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EPA Says All Landfills Leak, Even Those Using Best Available Liners



This article quotes, and provides context for, statements by U.S. Environmental Protection Agency (EPA), published in the Federal Register in the early 1980s, acknowledging that all landfills -- including those using the best available construction materials and techniques -- will eventually leak, allowing their contents (whether municipal solid waste or legally hazardous waste) to enter the local environment.
August 10, 1987
By Peter Montague
People who are enthusiastic about garbage
incinerators often fail to mention that every
incinerator has a landfill associated with it.
The ash left over from incineration needs to
be landfilled, and the ash is toxic. Some en-
gineers (especially those employed to pro-
mote garbage incinerators) try to argue that
the toxic constituents of the ash will remain
safely in the landfill "forever." But this is a
flawed view: the weight of evidence and
opinion in the technical world does not
agree with this argument. On the contrary,
even the U.S. Environmental Protection
Agency says that all landfills will leak. The
agency has published this opinion on many
occasions in the Federal Register. But be-
fore we look at the EPA's [U.S. Environ-
mental Protection Agency] reasons for be-
lieving all landfills will leak, let's look at the
way landfills are constructed:
A landfill is a carefully-engineered depres-
sion in the ground (or built on top of the
ground, resembling a football stadium) into
which wastes are put. The intention is to
avoid any hydraulic [water-related] connec-
tion between the wastes and the natural en-
vironment. To achieve this goal, there are
four important parts of all landfills: a bot-
tom liner, a leachate collection system, a
cover, and the natural hydrogeologic setting
(the earth).
The hydrogeologic setting can be selected
to slow the entry of wastes into the natural
environment. The other three components
must be engineered. The bottom liner can
be one or more layers of clay or a synthetic
flexible membrane liner [FML], for exam-
ple, a sheet of plastic; the liner effectively
creates a bathtub in the ground. The leach-
ate collection system consists of sloping the
sides of the landfill and putting pipes in the
lowest places, to pump out contaminated
water and other fluids (leachate) as they ac-
cumulate; the pumped leachate is treated at
a wastewater treatment plant (and the solids
removed from the leachate during this step
are returned to the landfill, or are sent to
some other landfill). The cover or cap will
consist of several sloped layers of clay or
FML (to prevent rain from intruding), over-
lain by a very permeable layer of sandy or
gravely soil, overlain by topsoil in which
vegetation can root (to stabilize the under-
lying layers of the cap).
Each of these components is critical to suc-
cess. If the bottom liner fails, wastes will
migrate directly into the environment. If
leachate collection pipes clog up and leach-
ate remains in the landfill, fluids can build
up in the bathtub; the resulting liquid pres-
sure becomes the main force driving waste
out the bottom of the landfill when the bot-
tom liner fails. If the cover (cap) is not
maintained, rain will enter the landfill, re-
sulting in buildup of leachate to the point
where the bathtub overflows its sides and
wastes enter the environment.
In the Federal Register Feb. 5, 1981, the
EPA first stated its opinion that all landfills
will eventually leak:
"There is good theoretical and empirical ev-
idence that the hazardous constituents that
are placed in land disposal facilities very
likely will migrate from the facility into the
broader environment. This may occur sev-
eral years, even many decades, after place-
ment of the waste in the facility, but data
and scientific prediction indicate that, in
most cases, even with the application of
best available land disposal technology, it
will occur eventually." [pg. 11128]
"Manmade permeable materials that might
be used for liners or covers (e.g., membrane
liners or other materials) are subject to
eventual deterioration, and although this
might not occur for 10, 20 or more years, it
eventually occurs and, when it does, leach-
ate will migrate out of the facility." [pg.
"Unfortunately, at the present time, it is not
technologically and institutionally possible
to contain wastes and constituents forever
or for the long time periods that may be nec-
essary to allow adequate degradation to be
achieved." [pg. 11129]
"Consequently, the regulation of hazardous
waste land disposal facilities must proceed
from the assumption that migration of haz-
ardous wastes and their constituents and by-
products from a land disposal facility will
inevitably occur." [pg. 11129]
More than a year later, on July 26, 1982, the
EPA again put its opinions into the Federal
Register, emphasizing that all landfills will
inevitably leak:
"A liner is a barrier technology that pre-
vents or greatly restricts migration of liq-
uids into the ground. No liner, however, can
keep all liquids out of the ground for all
time. Eventually liners will either degrade,
tear, or crack and will allow liquids to mi-
grate out of the unit." [pg. 32284]
"Some have argued that liners are devices
that provide a perpetual seal against any mi-
gration from a waste management unit.
EPA has concluded that the more reasona-
ble assumption, based on what is known
about the pressures placed on liners over
time, is that any liner will begin to leak
eventually." [pgs. 32284-32285].
In the Federal Register May 26, 1981, pgs.
28314 through 28328), the EPA argued
forcefully that all landfills will eventually
leak. Another EPA quote:
"Many organic constituents are stable (de-
grade very slowly); other hazardous constit-
uents (e.g., toxic metals) never degrade. Yet
the existing technology for disposing of
hazardous wastes on or in the land cannot
confidently isolate these wastes from the
environment forever.
"Since disposing of hazardous wastes in or
on the land inevitable [inevitably?] results
in the release of hazardous constituents to
the environment at some time, any land dis-
posal facility creates some risk." [pg.
EPA went on to estimate that the duration
of the hazard from a landfill would be
"many thousands of years." [pg. 28315]
And the Agency said, "The longer one
wishes to contain waste, the more difficult
the task becomes.
Synthetic liners and caps will degrade; soil
liners and caps may erode and crack. ...EPA
is not aware of any field data showing suc-
cessful long-term containment of waste at
facilities which have not been maintained
over time." [pg. 28324]
"Ultimately, waste reduction and resource
recovery probably provide the best alterna-
tive to land disposal," said the EPA [pg.
28325], though it has never begun any pro-
grams to make this happen.
One thousand issues of Rachel’s News (under slightly varying names, such as Rachel’s Envi-
ronment & Health News or Rachel’s Democracy & Health News) were published between
1986 and 2009 by Environmental Research Foundation, located at different times in Princeton,
N.J., Washington, D.C., Annapolis, Md., and New Brunswick, N.J. Unless otherwise noted,
all were written by Peter Montague, editor. Many back issues are available at
Technical Report
Full-text available
Nos termos da Lei nº 20/99 de 15 de Abril e do Decreto-lei nº 120/99 de 16 de Abril compete à “Comissão Científica Independente para o Tratamento de Resíduos Industriais Perigosos”, ou na designação do citado decreto-lei “Comissão Científica Independente de Controlo e Fiscalização Ambiental da Co-Incineração”, adiante designada por CCI, dar parecer sobre o tratamento de Resíduos Industriais Perigosos (RIP) e, numa primeira fase, pronunciar-se igualmente sobre a implementação da co-incineração de resíduos industriais perigosos. Na Introdução ao seu relatório a CCI pretende expor as linhas orientadoras que presidem à organização do seu trabalho e apresentar a terminologia relevante, e dados gerais de enquadramento no panorama europeu sobre o tratamento de resíduos.
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