G. Fred Lee

G. Fred Lee & Associates · www.gfredlee.com

This report presents a review of the information available pertinent to public health and environmental quality protection issues for proposed and existing Subtitle D solid waste landfills. Based on this review it is concluded that this type of landfill will at most locations cause groundwater pollution by landfill leachate and be adverse to the he...

This review • announces our recent update of our Technical Review report, “Flawed Technology of Subtitle D Landfilling of Municipal Solid Waste,” (Lee and Jones-Lee, 2021 – http://www.gfredlee.com/SubtitleDFlawedTechnPap.pdf) that addresses issues of landfill composition, pollution potential, and inevitable environmental pollution; key deficiencies...

This review • announces our recent update of our Technical Review report, “Flawed Technology of Subtitle D Landfilling of Municipal Solid Waste,” (Lee and Jones-Lee, 2021 – http://www.gfredlee.com/SubtitleDFlawedTechnPap.pdf) that addresses issues of landfill composition, pollution potential, and inevitable environmental pollution; key deficiencies...

Abstract This report presents a review of the information available pertinent to public health and environmental quality protection issues for proposed and existing Subtitle D landfills. Based on this review it is concluded that this type of landfill will at most locations cause groundwater pollution by landfill leachate and be adverse to the healt...

On June 18, 2015, the US EPA broadcast a webinar, " Advancing Sustainable Materials Management: Facts and Figures 2013, " during which results of its review of trends in the generation, recycling, and disposal of municipal solid waste (MSW) in the US in 2012 and 2013 were presented. It was announced that the webinar presentations will soon be poste...

Available at: http://www.gfredlee.com/Landfills/Comments_Ash_SubtitleD_Landfill.pdf Introduction This letter is sent in response to your request for a letter for inclusion in your comment notebook concerning potential public health, water quality, and other impacts of the proposed disposal of electric generation coal combustion ash in former clay m...

Those who generate solid waste should be required to pay for the full costs of proper, reliable and protective management of that waste as part of their garbage disposal fees. Sufficient funds need to be collected and placed in a dedicated trust fund that could be used only for post-post-closure plausible worst case care needs for as long as the wa...

Ultimately, hundreds of billions of dollars of public and private funds will be spent in the US in hazardous chemical site (Superfund and closed RCRA facilities) investigation and remediation. A critical review of the adequacy of remediation of many of these sites that are “closed ” in accord with RCRA and/or CERCLA requirements as being interprete...

A simplified chlorophyll analytical procedure is described that requires 4 min/sample and features an overall precision (measured by the coefficient of variation, C.V.) of ~ 3% at the 15 mg/m3 chlorophyll a level. The C.V. varies inversely with concentration for spectrophotometric determinations. The molar extinction coefficients (665 nm) for chlor...

Deficiencies in design and execution render stormwater-runoff monitoring programs for many hazardous chemical sites inadequate for assessing the potential environmental quality and public health impacts of chemicals in the runoff. Two pervasive problems are the use of analytical methods that are inadequate for measuring certain hazardous chemicals...

Stormwater runoff from the University of California, Davis/U.S. Department of Energy Laboratory for Energy-Related Health Research (UCD/US DOE LEHR) Superfund site located on the University of California campus in Davis, California, has been found to contain over 500 ng/L of total recoverable mercury, which is about ten times the California Toxics...

The ability of municipal solid waste (MSW) landfills’ engineered waste containment systems to prevent pollution of groundwater by chemicals that leach from such waste, for as long as the wastes can generate leachate, is of great concern to those who use, or otherwise desire to protect the quality of groundwater near landfills. Significant technical...

The Muggah Creek estuary in Sydney, Nova Scotia, received liquid and solid wastes from a steel mill and its associated coke ovens for approximately 100 years. This resulted in pollution of soils and sediments with polycyclic aromatic hydrocarbons (PAHs), polychlorinated biphenyls (PCBs), heavy metals, and other pollutants, including those in untrea...

The California Central Valley is a highly productive irrigated agricultural area. The San Joaquin River (SJR) in the Central Valley has 12 violations of water quality objectives (WQOs) (standards) that have caused the Central Valley Regional Water Quality Control Board to develop total maximum daily loads (TMDLs) to control the WQO violations. Nine...

This report presents a review of the information available pertinent to public health and environmental quality protection issues for proposed Subtitle D landfills. Based on this review it is concluded that this type of landfill will at most locations cause groundwater pollution by landfill leachate and be adverse to the health, welfare and interes...

Aquatic sediments often contain a large number of chemical contaminants that are potential pollutants. It is often presumed that such contaminants are released to the water column during sediment resuspension and, in there, adversely impact aquatic life and other beneficial uses of the water. However, extensive laboratory and field studies of about...

Urban creeks and lakes can be important habitats for a variety of aquatic life, as well as an aesthetic resource to communities. A key component of this resource is the quality of water in these waterbodies. This paper is devoted to a review of water quality problems in urban creeks and lakes associated with stormwater ,runoff and other urban sourc...

Ph.D., P.E., and Ph.D., respectively, G. Fred Lee & Associates, 27298 East El Macero Drive, El Macero, California 95618.

Urban stormwater runoff contains heavy metals including copper, lead, and zinc; organics such as pesticides, PAHs, and unidentified compounds; and nutrients (nitrogen and phosphorus) in concentrations that are a threat to cause water quality problems in the waters receiving the runoff. In 1990 the US EPA adopted an urban stormwater runoff water qua...

Excessive fertilization (eutrophication) of lakes and reservoirs is recognized as one of the most important causes of water quality impairment of lakes, reservoirs, and some streams, rivers, and nearshore marine waters. Driven by excessive input of nitrogen and phosphorus, eutrophication is characterized by the presence of sufficient planktonic and...

About 500 million yd3 of sediment are dredged annually to maintain navigation depth in the US's approximately 25,000 miles of navigable waterways. Sediments in some of these waterways are contaminated with potential pollutants (e.g., heavy metals, organics including pesticides, PCBs, nutrients) from municipal, industrial, and agricultural sources....

The Clean Water Act (PL 92–500, the 1972 amendments to the Federal Water Pollution Control Act) established a water quality standards-based approach for regulating water quality. The U.S. EPA was to develop national water quality criteria that would serve as the basis for state water quality standards. Those standards are the legally enforceable li...

The US water pollution control program focuses on the current 126 Priority Pollutants originally selected without peer review in the mid-1970s through a litigation settlement. That notwithstanding, they remain the focal point of water quality investigations. Limited attention is given to the many thousands of potential pollutants that are in munici...

When municipal solid waste (MSW) comes in contact with liquid, leachate is formed. Such leachate contains a myriad hazardous and otherwise deleterious chemicals which if introduced into groundwater would impair or destroy the ability to use the groundwater and aquifer. In an attempt to provide some protection of groundwater quality from adverse imp...

A disturbing trend among governmental agencies is the remediation of so-called “nonhazardous” contaminated sediments/soils by deposition in minimum-design Subtitle D municipal solid waste (MSW) landfills or landfills with equivalent design. This is done despite the fact that, in terms of protection of public health and environmental quality, the de...

Municipal solid waste landfills are notorious for having adverse impacts on those within their sphere of influence during the active life of the landfill (the period of time that wastes are received by the landfill). This situation leads to a justified NIMBY (“not in my backyard”) attitude on the part of the public. Lee and Jones-Lee (2005), in the...

The current State Water Resources Control Board (SWRCB) review of water rights (water flow management) in the San Joaquin River (SJR) and the Delta is developing an update of water management policies and its impact on water quality/beneficial uses of the Delta and its tributaries. Over the past 16 years that we have been involved in water quality...

Many Superfund/hazardous chemical sites include waterbodies whose sediments contain hazardous chemicals. With the need to assess, rank, and remediate contaminated sediments at such sites, as well as in other waterways, regulators seek a simple, quantitative assessment approach that feeds easily into a decision-making scheme. Numeric, co-occurrence-...

The US water pollution control program focuses on the current 126 Priority Pollutants originally selected without peer review in the mid-1970s through a litigation settlement. That notwithstanding, they remain the focal point of water quality investigations. Limited attention is given to the many thousands of potential pollutants that are in munici...

There is increasing support for the use of a best professional judgment, non-numeric, triad weight of evidence approach for evaluating aquatic sediment quality. This approach is based on an integrated use of sediment toxicity/source of bioaccumulatable chemicals, organism assemblages and chemical information to determine the potential for constitue...

This article discusses the appropriateness of using landfills as part of remediating hazardous chemical and Superfund sites, with particular emphasis on providing for true long-term public health and environmental protection from the wastes and contaminated soils that are placed in the landfills. On-site landfilling or capping of existing wastes is...

A discussion of some of the deficiencies of Superfund and hazardous chemical site investigation and remediation is presented. Of concern is the adequacy of defining the constituents of concern; stormwater-runoff monitoring; evaluating excessive bioaccumulation of hazardous chemicals in edible organisms; the extent and degree of groundwater pollutio...

In 1999 the US EPA added the Lava Cap Mine area to the National Priority List (NPL) Superfund sites. This site is a former gold and silver mine located in Nevada County, California, near Nevada City. The area is a Sierra-Nevada foothill wooded area, with low-density residential development. A risk assessment shows that there are significant potenti...

The excessive fertilization (eutrophication) of waterbodies is recognized as one of the major causes of the impairment of the beneficial uses of waters through the growth of excessive amounts of aquatic plants such as algae and water weeds. Agricultural land use has been found to be an important source of N and P compounds leading to excessive fert...

The Winter 2001 IEP Newsletter contained an article by Lee and Jones-Lee (2001) describing some of the major issues in developing the San Joaquin River (SJR) Deep Water Ship Channel (DWSC) Dissolved Oxygen (DO) TMDL. The following is a brief summary of some of the major findings from a CALFED-funded review of 1999-2003 studies (Lee and Jones-Lee 20...

Historically, municipal solid waste disposal has been conducted by disposal on low-value lands where the wastes were burned in open pits. Beginning in the 1950s, in some more developed areas, the landfilling of municipal and industrial wastes occurred in "sanitary" landfills. Sanitary landfills differed from the open-pit burning and disposal since...

Excessive fertilization is one of the most common and significant causes of the impairment of the beneficial uses of waterbodies. As a result of the widespread occurrence of excessive fertilization of waterbodies, the US EPA has initiated development of chemical-specific (nitrogen and phosphorus compounds) numeric water quality criteria designed to...

There is a resurgence of interest in controlling the excessive fertilization (eutrophication) of surface waters in order to protect domestic water supplies and other beneficial uses of waters from impairment (pollution) by excessive growths of algae or other aquatic plants whose growth is stimulated by nitrogen and phosphorus. An area of particular...

Presentation Slides

An essential step in achieving effective local and national stormwater runoff water-quality management programs is developing technically valid approaches for assessing the water-quality significance of chemical constituents and pathogens in urban runoff. But are we measuring the right things? And are the BMPs we currently use actually protecting w...

Urban stormwater runoff in several municipalities in California has been found to be toxic to Ceriodaphnia dubia. This toxicity is due to residential use of the organophosphate (OP) pesticides, diazinon and chlorpyrifos, for termite, ant, lawn and garden pest control. This toxicity has caused regulatory agencies to list the receiving waters for the...

Studies on NPDES-permitted urban area and highway stormwater runoff have shown that the total and dissolved concentrations of several heavy metals — copper, lead, zinc, and frequently cadmium — are present in the runoff waters above US EPA worst case-based national water quality criteria. This situation can lead to violations of water quality stand...

There is considerable interest today in the so-called "biocell" approach toward municipal solid waste (MSW) landfilling in which leachate is introduced back into the landfill. This approach reduces the cost of leachate management and is said to reduce/eliminate the potential for long term landfill gas production and groundwater pollution. However,...

There is considerable misinformation on the public health and environmental benefits of the reduction, reuse and recycling (3Rs) of municipal solid wastes. This situation arises from the publication of several popular press articles that claim that there are no environmental benefits of practicing the 3Rs. The June 30, 1996 New York Times Magazine...

The finding of widespread urban stormwater runoff aquatic life toxicity and the listing of waterbodies experiencing this toxicity as 303(d) listed impaired waterbodies has established the total maximum daily load (TMDL) process to control this toxicity in several areas of California. Since the toxicity is typically associated with the organophospha...

Common deficiencies in the typical evaluation of the surface water quality impacts of hazardous chemical sites are discussed. Particular attention is given to deficiencies in monitoring stormwater runoff, as well as the input of contaminated groundwaters that lead to impairment of the beneficial uses of nearby surface waters because of site-derived...

Shipyards' and drydocks' (SYDD) wastewater discharges and stormwater runoff are currently being regulated to control the concentrations of chemical constituents in the discharges/runoff. The regulatory approach typically being used is based on worst-case assessments of the potential impacts of chemical constituents in the discharge/runoff as it may...

Stormwater runoff in San Diego Creek, the primary tributary to Upper Newport Bay in Orange County, CA, has been found to be toxic to Ceriodaphnia and Mysidopsis with total acute 24 hr toxicities up to 16 TUa. About half of this toxicity has been found to be due to the organophosphate (OP) pesticides diazinon and chlorpyrifos used in urban areas for...

The deficiencies in the typical stormwater runoff water quality monitoring from hazardous chemical sites and an alternative approach (Evaluation Monitoring) for monitoring that shifts the monitoring program from periodic sampling and analysis of stormwater runoff for a suite of chemical parameters to examining the receiving waters to determine what...

The capping of waste management units and contaminated soils is receiving increasing attention as a low-cost method for hazardous chemical site remediation. Capping is used to prevent further groundwater pollution by existing waste management units and contaminated soils through limiting the moisture that enters the wastes. In principle, for wastes...

The problems with current stormwater runoff water quality monitoring programs are discussed, along with several suggestions of alternative monitoring approaches. Specific examples used were experiences gained from the San Francisco Bay and Santa Monica Bay monitoring studies.

The third and final article in a series addressing urban stormwater runoff deals with such issues as monitoring and modelling, highway runoff, classification of stormwater sediments as hazardous wastes, and the significance of aquatic plant nutrients and aquatic life toxicity testing. The first two articles, which appeared in the March and April is...

The need to regulate stormwater runoff differently from municipal and industrial wastewater is addressed. It is of utmost importance to distinguish clearly between pollutants and non-pollutants in developing stormwater runoff management programs. The evaluation of best management practices (BMPs) in achieving maximum extent practicable (MEP) should...

Issues to be considered in the implementation of urban stormwater runoff quality management regulations are examined. Several evolving concepts that recognize the need for different regulatory approaches are discussed. The regulation of chemical constituents in sediments associated with stormwater runoff is also examined. The Santa Monica Bay Resto...

The Environmental Protection Agency's groundwater monitoring program, ostensibly designed to detect failure of land fill liners for Subtitle C (hazardous waste) and Subtitle D (municipal solid waste) waste management facilities, does not support reliable early detection of groundwater pollution. A significantly different approach is needed to addre...

The basic question is related to practicality and cost-effectiveness--that is, are the structural stormwater control devices being installed in many areas of the country actually doing the job for which they are designed? Public works directors for many cites and counties, and stormwater management agencies are involved in developing programs desig...

A solid waste management crisis exists in many parts of the US as a result of the inability to site new landfills to replace the consumed capacity of existing landfills. Municipal solid waste (MSW) landfills can, and usually do, have a significant adverse impact on the individuals who own property in, reside in, or otherwise use, areas near the lan...

Abstract Lake Tahoe, California-Nevada, one of the most oligotrophic lakes in the world, is experiencing decreased water clarity and increased periphyton growth, and water supplies drawing from the lake are experiencing increased algal-related tastes and odors. The growth of algae in Lake Tahoe is primarily limited by the nitrogen (nitrate and ammo...

Water pollutio~ conuol agencies are implementing control programs for chemical contaminants in urban stormwater runoff because concenwations of total forms o~" some contaminants in receiving water exc~d numeric war~-quality standattis. While some assert that stormwamr-associamd contaminants am canning water q,a~ity problems (impairment of beneficia...

Municipal solid waste landfill leachate contains a wide variety of hazardous chemicals, conventional contaminants, and non-conventional contaminants. Contamination of groundwater by such leachate renders it and the associated aquifer unreliable for domestic water supply and other uses; "remediation" treatment does not restore their quality. Focus m...

During the austral summer of 1980-1981, a study was undertaken on the applicability of the Vollenweider-Organization for Economic Cooperation and Development (OECD) phosphorus loading-eutrophication response relationships to Lake Vanda, a permanently ice-covered, meromictic lake located in the Wright Valley of Antarctica. The Vollenweider-OECD empi...

In November 1990 the US EPA issued regulations for the control of contaminants in urban and industrial stormwater runoff. Some municipalities have already developed NPDES permits that require that water quality standards (often equal to US EPA criteria) be met at the edge of the mixing zones for those discharges. However, US EPA water quality crite...

The evaluation of the water quality hazard that contaminants associated with aquatic sediments represent is of considerable interest in many aspects of water pollution control. While it has been known for many years that contaminants associated with particulate matter in natural water may have limited adverse impact on fish and aquatic life-related...

The Vollenweider-OECD eutrophication model has been expanded to approximately 400 lakes. It is possible to make a quantitative prediction of the effects of a detergent phosphate ban and thereby to ascertain the potential benefits of such a ban. In order to assess the effect of a detergent phosphate ban on water quality it is necessary to know the p...

Mn, Fe, Cu, and Cd concentrations are reported for Lake Vanda, a closed-basin, meromictic, Antarctic lake and for its single major inflow, the Onyx River. Trace metal distributions in the upper lake and annual metal fluxes from the Onyx River were used to estimate chemical residence times in the mixed zone above the chemocline. Residence times, bas...

The Vollenweider-OECD eutrophication modeling approach has been demonstrated to be one of the most useful, versatile, and straightforward for assessing impacts of changes in nutrient load from various sources on eutrophication-related water quality of lakes, reservoirs, estuarine, and some riverine systems. This paper provides an overview of advanc...

Leachate recycle is a potentially useful tool that municipalities should consider for increasing the rate of stabilization of sanitary landfills and as a method of partial leachate treatment and disposal. Caution must be exercised, however, to ensure that leachate recycle does not result in increased surface water contamination, and especially grou...

In response to an article by R.K. Raman in an earlier issue (”Controlling Algae in Water Supply Impoundments,” Journal AWWA, August, 1985), the authors of this letter-to-the-editor state that Raman has failed to discuss the most important method for controlling algae in water supply reservoirs. According to the authors, this method is the limiting...

Research was conducted to 1) review current information on the availability of phosphorus derived from off-lake point and nonpoint sources for phytoplankton growth in receiving water bodies, 2) present eutrophication management strategies with respect to phosphorus control, and 3) provide guidance on approaches that should be used to develop update...

This discussion questions the safety and adequacy of clay-lined disposal pits for containing the migration of leachates from hazardous wastes into groundwater systems. The authors advocate pretreating all hazardous wastes prior to disposal to detoxify them to the maximum extent possible. Heavy metal wastes should be segregated and immobilized by fi...

In the early 1970's, under the auspices of the Organization for Economic Cooperation and Development (OECD), a Cooperative Programme on Eutrophication was initiated to quantify relationships between nutrient loads to waterbodies and their eutrophication-related water quality responses. This project included a five-year study of about 200 lakes and...