end of each day that refuse is received at the landfill.

The  timing  of  the  inspections  were  in  the  middle  of  the  day  therefore  I  was  unable  to  verify  this
condition.    Please ensure  daily  cover  is  applied  in  accordance  with  this  condition.  It  is  noted  that the
Landfill  Management  Plan  states  primary  cover  of  waste  should  be  provided  daily  except  where  no
significant  adverse  impact  would  occur  without  the  cover.    For  clarification  it  is  expected  that  the
consent holder will adhere to Condition 3b.  Not Assessed.
8

3.
If refuse is discharged from within the active landfill areas to land outside the legal boundary of
the landfill property, the Permit Holder shall ensure that such waste is cleared and removed to
the landfill as soon as practicable.

The  Levin  Landfill  has  litter  fences  on  the  periphery  of  the  landfill  cells  to  help  control  any  airborne
refuse leaving the site. During both inspections the litter fences were clean; in addition to this I did not
see any rubbish beyond the litter fences.  Comply – Full.

4.
The Permit Holder will monitor the landfill at least once every two weeks for the build up of litter,
paper  and  other  deposits  outside  the  active  landfilling  areas,  and  remove  such  material  as
required.

As  discussed  above,  the  landfill  has  litter  fences  to  intercept  any  rubbish  blown  from  the  active
landfilling areas.  This material is collected regularly by onsite staff and returned to the active landfilling
areas.  During my inspections I noticed the litter fences were clear with full collection bags spaced along
the litter fence line indicating the litter fences were regularly cleared.  Comply – Full.

5.
The Permit Holder shall regularly inspect for the presence of vermin, birds and other pests take
appropriate measures to control them.

The onsite staff utilise a gas-powered bird scarer with an occasional shooting to manage birds and cats.
Rat stations are also installed around the litter fences.  During both inspections birds were seen on the
operational Landfill cells.  The gas powered bird scarer was seen but not heard during both inspections
therefore it is not clear whether it is in operation.  The Landfill Management Plan is silent with regard to
recording  the  instances  of  any  inspections  for  the  presence  or  vermin,  birds  and  other  pests.    It  is
recommended the consent holder record and report on any inspections and any action taken, to achieve
full compliance with this condition.  Comply – At Risk.

6.
The  Permit  Holder  shall  regularly  inspect  the  landfill  for  noxious  weeds,  and  take  appropriate
measures to control those noxious weeds.

At the time of my inspection there were no obvious populations of noxious or invasive weeds such as
gorse, broom or ragwort.  The consent holder has provided an invoice showing a helicopter was used to
spray gorse on 27 February 2017. The Landfill Management Plan is silent with regard to recording the
instances of inspections for noxious weeds and the measures used to control them.  It is recommended
the consent holder amend the Landfill Management Plan to reflect this.  Comply – Full.

9

GENERAL  CONDITIONS  APPLICABLE  TO  DISCHARGE  PERMIT  6010  –
DISCHARGE LANDFILL LEACHATE ONTO AND INTO LAND
1.
Charges,  set  in  accordance  with  section  36(1)c  of  the  Resource  Management  Act  1991,  and
section 690 A of the Local Government  Act  1974, shall be paid to the Regional Council for  the
carrying out of its functions in relation to the administration, monitoring and supervision of this
resource  consent  and  for  the  carrying  out  of  its  functions  under  section  35  (duty  to  gather
information, monitor, and keep records) of the Act.

Note: Section 36(1)c of the Act provides that Council may from time to time fix charges payable
by holders of resource consents. The procedure for setting administrative charges is governed by
section 36(2)  of the Act  and  is  currently carried out  as  part  of the formulation of the Council’s
Annual Plan.
Not Assessed.

2.
Landfill leachate shall not contaminate adjoining land.

At the time of the inspections the leachate collection area at the toe of stage 3, the new bio-filter, the
leachate ponds and the periphery of stage 2 were inspected.  During the inspection on 12 May 2017 it
was raining.  The the stormwater drains along the internal haul roads and the outside of the litter nets
were inspected.  A leachate breakout was noted halfway along the eastern edge of stage 2.  This was
raised with HDC who took immediate measures to repair the capping and drain the leachate back into
the landfill.  Although leachate had escaped from the lined area of the landfill I could find no evidence
that leachate had escaped onto adjoining land or the stormwater system.  For the purpose of assessing
this condition adjoining land is considered to be adjoining properties outside the legal boundary of the
Landfill.

The consent holder shall ensure landfill cover is regularly inspected to prevent leachate breakouts.  It is
noted  that  the  Landfill  Leachate  Management  Plan  requires  onsite  staff  to  advise  the  Solid  Waste
Engineer  of  any  required  maintenance  of  problems  with  the  leachate  system  and  any  maintenance
preformed  shall  be  recorded  on  a  Daily  Inspection  Sheet  provided  under  Appendix  C  of  the  Landfill
Leachate  Management  Plan.    To  provide  assurance  and  achieve  full  compliance  with  this  condition  it
is recommended  that  completed  Daily  Inspection  Sheets  are  provided  to  HRC  for  review.
Comply – At Risk.
10

Figure 1 – Approximate location of leachate breakout on 12 May 2017.

11

GENERAL  CONDITIONS  APPLICABLE  TO  DISCHARGE  PERMIT  6011  –
DISCHARGE LANDFILL GAS, ODOUR AND DUST TO AIR
2.
The Permit Holder will ensure dust is controlled on access roads and on the landfill, if necessary,
by watering or other methods.

The  access  road  up  to  the  site  office  within  the  landfill  is  sealed.    The  main  access  roads  within  the
landfill are metaled.  During my site visits there had been recent rain which prevented dust generation.
HRC have not received any complaints in relation to dust from the landfill access roads.  Please ensure
access to a water truck is available in the event dust becomes an issue onsite. Comply – Full.

3.
There shall be no discharge of odour or dust from the landfill that in the opinion of a Regional
Council  Enforcement  Officer  is  noxious,  dangerous,  offensive,  or  objectionable  beyond  the
property boundary. The Permit Holder will also ensure that:

When deciding whether an odour is offensive or objectionable HRC enforcement officers must consider
the  frequency,  intensity,  duration,  offensiveness/character  and  location  of  an  odour  event.    These
parameters are known as the FIDOL factors and are described in Table 1 below.  Odour is monitored by
officers  using  odour  complaint  &  assessment  forms.    In  completing  these  forms  the  officer  uses  an
interval method, noting the odour intensity every 10 seconds for 10 minutes.  The officer will indicate
the hedonic tone of the odour and note the type of land use affected by the odour.  This information is
recorded  on  the  assessment  form  along  with  weather  information.    To  determine  the  frequency  and
duration of odour events an officer may request that an odour diary is kept by affected complainants.
This approach is consistent with best practice in assessing odour as per the Ministry for the Environment
Guidelines titled, “Good Practice Guide for Assessing and Monitoring Odour”, dated 2016.

Frequency
How often an individual is exposed to the odour.
Intensity
The strength of the odour. Measured on a scale of 0 to 6.
Duration
The length of exposure.
Offensiveness/character
The  character  relates  to  the  ‘hedonic  tone’  of  the  odour,  which  may  be
pleasant, neutral or unpleasant. On a scale of -4 (Extremely unpleasant) to
4 (Extremely pleasant).
Location
The  type  of  land  use  and  nature  of  human  activities  in  the  vicinity  of  an
odour source.
Table 1: Description of the FIDOL factors.

12

HRC has received a number of complaints in relation to odour from the Levin Landfill.  These complaints
have  primarily  been  from  a  complainant,  at  one  address,  who  shares  a  mutual  boundary  with  the
landfill.    To  assess  compliance  with  this  condition  HRC  has  worked  with  the  primary  complainant
requesting  they  keep  an  odour  diary.    A  review  of  this  odour  diary  shows  81  entries  between
6 February 2017 and 12 May 2017 this is summarised below in Figure 2.

Number of Complaints by week 6 Feb to 12 May 2017.
16
C 14
o 12
m
10
p
l
8
Number of Complaints
a
6
i
4
Linear (Number of
n
2
Complaints)
t
0
s
b
b
b
r
r
r
r
r
r
r
r

Fe-
Fe-
Fe-
Ma
Ma
Ap
Ap
Ap
Ap
Ap
-
Mar-
Ma-
-
-
-
2-
9-
May
12
19
26
5-
12
19
26
16
23
30
7-
Week Ending

Figure 2: Number of complaints by week 6 February – 12 May 2017.

In conjunction with this HRC consents monitoring officers have undertaken proactive and reactive odour
assessments  at  various  times  to  compare  with  the  odour  diary.  From  these  assessments  eight
completed  assessment  forms  are  available,  these  are  summarised  in  Table  2  below.    Of  these
assessments  there  were  five  occasions  where  odour  was  detected.    Of  these  five  occasions  one
assessment  concluded  that  odour  was  detected;  however,  the  officer  did  not  consider  it  would  be
objectionable  at  any  location  for  any  duration  or  frequency,  two  assessments  detected  odour  and
concluded  it  would  not  be  objectionable  unless  it  became  continuous  and  two  assessments  detected
odour and concluded it would be objectionable if it occurred on a regular or frequent basis.
13

Odour detected
Odour detected
Odour detected
and would be
Odour
Odour detected
not
and would be
objectionable if
Nature/Assessment
No Odour.
but not
objectionable
objectionable
Total
occurred
Type.
objectionable.
UNLESS
even in short
regularly or
continuous.
duration.
frequently.
Proactive
2
1
2
0
0
5
Assessment
Reactive
1
0
0
2
0
3
Assessment
Total
3
1
2
2
0
8
Table 2:  Results of odour assessment forms completed by HRC Consents Monitoring Officers 14 March
– 1 June 2017.

One  of  the  above  assessments,  undertaken  by  an  HRC  officer  on  the  evening  of  28  May  2017  at  the
complainants’ residence, noted land fill gas odour at a constant intensity of 1-2 out of 6.  This was for
the  duration  of  the  assessment,  which  was  20  minutes.    Despite  the  relative  low  intensity  the  officer
considered  the  odour  to  be  objectionable  because  of  its  tone  and  it’s  proximity  to  the  complainants’
residence.

Review of the primary complainants’ odour dairies from 6 February to 12 May 2017 show odour events
occurring on a frequent basis.  These events are typically in the 1-3 intensity range; however, there have
been several events in the 5-6 intensity range.

HRC’s  own  assessments  undertaken  at  the  primary  complainants’  address  have  demonstrated  the
presence of land fill gas odour that is, at times, objectionable and beyond the consented boundary of
the Levin landfill.  Review of the odour diaries kept by the primary complainant, whom HRC believe to
be  reasonable  people,  have  demonstrated  this  odour  is  occurring  on  a  regular  or  frequent  basis.    A
compliance  report  completed  by  HRC  on  9  February  2015  provided  a  Significant  Non  –  Compliance
grading for this condition based on odour diaries kept by the primary complainants.

After considering the  available information, that  includes  odour diaries  from the  primary complainant
and HRC’s own odour assessments, it is my opinion that during this assessment period odour from the
Landfill  has  been  objectionable  beyond  the  property  boundary.    Accordingly  a  Significant  Non  –
Compliance  grading  has  been  given  for  this  condition.    Also,  given  this  is  a  repeat  Significant  Non  –
Compliance grading the landfill has been graded as Significantly Non – Complying with resource consent
6011.  Significant Non-Compliance.

14

3a.
On-site  and  off-site  Health  and  Safety  Effects  of  landfill  gas  being  emitted  by  the  old  landfill
should be quantified by sampling groundwater monitoring wells for evidence of landfill gas when
groundwater  samples  are  taken  from  the  wells.    As  a  minimum,  the  gases  tested  for  are  to
include methane, carbon dioxide and oxygen; and

This data will be assessed by a subsequent compliance report covering the quarterly and comprehensive
reports.  Not Assessed.

3b
Any building constructed on the landfill site is adequately ventilated.
Not Assessed.

4.
There shall be no deliberate burning of waste or other material at the landfill.  If fires occur at
the landfill they shall be extinguished as quickly as possible.

Inspections of the landfill have shown no evidence that the burning of waste is occurring onsite.  There
have been no complaints received by HRC in relation to this.  Comply – Full.

5.
The  Permit  Holder  shall  take  all  practicable  steps  to  avoid,  remedy  or  mitigate  significant
adverse effects of the discharge of landfill gases to air.

As  previously  stated  by  this  report  HDC  has  been  through  a  review  for  the  conditions  of  the  Landfill
resource  consents.    Accordingly  HDC  has  undertaken  various  measures  to  avoid,  remedy  or  mitigate
significant adverse effects of the discharge of landfill gases to air; these measures include:

Construction of a bio-filter at the leachate sump collection area, which is now complete.

Construction  of  a  pipe  to  take  leachate  directly  to  trade  waste  by-passing  the  leachate  pond,
which is now complete.

A Windsor landfill gas flare is onsite and in the process of being commissioned, this is expected
to be complete in July.

Cover  on  the  batters  of  stage  2  is  being  improved  with  additional  clay  being  added  with
additional material being sourced via district roading projects as it becomes available.
As it appears to be silent in this regard it is recommended HDC update their Landfill Management Plan
to  incorporate  procedures  to  manage  and  monitor  the  landfill  gas  wells  and  flare  when  it  is  fully
commissioned,  to  optimise  LFG  capture  and  destruction.    A  means  of  surveying  the  Landfill  for  any
weaknesses/LFG breakouts in the capping layer should also be incorporated.  Comply – On Track.

15

6.
The Permit Holder shall keep a record of any complaints received.  The complaints record shall
include the following, where possible:
a.
Names and addresses of complainant;
b.
Nature of complaint;
c.
Date and time of the complaint and alleged event;
d.
Weather conditions at the time of the event; and
e.
Any action taken in response to the complaint.

The record shall be made available to the Regional Council on request.

The Permit Holder shall also keep a record of landfill gas monitoring results including:
a.
Date and time of sampling;
b.
The concentrations of gasses detected.
c.
Weather conditions at the time of sampling.

The monitoring results shall be made available to the Regional Council on a quarterly basis.

To determine compliance with this condition HRC requests that all records required by Condition 6(a) to
(e) covering this assessment period (6 February 2017 to 1 June 2017) held by HDC be provided prior to
30 June  2017.    All  monitoring  results  required  will  be  assessed  in  a  subsequent  compliance  report
following a review of the quarterly and comprehensive reports.  Not Assessed.

16

GENERAL  CONDITIONS  APPLICABLE  DISCHARGE  PERMIT  6012  DIVERT
STORMWATER FROM AROUND THE LEVIN LANDFILL
2.
Stormwater  run-off  contaminated  by  leachate  to  an  extent  that  it  may  cause  adverse
environmental effects shall be regarded as leachate.

During the 12 May 2017 site inspection a leachate breakout was detected along the stage 2 litter fence.
Leachate had been collected by stormwater as it ran off the clay capping and was contained in a small
area  of  ponding  immediately  adjacent  to  the  litter  fence.    Fortunately  the  area  of  ponding  was  not
flowing to the stormwater system preventing it from causing any adverse environmental effects.  HDC
were advised of the issue and the area of ponding was drained back into the landfill and bunding put in
place to prevent a re-occurrence.  Please ensure any diversion bunds and or drains on the operational
landfill cell are regularly inspected to prevent leachate out breaks.

HDC  is  requested  to  advise  by  30  June  2017  what  steps  it  will  take  to  ensure  this  is  appropriately
managed into the future.  Comply – At Risk.

3.
Stormwater falling on any operational cell shall be regarded as leachate.

Stages 2 and 3 are the current operational cells at the landfill.  Stormwater that falls on these areas is
captured  by  the  leachate  collection  system  and  treated  as  leachate  and  therefore  pumped  to  trade
waste.  Comply - Full.

4.
The  Permit  Holder  shall  carry  out  such  stormwater  or  sediment  control  measures  as  are
necessary  to  ensure  that  sediment  is  not  carried  and  deposited  beyond  the  boundaries  of  the
site.

During both site visits it was noted that all access roads were stabilised by aggregate or sealed and well
maintained.    The  other  potential  source  of  sediment  was  from  clay  capping  however  this  area  is
maintained  to  drain  back  into  the  landfill  cells  and  ultimately  be  collected  by  the  leachate  collection
system.    Any  stormwater  with  the  potential  to  leave  site  is  collected  by  stormwater  pond  1  which  is
situated in a natural dune depression.  Comply – Full.

17

5.
The Permit Holder shall ensure that:
A.
stormwater drains within the site are maintained to ensure that the flow of stormwater
around  the  landfill  is  unrestricted  and  the  potential  for  stormwater  contamination  is
reduced; and

As  discussed  above  during  the  second  visit  on  12  May  2017  I  detected  a  leachate  breakout  halfway
along the eastern edge of stage 2 which was mixing with ponded stormwater immediately adjacent to
the  landfill  cell.    Leachate  had  escaped  from  the  lined  area  of  the  landfill  no  evidence  was  found  to
indicate leachate had entered the stormwater system or had escaped onto adjoining land.

On this occasion contaminated stormwater did not leave the site however the breakout highlighted the
potential for stormwater contamination should contaminated stormwater enter the stormwater system.
For this reason a comply-at risk grading has been allocated for this condition.

Accordingly HDC are required to advise by 30 June 2017 what steps it will take to ensure this risk area is
actively managed to ensure compliance with this condition.  Comply – At Risk.

B.
stormwater diversion systems, including all drains and ponds, are kept clear of refuse ;
and

The  stormwater  drains  inspected  during  my  site  inspections  were  maintained  and  free  of  refuse.
Comply – Full.

C.
any sediment ponds are regularly cleaned to ensure effective settling out of suspended
solids.

Stormwater  pond  1  was  not  viewed  during  my  inspections.    When  a  timeline  is  provided  for
improvements to prevent leachate breakouts along the eastern edge of stage 2 a follow up inspection
will be scheduled and this area inspected.  Not Assessed.

18

GENERAL  CONDITIONS  APPLICABLE  DISCHARGE  PERMIT  102259  –
DISCHARGE  STORMWATER  TO  LAND  AND  POTENTIALLY  TO
GROUNDWATER VIA GROUND SOAKAGE
4.
All works and structures relating to this Discharge Permit shall be designed and constructed to
conform  to  best  engineering  practices  and  shall  at  all  times  be  maintained  to  a  safe  and
serviceable standard.

During  my  second  inspection  there  was  substantial  rain.    At  this  time  the  stormwater  drains  that  I
inspected were free of obstructions and ponding thereby indicating they are designed and maintained
to a serviceable standard.  Comply – Full.

5.
The  Permit  Holder  shall  ensure  that  the  stormwater  system,  including  all  drains  and  ponds,  is
kept clear of refuse at all times.

I  inspected  various  stormwater  drains  during  both  inspections  but  not  stormwater  pond  1;  therefore
this  condition  can  not  be  fully  assessed.    There  was  no  refuse  in  the  stormwater  drains  I  inspected.
Not Assessed.

6.
The  Permit  Holder  shall  ensure  the  stormwater  soakage  ponds  are  inspected  regularly  and
maintained  to  optimise  their  performance  at  all  times.    This  shall  include  de-sludging  or
remediating the ponds as required.

The stormwater management plan requires stormwater drains to be inspected not less than monthly;
however, it is silent with respect to maintenance of the stormwater soakage ponds.  It is recommended
that  the  management  plan  is  amended  to  include  this  information  and  maintenance  of  the  ponds  is
undertaken accordingly.  Not Assessed.

7.
There shall be no ponding in the stormwater soakage areas 12 hours after the last rain event.
Not Assessed

8.
There shall be no runoff or existing discharge of stormwater beyond the property boundary that
has originated on any landfill area or new lined landfill area that has had, or is intended to have,
refuse placed on it.

The  catchment  area  serviced  by  stormwater  pond  1  does  not  include  stormwater  from  stage  2  or  3.
Stormwater generated on these areas is collected by the leachate collection system.  Comply – Full.

19

9.
As  far  as  practically  possible,  the  Permit  Holder  shall  ensure  that  all  stormwater  from  the
existing landfill area is directed to a centralised soakage area to the south of the existing fill, as
shown on Plan C 102259.

Onsite  stormwater  drains  are  directed  along  the  internal  haul  roads  towards  stormwater  pond  1.
Comply – Full.

10.
Where  it  is  practical  and  economical  to  do  so,  the  Permit  Holder  shall  ensure  that  within  the
operational  landfill  cell  the  minimum  amount  of  stormwater  shall  be  allowed  to  come  into
contact  with  refuse.    This  shall  be  effected  by  constructing  impermeable  barriers,  diversion
drains or bunds on the side slopes and within the base of the landfill.

All stormwater that falls on the operational landfill is treated as leachate and collected by the leachate
collection system. For the purpose of compliance with this condition it is expected that diversion drains
and  bunds  are  constructed  to  ensure  stormwater  falling  on  any  operational  cell  stays  within  that
operational  cell  and  is  collected  by  the  leachate  collection  system;  this  is  addressed  by  Condition  11
below.  Not Assessed.

11.
There  shall  be  no  contamination  of  stormwater  with  leachate.    Leachate  includes  any
stormwater within an operational cell that is not separated from refuse by a barrier as defined in
Condition 10.

Due to the definition of leachate offered by Condition 3 in resource consent 6012, any stormwater that
falls  on  an  operational  cell  is  considered  leachate.    Therefore  in  the  event  stormwater  fell  on  an
operational  cell,  which  discharged  to  an  area  outside  the  cell,  this  would  be  considered  a  non
compliance with this condition.

Following the reasoning above, the observations made of a leachate breakout during my site inspection
on  12  May  2017  is  a  breach  of  this  condition  as  it  entered  clean  ponded  stormwater  adjacent  the
operational cell.  It is noted that HDC took immediate action to remediate this breakout and construct
diversion bunds to prevent a re-occurrence. It is also noted the scale of the breakout was small and the
effects  can  be  considered  less  than  minor  as  they  were  isolated  to  the  ponding  stormwater.
Consideration of these factors has resulted in a minor non-compliance grading having been issued for
this condition on this occasion.  Minor Non – Compliance.

12.
The Permit Holder shall ensure that a suitable stormwater soakage area is available for a given
design storm and the area of the operational cell from which the stormwater is collected.

All stormwater that currently falls on an operational cell is treated as leachate and is collected via the
leachate collection system.  Comply – Full.
20

13.
Areas designated for stormwater discharge to land and their catchment and reticulation system
shall  be  identified  and  located  on  site  plans  and  their  dimensions  submitted  for  approval  by
horizons.mw’s Team Leader Compliance prior to their use.

This  condition  has  previously  been  assessed  and  complied  with  therefore  has  not  applicable.
Not Applicable.

CONCLUSION
Two site inspections to the landfill have been completed by HRC Consents Monitoring Officers.  These
inspections  occurred  on  14  February  2017  and  12  May  2017  respectively  and  were  undertaken  to
determine  compliance  with  onsite  conditions  as  outlined  in  the  report  above.  As  a  result  of  these
assessments the landfill obtained the following Resource Consent compliance gradings overall, based on
the conditions assessed;

  Discharge Permit 6009 – discharge solid waste to land = Comply – Full.
  Discharge Permit 6010 – discharge landfill leachate onto and into land = Comply
  Discharge Permit 6012 – divert stormwater from around the Levin landfill = Compy
  Discharge  Permit  102259  –  discharge  stormwater  to  land  and  potentially  to  groundwater  via
ground soakage = Comply

Due  to  odour  complaints  received  by  HRC  in  relation  to  the  landfill  proactive  and  reactive  odour
assessments of the landfill have been undertaken. HRC has worked closely with a primary complainant
who  owns  a  property  with  a  mutual  boundary  to  the  landfill.  HRC  has  asked  that  the  primary
complainant  keep  an  odour  diary.  HRC  has  used  this  odour  diary  in  conjunction  with  its  own
assessments to determine the nature of the odour taking in to consideration the FIDOL factors, outlined
above  in  the  introduction  section  above.  After  careful  consideration  of  this  information  HRC  has
determined  that the  landfill  is  significantly  non-complying  with  condition 3  of  resource  consent 6011.
Due  to this condition having been previously significantly non  –  complied in a HRC compliance  report
dated  9  February  2015  the  effects  of  this  odour  can  be  considered  ongoing.  On  this  basis  the  landfill
following Resource Consent compliance grading overall;

  Discharge  Permit  6011  –  discharge  landfill  gas,  odour  and  dust  to  air  =  Significant  Non  -
Compliance
Please find attached a copy of Horizons Regional Council’s Compliance Assessment Guidelines for your
reference.

21

RECOMMENDATIONS:
It is recommended the consent holder undertake the following actions to ensure the landfill
complies with its resource consents;

Discharge Permit 6009 – discharge solid waste to land.
  The  Landfill  Management  Plan  is  silent  with  regard  to  recording  the  instances  of
any  inspections  for  the  presence  or  vermin,  birds  and  other  pests.  It  is
recommended  the  consent  holder  record  and  report  on  any  inspections  and  any
action taken, to achieve full compliance with condition 5.
  The  Landfill  Management  Plan  is  silent  with  regard  to  recording  the  instances  of
inspections  for  noxious  weeds  and  the  measures  used  to  control  them.  It  is
recommended the consent holder amend the Landfill Management Plan to reflect
this.
Discharge Permit 6010 – discharge landfill leachate onto and into land.
  To  provide  assurance  and  achieve  full  compliance  with  condition  2  it  is
recommended  that  completed  Daily  Inspection  Sheets  are  provided  to  HRC  for
review.
Discharge Permit 6012 – divert stormwater from around the Levin landfill.
  During the 12 May 2017 site inspection a leachate breakout was detected along the
stage 2 litter fence. Accordingly HDC is requested to advise by 30 June 2017 what
steps  it  will  take  to  ensure  this  is  appropriately  managed  into  the  future  and
maintain compliance with conditions 2 and 5.
Discharge  Permit  102259  –  discharge  stormwater  to  land  and  potentially  to  groundwater
via ground soakage.
  During a site inspection on 12 May 2017 a leachate breakout was noticed adjacent
to  the  litter  fence  along  the  eastern  edge  of  stage  2  (see  Figure  1).  As  discussed
above HDC is requested to advise by 30 June 2017 what steps it will take to ensure
this  is  appropriately  managed  into  the  future  and  prevent  further  non  –
compliance.

22

Discharge Permit 6011 – discharge landfill gas, odour and dust to air.
  It  is  recommended  HDC  update  their  Landfill  Management  Plan  to  incorporate
procedures  to  manage  and  monitor  the  landfill  gas  wells  and  flare,  when  fully
commissioned, to optimise LFG capture and destruction. A means of surveying the
Landfill  for  any  weaknesses/LFG  breakouts  in  the  capping  layer  should  also  be
incorporated and regularly undertaken to ensure compliance with condition 5.
  To determine compliance with condition 6 HRC requests that all records required
by condition 6(a) to (e) covering this assessment period (6 February to 1 June 2017)
held by HDC be provided prior to 30 June 2017.

If you have any queries about the attached report, please contact me on 0508 800 800

Kind regards,

Hamish Sutherland
SENIOR CONSENTS MONITORING OFFICER
23

Table 1.  Compliance Assessment Guideline for Individual Consents
Site Compliance
Examples
Grade
Comply - Exceeds
  Consent holder has implemented practices, procedures, systems that are over and above that required by the resource
consent or consents for the site which are having a tangible environmental benefit.
Comply - Full
  Complying with all conditions of consent; and/or
  A non-compliance has occurred beyond the control of the consent holder; and/or
Comply
  One Minor Non-Compliance with a condition of the resource consent.
Comply – At Risk
  At Risk grading identified against key condition(s) of one or more of consents for the site.
Comply – On Track
  At risk grading identified AND site has entered into a Compliance Pathway Agreement (CPA) to reduce system risks and
achieve best practice.
Non-Compliance
  There have been two ‘first time’ Non -Compliances with the conditions of consent; and/or
  There has been one repeat Minor Non-Compliance with the same or similar condition.
Significant
Non-   There has been at least one Significant Non-Compliance Rating with a condition; and/or
Compliance
  There has been at least two repeat Non- Compliance Ratings associated with the same or similar condition; and/or
  There have been three or more ‘first time’ Non Compliance Ratings.
Not assessed
  Monitoring has not been undertaken of this consent during the reporting period.

Table 2.  Compliance Assessment Guideline for Individual Conditions
Condition

Compliance
Adverse Effects Scale
Examples (not exhaustive)
Grade

Consent holder has implemented practices, systems, and procedures
Comply
–
Nil.
that are over and above that required by the resource consent and
Excellent
are having tangible environmental benefit.
Conditions of consent are fully complied with.
Comply - Full
Nil.
Sampling  out  of  sequence  or  late  due  to  circumstances  outside  of
consent holders control (e.g. flow related sampling).
Nil – de-minimus.
(dictionary: de-minimus - need not  Compliant  at  time  of  inspection  but  management  /  system
be  considered.    In  terms  of  the  deficiencies  indicate  there  is  a  real  risk  of  a  non-compliance
Comply – At Risk
RMA  the  term  means  an  effect  occurring  (e.g.  insufficient  effluent  storage,  poor  irrigator
which  is  less  than  minor,  of  no  performance).
consequence,  so  trifling  that  it
should be disregarded).
System  has  been  identified  as  At  Risk,  but  the  consent  holder  has
Comply
–
On
agreed  to  enter  into  a  Compliance  Pathway  Agreement  (CPA)  to
Nil – de-minimus.
Track
ensure  compliance  is  consistently  achieved.    Consent  holder  is
currently complying with conditions of consent.
One-off  failure  to  comply  with  a  condition  of  consent  (e.g.  One  off
minor exceedance in key parameter in 6-months worth of sampling
(allows for two minor exceedances in a 12-month period).
Minor
Non-
Intent of condition met however data and / or report provided late
De-minimus to less than minor.
Compliance
(no later than 6 weeks).
First up failure to install a water meter for a small take (stockwater),
provide management plan or environmental information (e.g. water
quality information) within required timeframes.
More than minor and / or ongoing  Four minor exceedances of key parametres for one year’s worth of
(dictionary:  defines  ‘minor’  as  sampling / data.
lesser  or  comparatively  small  in  Repeat failure to provide a report or monitoring data.
Non - Compliance
size or importance).
Repeat Failure to undertaken sampling.
Ongoing (dictionary: continuing to  Failure  to  install  water  meter  for  a  more  than  minor  take  (e.g.
exist).
irrigation).
Water  quality  results  indicate  there  is  a  potential  for  or  an  actual
More  than  minor  to  significant,  effect  which  is  more  than  minor  that  is  not  authorised  by  the
serious and / or ongoing.
resource consent.
Significant  (dictionary:  important,  Unauthorised discharge of wastewater / effluent into water or onto
noteworthy, consequential).
land where it may enter water, excessive ponding of effluent on the
Significant  Non-
Serious  (dictionary:  important,  land surface.
Compliance
demanding  consideration,  not  Repeated failure to provide a report/monitoring data/ management
slight).
plans/install water metering equipment etc.
Ongoing:  (dictionary:  continuing  Repeated failure to undertake sampling.
to exist).
Repeated failure to comply with authorised discharge or water take
volumes.
Applies to conditions that are no longer applicable.  Generally relates
to  historic  conditions  that  may  require  provision  of  a  management
Not Applicable

plan,  which  has  been  provided  and  consent  requires  no  further
action.
Not Assessed

Monitoring not undertaken of consent condition.