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Evaluating Potential Impacts of Landfills & Landfill Pollution:
Flawed Technology of Subtitle D Landfilling of Municipal Solid Waste
G. Fred Lee, PhD, PE, BCEES, F.ASCE and Anne Jones-Lee, PhD
G. Fred Lee & Associates
27298 E. El Macero Drive, El Macero, CA 95618
www.gfredlee.com
gfredlee33@gmail.com
(530)753-9630
Updated Jan (2021)
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 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 health, welfare and interests
of nearby residents and property owners/users. As discussed, there is normally significant
justification for those near a proposed Subtitle D landfill to oppose the development of the
landfill and the existence of an operating Subtitle D landfill.
Typically landfilling regulations require that,
(a)
the solid waste facility shall not pose a substantial endangerment to public health or safety
or the environment;
(b)
the solid waste facility shall not cause an environmental nuisance.
Frequently in review of a proposed landfill, the regulatory agency staff does not adequately or
reliably evaluate the potential for a proposed landfill to endanger public health, safety and the
environment, and cause nuisance on adjacent properties.
Subtitle D landfills have the potential to generate leachate (garbage juice) that will pollute
groundwater with hazardous and deleterious chemicals that are a threat to human health and the
environment for thousands of years. These landfills have the potential to generate landfill gas
that will contain hazardous and obnoxious chemicals for a long period of time well beyond the
current minimum 30-year funded postclosure period. Specific deficiencies in the siting, design,
operation, closure and postclosure care provisions for Subtitle D landfills include:
•
a single composite landfill liner that will eventually fail to prevent leachate pollution of
groundwater,
•
a landfill cover that will eventually allow rainfall to enter the landfilled wastes which will
generate leachate that will pollute groundwater,
•
a grossly inadequate groundwater monitoring system that has a low probability of
detecting leachate-polluted groundwater before it leaves the landfill owner’s property,
•
inadequate postclosure funding for landfill monitoring, maintenance and remediation of
polluted groundwater for as long as the wastes in the landfill will be a threat,
•
inadequate buffer lands between where wastes will be deposited and adjacent properties,
which will result in adverse impacts on nearby property owners/users from landfill releases,
including odors, dust, vermin, and noise and lights from night time landfill activities,
•
decreased property values for owners of nearby properties.
In addition, at some locations there is an environmental justice issue associated with the
development of a landfill that will be adverse to minority communities.
iv
Table of Contents
Abstract
................................................................................................................................... i
Table of Contents
..................................................................................................................................... ii
Tables and Figures
................................................................................................................................. iv
Acronyms and Definitions
............................................................................................................................v
Overview of Landfilling Regulations
.................................................................................................. 1
Qualifications to Provide Comments
................................................................................................... 2
Evolution of Subtitle D Landfills
.......................................................................................................... 3
Leachate Generation Potential Will Continue for Thousands of Years
.................................... 8
Effect of Climate on Leachate Generation
...................................................................................... 8
Subtitle D Landfill Design Will Not Protect Groundwater for as Long
as Leachate Can Be Generated
.......................................................................................................... 9
Expected Performance of Subtitle D Landfill Liner System
...................................................... 10
Liner Failure Inevitable ................................................................................................................ 10
NRC Committee Report ...................................................................................................................... 13
Desiccation Cracking of Liner ..................................................................................................... 13
Cation Exchange-Related Failure ............................................................................................... 14
Permeation through the Liner ...................................................................................................... 15
Diffusion Can Be Important ............................................................................................. 15
Potential Problems with Geosynthetic Clay Liners .................................................................. 16
Leachate Collection and Removal System Problems
.................................................................. 18
Plugging of Leachate Collection Systems................................................................................... 19
Unreliable Evaluation of the Long-Term Integrity of Landfill Covers
.................................... 19
Leak-Detectable Covers ...................................................................................................................... 21
Alternative Cover Design .............................................................................................................. 22
New SWANA Report Focuses on Landfill Long-Term Cover Management Issues ................. 24
Landfill Cover Area Reuse
............................................................................................................... 25
Closing Unlined Landfills
...................................................................................................................... 25
Landfills at Superfund Sites
............................................................................................................. 26
Unreliable Groundwater Monitoring
................................................................................................ 28
Initial Liner Leakage Can Produce Narrow Plumes of Leachate-Polluted Groundwater
. .. 29
Monitoring of Some Fractured Rock Aquifers Nearly Impossible ......................................... 32
Regulatory Agency Should Evaluate Ability of Groundwater Monitoring
System to Detect Initial Groundwater Pollution
........................................................................ 34
Potential Change in Direction of Groundwater Flow
................................................................ 34
Evaluation of Leachate Density
....................................................................................................... 34
State’s Responsibility to Require Reliable Groundwater Monitoring for
Responsibility for Long-Term Monitoring
.................................................................................. 35
Responsibility for Long-Term Monitoring
..................................................................... 35
Frequency of Groundwater Monitoring
........................................................................................... 35
Vertical Migration of Leachate Polluted Groundwater in Wells
............................................... 36
Leachate Management
........................................................................................................ 36
Unreliable Information on Detection of Landfill Liner Failure
................................................. 36
Impact of Seismic Activity on Integrity of Landfill Containment Systems
............................. 37
Landfill Gas and Airborne Emission Problems
............................................................................. 37
Threat of Landfill Gas to Wildlife
............................................................................................. 39
iv
Table of Contents (continued)
Landfill Odor Control Problems and Impacts ...................................................................... 40
Landfill Dust Control Problems ............................................................................................ 41
Stormwater Runoff Pollution Impacts/Control ...................................................................... 42
Monitoring Stormwater Runoff from Hazardous Chemical Sites ....................................... 43
Inadequate Stormwater Runoff Parameter Monitoring ....................................................... 45
Safe Drinking Water Act Source Protection Issues ................................................................ 46
Inadequate Postclosure Monitoring and Maintenance .......................................................... 47
Hazardous versus Nonhazardous Waste Classification ......................................................... 51
Inadequate Waste Screening for Prohibited Wastes ............................................................ 53
Hazardous Characteristics of MSW ...................................................................................... 53
Construction and Demolition Waste Landfilling .................................................................... 57
PFAS Pollutant ...................................................................................................................... 58
PCBs in Caulk in Older Buildings ........................................................................................ 59
Aluminum Production Wastes .................................................................................................. 63
Hazards of Living/Working near Landfills ............................................................................. 63
Recommended Approach ....................................................................................................... 65
Landfill Siting Issues .................................................................................................................. 65
Justified NIMBY ........................................................................................................................ 66
Inadequate Buffer Lands ....................................................................................................... 68
Other Impacts of Landfill Releases and Activities ................................................................ 68
Vermin/Disease Vectors ..................................................................................................... 68
Noise Pollution ................................................................................................................... 68
Light Pollution ................................................................................................................... 68
Stormwater Flooding Problems ......................................................................................... 69
Decreased Values of Nearby Property .............................................................................. 69
Host Fees ................................................................................................................................ 69
Impact on the Three Rs ............................................................................................................. 70
Environmental Justice Issues .................................................................................................... 70
Professional Ethics Issues .......................................................................................................... 71
Developing Protective Landfills ................................................................................................ 71
Siting ....................................................................................................................................... 71
Design ..................................................................................................................................... 71
Closure .................................................................................................................................... 71
Monitoring .............................................................................................................................. 72
Landfill Gas Collection .......................................................................................................... 72
Maintenance ........................................................................................................................... 72
Funding .................................................................................................................................. 72
Improving Public Health and Environmental Protection from
Inadequately Developed Landfills ....................................................................................... 72
Need for Improved Hydrogeological Characterization ..................................................... 73
Subtitle D Landfills in Other Countries ................................................................................... 74
Comments on Environment Alberta July 1, 2009 Draft Standards for Landfills ............... 75
Offsite Groundwater, Water Supply Well, and Surface Water Monitoring ........................ 76
Hazardous Waste Landfilling ................................................................................................... 77
Addressing the Flawed Technology of Subtitle D Landfilling ............................................... 78
Fermentation Leaching of MSW (Bioreactor Landfills) ........................................................ 79
References ................................................................................................................................... 80
iv
Tables and Figures
Tables
Table 1 – Causes of Liner Failure .......................................................................................................... 11
Table 2 – Adverse Impacts of “Dry Tomb” Landfills on
Adjacent/Nearby Property Owners/Users ............................................................................ 67
Figures
Figure 1
–
Single Composite Liner Landfill Containment System ..................................................... 4
Figure 2
–
Factors Affecting Landfill Cover Integrity ........................................................................ 20
Figure 3
–
Pattern of Landfill Leakage-Groundwater Contamination from unlined Landfills .... 29
Figure 4
–
Pattern of Landfill Leakage-Groundwater Contamination from Lined Landfills ....... 30
Figure 5
–
Zones of Capture of Standard Monitoring Wells
Must Overlap to Detect Leakage from Lined Landfills .................................................... 31
Figure 6
–
Double Composite Liner Landfill Containment System ................................................. 32
Figure 7 – Chemical Analysis Output for a Typical Environmental Sample .................................. 46
Figure 8 – Comparison of Pattern of Landfill Gas Generation over Time
at Classical Sanitary Landfill and “Dry Tomb” Landfill ............................................ 48
Figure 9 – Impact of Moisture on Landfill Gas Formation ................................................................ 49
Figure 10 – Chemical Sources for California Coastal Water.......................................................
57
v
Acronyms and Definitions
CCL compacted clay liner
C&D construction and demolition
C&DD construction and demolition debris
CERCLA Comprehensive Environmental Response, Compensation and
Liability Act
CIWMB California Integrated Waste Management Board
CWA Clean Water Act
FML flexible membrane liner
GAO General Accounting (Accountability) Office (federal)
GCL geosynthetic clay liner
HDPE high-density polyethylene
HELP Hydrologic Evaluation of Landfill Performance (model)
LDEQ Louisiana Department of Environmental Quality
LEL lower explosive limit
MCLs maximum contaminant levels
Mil thousands of an inch
MSW municipal solid waste
NIMBY “not in my back yard”
OEHHA Office of Environmental Health Hazard Assessment California
PFAS Per- and polyfluoroalkyl substances
PBDEs polybrominated diphenyl ethers
PAHs polycyclic aromatic hydrocarbons
PCBs polychlorinated biphenyls
POTWs publicly owned treatment works (domestic wastewater treatment plants)
PPCPs pharmaceuticals and personal care products
RCRA Resource Conservation Recovery Act
SWANA Solid Waste Association of North America
SWAT Solid Waste Assessment Test
SWRCB State Water Resources Control Board (California)
TCLP toxicity characteristic leaching procedure
TDS total dissolved solids
US EPA US Environmental Protection Agency
VOCs volatile organic solvents
1
Flawed Technology of Subtitle D Landfilling of
Municipal Solid Waste
Overview of Landfilling Regulations
In 1991 the US EPA (1991) promulgated regulations for landfilling of municipal solid wastes
(MSW). These regulations cover Resource Conservation Recovery Act (RCRA) Subtitle D
requirements mandated by the US Congress. These regulations establish the “dry tomb”
landfilling approach, where the MSW to be landfilled is entombed in a plastic sheeting and
compacted soil/clay liner and cover. The Subtitle D regulations established a national minimum
design standard requiring a single composite (plastic sheeting and compacted clay) bottom liner
and a landfill cover that is no more permeable than the bottom liner. A groundwater monitoring
program is to be established that in principle can detect landfill-leachate-polluted groundwater
when it first reaches the point of compliance for groundwater monitoring. The groundwater
monitoring program includes monitoring to define the extent of groundwater pollution when it is
detected at the point of compliance. Further, the polluted groundwater is to be remediated
(cleaned up). This approach has the purpose of preventing offsite (adjacent property)
groundwater pollution by landfill leachate. Landfill gas is to be collected/managed to prevent
offsite explosive hazards. These regulations also establish a minimum 30-year postclosure
landfill monitoring and maintenance period that may be extended at the discretion of the US
EPA Regional Administrator. There are also some restrictions on the siting of landfills with
regard to flood plains, near airports, and near earthquake faults.
In the mid- to late 1980s, considerable research was undertaken on the properties of plastic
sheeting liners. It was well established that the plastic sheeting flexible membrane liner (FML)
and compacted clay had significant problems in preventing moisture from entering the landfill
through the cover and in collecting the leachate (garbage juice) that is generated in the landfill
when water enters the wastes. In 1998 the US EPA draft Subtitle D regulations included
statements (see below) that it was understood that a single composite liner would eventually
deteriorate and fail to prevent groundwater pollution.
One of the major driving forces for
not
developing landfills that would be protective of public
health and the environment for as long as the wastes in a MSW landfill would be a threat was the
concern that developing this type of landfill would significantly increase the cost of municipal
solid waste management that would be passed on to the public and commercial interests that
contribute wastes to the landfill. The national administration, through several
administrations, did not want to have to face the public opposition associated with
increasing the cost of household and industrial solid waste disposal.
In the early 1990s there was growing concern that the entombment of MSW in plastic sheeting
and compacted clay would not be effective in preventing leachate pollution of offsite
groundwaters for as long as the wastes in the “dry tomb” landfill would be a threat. Based on an
understanding of the processes that take place in a MSW landfill, it is obvious that keeping the
wastes dry would lead to a situation where no waste decomposition would occur, and
therefore the wastes would be a threat to generate leachate, effectively forever – well beyond the
30-year postclosure period of required funding. There was growing recognition that the dry
tomb landfilling approach with compacted soil and plastic sheeting liner and cover was not a
reliable approach for preventing groundwater pollution for as long as the wastes in a minimum
Subtitle D landfill would be a threat. This led to the US EPA’s delaying the promulgation of the
2
Subtitle D regulations beyond the due date that Congress had established. An environmental
group filed suit against the US EPA to force the Agency to promulgate the Subtitle D
regulations, with the result that the current Subtitle D regulations were adopted in 1991, even
though it was well understood that landfills that conformed to these regulations would not be
protective of public health and the environment for as long as the wastes in the landfill would
be a threat.
Typically when private companies and/or public agencies propose to construct a municipal solid
waste (MSW) landfill in an area, the residents/property owners of the area oppose the
development of the landfill. This report presents a review of the information available
pertinent to this issue and concludes that typically proposed Subtitle D landfills will cause
groundwater pollution by landfill leachate and be adverse to the health, welfare and interests
of the residents and property owners in the area of the landfill. As discussed herein, normally there
is significant justification for opposition to the development of Subtitle D landfills by those
within the sphere of influence of the landfill.
Qualifications to Provide Comments
Information on Drs. G. Fred Lee and Anne Jones-Lee’s qualifications to provide these comments
is summarized below. G. Fred Lee earned a bachelor’s degree in environmental health sciences
from San Jose State College in San Jose, California, in 1955. His undergraduate education
included work on public health aspects of landfilling of municipal solid wastes. He obtained a
Master of Science in Public Health degree from the University of North Carolina, Chapel Hill,
NC in 1957, and a PhD degree in Environmental Engineering from Harvard University in 1960.
Both his masters and PhD degree work included studies on water quality, public health, and
waste management.
For 30 years he held teaching and research positions in graduate-level environmental
engineering/environmental science programs at several major US universities. During that
time he conducted more than $5 million in research and published more than 500 papers and
reports on various aspects of water quality and the impact of chemical contaminants on public health
and environmental quality. His work included investigating numerous municipal solid
waste landfills and conducting research for the US EPA and others on landfill liner properties.
In 1989 he retired from university teaching and research and expanded his part-time, private
consulting activities into a full-time business. He was joined in that work by his wife, Dr. Anne
Jones-Lee, who at that time held a professorship in environmental engineering/science. Since
that time they have been active in investigating more than 85 municipal solid waste landfills
located in various parts of the US and other countries. They have published more than 1100
additional papers and reports, approximately 120 of which are devoted to landfill pollution
issues.
In 1992 Drs. Lee and Jones-Lee developed a “flawed technology” review (Lee and Jones,
1992), in which they summarized the significant potential problems with Subtitle D
landfilling with respect to protecting public health and the environment for as long as the
wastes in the landfill will be a threat. Throughout the 1990s Drs. Lee and Jones-Lee developed
several papers and reports that provided further information on the potential problems with Subtitle
D landfilling. A comprehensive review of these issues was published by Lee and Jones (1991).
The discussion presented herein represents an integration of the current understanding of the
problems with Subtitle D landfilling of municipal solid waste. Additional information on
3
Drs. G. F. Lee and Anne Jones-Lee’s experience and expertise in evaluating landfills’
public health and environmental impacts is available from www.gfredlee.com, at
http://www.gfredlee.com/landfill.htm
In the discussion presented herein, statements/approaches that are advocated by landfill
proponents are presented. These statements are typical of the types of statements that are
made by landfill developers and regulatory agency staff that support the development of a
minimum Subtitle D landfill.
Evolution of Subtitle D Landfills
Traditionally, the landfilling of solid wastes has been accomplished at the least possible cost.
Initially, urban areas deposited their solid wastes on nearby low-value lands, frequently
wetlands, creating a waste dump. This approach was followed by excavation of an area and
depositing the wastes in the excavated area. Often the wastes in the dump were burned to reduce
volume and some other adverse impacts. Eventually, beginning in some areas in the 1950s,
it was determined that there was need to cover the daily deposited wastes with a layer of soil
to reduce odors and access to wastes by vermin, rodents, flies, birds, etc. This approach led to the
development of the “sanitary” landfill. Basically, the sanitary landfill was an excavated area in
which the wastes were supposed to be covered each day by a layer of soil. No regard was given
to the potential for the wastes in a sanitary landfill to cause groundwater pollution or for the gas
generated in the landfill to be a threat to cause offsite explosions and to cause public health
and environmental problems. While landfilling in the conventional sanitary landfill was
recognized in the 1950s as leading to the pollution of groundwater by landfill leachate (ASCE,
1959), it was not until the 1980s/1990s that there were national regulations that were designed
to control groundwater pollution by landfills. In the 1980s the US EPA and state regulatory
agencies adopted the “dry tomb” landfilling approach.
In accordance with current US EPA regulations, solid waste landfills today are of a “dry tomb”
design and, in principle, operation. Environmental groups in the early 1980s convinced the US
Congress and the US EPA that landfilling should be based on the concept of isolating the waste
from water that can generate leachate (garbage juice) that can in turn lead to groundwater
pollution by constituents leached (released) from the solid waste. In theory, since one of the
primary problems of solid waste landfills that are used to manage municipal or industrial solid
waste is the pollution of groundwater by leachate, if the waste could be isolated from water that
leads to the formation of leachate, then groundwater pollution by landfills could be prevented.
The dry tomb landfilling approach, however, leads to a situation where the wastes that are
isolated from the environment in a compacted soil and plastic sheeting lined “tomb” will
remain a threat to cause groundwater pollution and to generate landfill gas.
The dry tomb landfilling approach (see Figure 1), as implemented by the US EPA, is based
on the use of a relatively thin plastic sheeting (high-density polyethylene – HDPE) layer and
a compacted soil/clay layer to form what is called a “composite” liner. The evolution of this
approach began in the 1970s, when compacted soil/clay liners were proposed for landfills.
However, this did not prevent the wastes in the landfill from causing groundwater pollution.
Further, the clay liners were found to be subject to a number of problems that led to their
failure to prevent leachate from passing through them at the design characteristics.
4
Figure 1.
Single Composite Liner Landfill Containment System
The fact that compacted soil layers cannot prevent groundwater pollution by landfill leachate
led the US EPA in the early 1980s to adopt the use of a plastic sheeting layer as a liner.
However, that approach was soon found to be unreliable, since relatively small holes in the
plastic sheeting could lead to high leakage rates through it. The next approach adopted was
that of a composite liner, in which the high-density polyethylene plastic sheeting is laid
immediately adjacent to the compacted soil/clay layer. This approach can greatly decrease the
rate of leakage through the plastic sheeting liner, where there are only a few holes in the plastic
sheeting, if the clay and the plastic sheeting layers are in intimate contact.
The evolution of liner and cover systems for landfills – from no liner, to a clay/soil liner, to a
plastic sheeting liner, to the current composite liner – was not based on a finding that any of
these liners could potentially prevent groundwater pollution by wastes for as long as the
wastes in the containment system were a threat. The clay/soil liner was based on using the next
least expensive material to no liner. When it was realized that clay/soil liners had
significant problems, plastic sheeting was the next least expensive to clay/soil. There was
never an evaluation that showed that clay/soil or plastic sheeting would be expected to
prevent groundwater pollution for as long as the wastes were in the landfill. The same
situation applies to the composite liner system that is used today. It is only a matter of time
until that liner system fails to prevent leachate from passing through it which can pollute
groundwaters, rendering them unusable for domestic and many other purposes.
Dr. Peter Montague in RACHEL'S HAZARDOUS WASTE NEWS #37, August 10, 1987,
located at, http://www.ejnet.org/rachel/rhwn037.htm has presented excerpts from the US EPA
Federal Registers on the expected performance of landfill liners as follows.
“In the FEDERAL REGISTER Feb. 5, 1981, the EPA first stated its opinion that all landfills
5
will eventually leak:
‘There is good theoretical and empirical evidence 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 several years, even many decades, after placement 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, leachate will migrate out of the
facility.’ [pg. 11128]
‘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 necessary 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 hazardous 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 prevents or greatly restricts migration of liquids 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 migrate out of the unit.’ [pg. 32284]
‘Some have argued that liners are devices that provide a perpetual seal against any migration
from a waste management unit. EPA has concluded that the more reasonable 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 (degrade very slowly); other hazardous constituents (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 disposal facility
creates some risk.’ [pg. 28315]
“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 successful 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 alternative to land
disposal," said the EPA [pg. 28325], though it has never begun any programs to make this
6
happen.’
The US EPA, as part of adopting the RCRA Subtitle D regulations, stated in the draft regulations
(US EPA, 1988a),
“First, even the best liner and leachate collection system will ultimately fail due to natural
deterioration, and recent improvements in MSWLF (municipal solid waste landfill)
containment technologies suggest that releases may be delayed by many decades at some
landfills.”
The US EPA (1988b) Criteria for Municipal Solid Waste Landfills stated,
“Once the unit is closed, the bottom layer of the landfill will deteriorate over time and,
consequently, will not prevent leachate transport out of the unit.”
With this background of the ultimate long-term failure of the landfill containment system, it is
appropriate to inquire as to why the US EPA adopted a fundamentally flawed approach for
landfilling of wastes. This situation arose out of the fact that environmental groups had filed suit
against the US EPA for failure to develop municipal and industrial “nonhazardous” solid waste
landfilling regulations. This led the Agency to promulgate the Subtitle D regulations (US EPA,
1991), based on a single composite liner and equivalent landfill cover, even though it was
understood in the early 1990s that at best this approach could only postpone when groundwater
pollution occurs by landfill leachate.
For a number of years following the adoption of the Subtitle D regulations, US EPA
management indicated that the problems with Subtitle D landfills discussed in the draft
regulations still existed, and acknowledged that ultimately the liner system will fail to prevent
groundwater pollution. Lee and Jones-Lee (1998a), as part of preparing an updated review of
their 1992 “flawed technology” report, contacted the US EPA administration to ascertain if this
administration had changed the conclusion reached by the US EPA 1988 administration that a
single composite liner would, at best, only delay when groundwater pollution occurs by landfill
leachate (Clay, 1991). Dellinger (1998), head of the Office of Solid Waste and Emergency
Response for the US EPA, indicated that the Agency still concluded that a single composite liner
will ultimately fail to prevent leachate transport through it.
Under the Bush administration, the US EPA has been espousing on its website and in
correspondence a different position, intimating that minimum Subtitle D landfill liner systems –
which have not changed – now will be protective. Lee (2003a) discussed the unreliable
information that was then being provided by the US EPA on the ability of a minimum Subtitle D
landfill’s design, closure and postclosure care to protect public health and the environment for
as long as the wastes in a dry tomb type landfill will be a threat. As discussed below, the US
EPA’s revised position is not based on a technically valid assessment of the length of time
that the waste in a municipal solid waste dry tomb landfill will be a threat to generate leachate
and the duration that a minimum Subtitle D single composite liner can be expected to collect all
leachate generated in the landfill and thereby prevent groundwater pollution by it for as long as
the wastes in the dry tomb landfill will be a threat to generate leachate and landfill gas.
The 30-year funding period for postclosure monitoring and maintenance of Resource
Conservation and Recovery Act Subtitle C and D landfills that was specified by Congress
was one of the most significant errors made in developing RCRA Subtitle C (hazardous waste) and
7
D (municipal solid waste) landfilling regulations. In establishing the original RCRA landfilling
regulations, the environmental groups and Congress, apparently with US EPA approval, had no
understanding of the length of time that municipal or industrial waste in a dry tomb landfill
would be a threat to cause groundwater pollution when moisture (water) infiltrates into the
landfill. There was the mistaken idea that 30 years after closure of a dry tomb landfill, the
waste in the landfill would no longer be a threat. Those who understand the characteristics of
wastes and their ability to form leachate, as well as the processes that can occur in a landfill,
realize that 30 years is an infinitesimally small part of the time that waste components in
a landfill, especially a dry tomb landfill, would be a threat to cause groundwater pollution through
leachate formation. While Congress required that the regulations include provisions to potentially
require additional funding at the expiration of the 30-year postclosure care period, the
likelihood of obtaining this funding from private landfill companies, even if they still exist 30
years after a landfill has been closed, or from a public agency that develops or owns a landfill,
is remote.
A review of the properties of municipal solid wastes and how they degrade/decompose in a
landfill shows that the rate of decomposition is dependent on the amount of moisture that enters
the landfill. Water is needed by bacteria that are present in the landfilled wastes in order to
decompose those parts of the waste that are subject to bacterial decomposition. These issues
have been discussed by Christensen and Kjeldsen (1989). This decomposition leads to landfill
gas production. Another mechanism for decomposition of municipal solid waste components
is the leaching (dissolving) of waste components to produce leachate. In a true dry tomb
landfill, the wastes are kept dry and, therefore, do not decompose or leach. Under this
condition, the wastes will, forever, be a threat to generate landfill gas and leachate. This
situation necessitates that the landfill bottom liner collect all leachate that is generated for as
long as the wastes are a threat (forever). Further, the landfill cover must be designed, operated
and maintained to greatly restrict the amount of moisture that enters the landfilled wastes
through the cover, forever.
As noted by John Skinner, Executive Director of the Solid Waste Association of North America
(SWANA) and former US EPA official in the Office of Solid Waste and Emergency
Response, on pg.16 of the July/August 2001 MSW Management Journal,
“The problem with the dry-tomb approach to landfill design is that it leaves the waste in an
active state for a very long period of time. If in the future there is a breach in the cap or a
break in the liner and liquids enter the landfill, degradation would start and leachate and
gas would be generated. Therefore, dry-tomb landfills need to be monitored and
maintained for very long periods of time (some say perpetually), and someone needs to be
responsible for stepping in and taking corrective action when a problem is detected.”
Leachate Generation Potential Will Continue for Thousands of Years.
The municipal solid
wastes in a classical sanitary landfill where there is no attempt to prevent moisture from entering
the wastes have been found to generate leachate for thousands of years. Freeze and Cherry
(1979) of the University of British Columbia and the University of Waterloo, Ontario, Canada,
in their book, Groundwater, discuss that landfills developed in the Roman Empire about 2,000
years ago are still producing leachate. Belevi and Baccini (1989), two Swiss scientists who
have examined the expected contaminating lifespan of Swiss MSW landfills, have estimated that
Swiss landfills will leach lead from the waste at concentrations above drinking water
standards for over 2,000 years. Based on the information in these references, a proposed
8
Subtitle D dry tomb landfill will be a threat to groundwater resources for long periods of time,
effectively forever. These issues are discussed further in the papers, “Landfilling of Solid &
Hazardous Waste: Facing Long-Term Liability” (Lee and Jones-Lee, 1994a), “Landfill
Leachate Management,” (Lee and Jones-Lee, 1996) and “Groundwater Pollution by Municipal
Landfills: Leachate Composition, Detection and Water Quality Significance” (Jones-Lee and
Lee, 1993).
Another significant error that was made in developing the dry tomb landfilling approach was
that it was assumed that it would be possible to design, construct and operate the landfill
containment system so that little or no moisture could enter the landfill once the landfill was
closed – i.e., no longer accepting waste – and a landfill cover had been placed on the waste.
Further, it was assumed that, even if moisture did get through the low-permeability cover of
the landfill, the leachate generated would be collected in a leachate collection system which
overlies the single composite liner. Further, the US EPA assumed then (and, unfortunately,
still assumes today) that, when a dry tomb landfill generates leachate that passes through the liner
into the underlying geological strata and groundwater system, the groundwater monitoring
system used would detect this leachate-polluted groundwater while the leachate-polluted
groundwater was still on the landfill owner’s property. Unfortunately, these assumptions
were based on inappropriate analysis, and it is now clear that the dry tomb landfill is a
fundamentally flawed technological
approach
for managing solid waste.
Effect of Climate on Leachate Generation.
During the active life of the landfill (while
wastes are being accepted), landfills located in wet climates such as the Northwest, Midwest,
South and East generate leachate proportional to the precipitation. Once the landfill cover is
placed over the wastes, leachate generation is dependent on the ability of the cover to prevent
infiltration of moisture into the wastes through the cover. Landfills located in the arid west
produce less leachate than landfills located in wetter climates; however, the leachate
produced by such landfills still poses a significant threat to cause groundwater pollution.
In 1984 the California legislature passed a law requiring the testing of water and air at all solid
waste disposal sites. This program became known as the Solid Waste Assessment Test (SWAT)
program. In 1995 Mulder and Haven (1995) presented a report of the results of the testing
that had been done at 544 landfill sites in California. They reported that 72 percent of the sites
tested had been found to have leaked waste constituents from the waste management unit.
Only 14 percent were found to be not leaking, a finding that may reflect more the adequacy of the
SWAT investigation than the lack of leakage. Another 14 percent was “undetermined” with
respect to leaking leachate. Mulder and Haven (1995) concluded,
“Available data indicate no apparent correlation between the percentage of landfills which
leaked and any of the different site-specific factors checked, including depth to ground water,
average annual precipitation, waste acceptance rate, and rock type.”
The California SWAT results have pertinence to the potential for landfills located in arid areas to
pollute groundwaters, since some of the California landfills that have been found to be leaking
leachate are located in an arid climate. The results of the SWAT investigations were for unlined
landfills or landfills that had been constructed since 1984, which was the date that California
landfilling regulations (Chapter 15) required that all new landfills or landfill expansions
contain a clay liner. Mulder and Haven reported that there was no difference between the
leakage of clay-lined landfills versus unlined landfills – i.e., the lining of a landfill with a clay
9
liner did not prevent groundwater pollution.
Lee and Jones-Lee (2007a,b) discussed groundwater quality protection issues, focusing on
land surface activities, including landfills that can lead to groundwater pollution. They have
provided a chronology of the landfilling regulations in California, where the regulatory
agencies have failed to implement regulations that were originally adopted in the 1970s and
readopted in 1984, which require that the siting, design, operation, closure and postclosure care
(monitoring and maintenance) of a landfill prevent groundwater pollution for as long as the
wastes in the landfill will be a threat. These regulations also apply to the Subtitle D landfills
that have been developed in the state since the mid-1990s. As Lee and Jones-Lee (2006a)
discuss, while these regulations have been in effect since the mid-1980s, they are still not
properly implemented by the Regional and State Water Resources Control Boards, with the
result that landfills have been and continue to be developed in the state that will eventually
pollute groundwaters by landfilled waste components. As discussed herein, this same
problem exists in the federal and many state landfilling regulations governing the landfilling
of municipal solid waste.
Subtitle D Landfill Design Will Not Protect Groundwater
for as Long as Leachate Can Be Generated
A typical Subtitle D landfill is designed with a composite liner system composed of a two-foot
thick clay liner and a 60-mil-thick plastic sheeting geomembrane liner. Overlying this composite
liner is a leachate collection system consisting of a series of six-inch diameter or so
perforated pipes draining to sumps along the exterior of the landfill. The drainage layer will be
a porous material such as geonet with a geotextile attached to the top of the geonet. The
authors have participated in a landfill permitting hearing where the regulatory agency staff
stated, as part of an attempt to convince the public of the safety of the landfill, that the liner that
had been proposed and that the regulatory agency had accepted would be “five feet thick.”
Such a characterization of a minimum Subtitle D liner is highly misleading with respect to its
key components for preventing leachate generated in the landfill from passing through it into
the underlying groundwater system. In fact, the low-permeability layer of this liner is 60 mil
thick (60 thousandths of an inch, which is less than a sixteenth of an inch) – i.e., about the
thickness of thin paperboard. With increasing frequency, landfill developers are using a
geosynthetic clay liner (GCL) as a substitute for the two feet of clay. While the geosynthetic clay
liner is somewhat thicker than the plastic sheeting geomembrane layer, it is only about a quarter-
inch thick. The other components included in the five-foot-thick “liner” are a drainage layer and
a layer of soil that is designed to separate the drainage layer from the wastes and protect its
underlying plastic sheeting liner from puncture by the waste components. As discussed below,
the low-permeability components of the liner would not be expected to prevent leachate from
passing through them for as long as the wastes in the minimum Subtitle D landfill will be a
threat.
Title 40 PART 258--CRITERIA FOR MUNICIPAL SOLID WASTE LANDFILLS-Subpart D--
Design Criteria Sec. 258.40 Design criteria states,
“(a) New MSWLF units and lateral expansions shall be constructed:
(1)
(In accordance with a design approved by the Director of an approved State or as
specified in Sec. 258.40(e) for unapproved States, The design must ensure that the
concentration values listed in Table 1 of this section will not be exceeded in the
uppermost aquifer at the relevant point of compliance, as specified by the Director of an
10
approved State under paragraph (d) of this section, or
(2) With a composite liner, as defined in paragraph (b) of this section and a leachate
collection system that is designed and constructed to maintain less than a 30-cm depth
of leachate over the liner.
(c)
For purposes of this section, composite liner means a system consisting of two
components; the upper component must consist of a minimum 30-mil flexible
membrane liner (FML), and the lower component must consist of at least a two-
foot layer of compacted soil with a hydraulic conductivity of no more than 1x10
-
7
cm/sec. FML components consisting of high density polyethylene (HDPE) shall
be at least 60-mil thick. The FML component must be installed in direct and
uniform contact with the compacted soil component.”
As discussed below, the US EPA’s assuming that a single composite liner will provide the
same degree of protection of offsite groundwater quality as the appropriate monitoring of
groundwater at the point of compliance for groundwater monitoring is one of the most
significant errors made in developing/adopting Subtitle D regulations.
Expected Performance of Subtitle D Landfill Liner System.
Lee and Jones-Lee (2004a) have
discussed the characteristics and expected performance of the typical Subtitle D landfill liner
containment system and monitoring system. As discussed, it is possible to construct a single
composite landfill liner system that will not leak leachate at the time of construction at a
sufficient rate to pollute large amounts of groundwaters. However, ultimately the plastic
sheeting layer of such a landfill liner will deteriorate to the point where it will be ineffective in
collecting leachate to enable its removal from the landfill in the leachate collection/removal
system. This deterioration will eventually allow transport of leachate through the liner on
its way toward the groundwater resources hydraulically connected to the landfill through a
vadose (unsaturated) zone, which could be used for domestic water supply purposes.
Further, compacted soil (clay layers) used in landfill liners are well-known to experience
increased permeability with time over that which was designed and originally constructed.
Lee and Jones (1992) and Lee and Jones-Lee (1998a) have presented reviews of the literature
on what is known about the properties of plastic sheeting flexible membrane liners (FMLs) and
clay liners with respect to their ability to prevent landfill leachate from passing through them
for as long as the wastes in the landfill will be a threat. Peggs (1998) has discussed the
inevitable failure of plastic sheeting layers used in landfill covers and liners. Shackelford
(1994) has presented a comprehensive review of the potential for waste and compacted soil
interactions that alter the hydraulic conductivity of liners. Table 1 summarizes some of the
causes of landfill plastic sheeting and clay liner failure.
Liner Failure Inevitable. Hsuan and Koerner (1995) have reported on the initial phase of long
term (10-year) studies underway at that time devoted to examining the rates of deterioration of
flexible membrane liners. The focus of the Hsuan and Koerner work was on the breakdown of
the polymers in the plastic sheeting liners. They predicted that such breakdown will occur due
to free radical polymer chain scission in 40 to 120 years. These estimates were indicated by
Koerner to consider only some of the mechanisms that could cause breakdown. It is possible
that breakdown could begin much earlier. Even if the breakdown of the plastic sheeting
polymers took 100 years or so, ultimately the plastic sheeting in the flexible membrane liners
will break down, leading to an inability to prevent large amounts of leachate from passing
through the liner, causing groundwater pollution in the landfill area.
11
Table 1
Causes of Liner Failure
Plastic Sheeting FMLs
Soil/Clay Liners
Holes at Time of Liner
Construction
Desiccation Cracks
Holes Developed in liner
Liner
Waste Placement
Differential Settling
Cracks
Stress-Cracks
Cation Exchange
Shrinkage (for
Expandable-Layer
Clays)
Free-Radical
Degradation
Inherent Permeability
Permeable to Low-
Molecular-Weight
Solvents – Permeation
Interactions between
Leachate and the Clays
Inherent Diffusion-Based
Permeability
Finite Effective Lifetime
– Will Deteriorate and
Ultimately Become Non-
Functional in Collecting
Leachate and as a Barrier
to Prevent Groundwater
Pollution
Highly Permeable –
Allow Large Amount of
Leakage under Design
Conditions and Subject to
Cracking and Other
Failure Mechanisms
One of the approaches used by Koerner and his associates in an attempt to predict long-term
stability of HDPE plastic sheeting liners is the application of the Arrhenius equation. This
equation is used in physical chemistry to relate the effect of temperature on the rates of
reactions. In some of Koerner’s publications he has made predictions in which he has estimated,
using the Arrhenius equation and short-term elevated temperature liner deterioration studies
that the HDPE liners should be serviceable for hundreds to a thousand or so years, but
eventually will break down. The US EPA (Bonaparte et al., 2002) released a report that claims
that a single composite landfill liner can be expected to have a service life of “1,000 years.” A
critical review of the technical base for this estimate shows that it is based on an
Arrhenius equation extrapolation of a few studies on liner stability that were conducted for
short periods of time at elevated temperatures compared to landfill temperatures. This
approach for extrapolation is highly speculative and likely to be unreliable. That report
continues to support the US EPA (1988a,b) conclusion about the eventual failure of the landfill
liner system and its leading to groundwater pollution. While the length of time that the landfill
liner will delay groundwater pollution is unknown, there is no doubt that a single composite
landfill liner system will eventually fail, and groundwater pollution will occur, when the
landfill is sited at locations where there is high-quality groundwater underlying the landfill.
An issue of concern in MSW landfills is the impact of temperature of the landfilled wastes on
the integrity of the plastic sheeting liner. Yesiller and Hanson (2003) have provided
information on the temperature of solid wastes in MSW landfills where they did not find
significant elevated temperatures in MSW landfills.
In the US EPA (Bonaparte et al., 2002) report, Koerner made a significant error in claiming
that the municipal solid wastes in a Subtitle D dry tomb landfill will only be a threat for about
200 years. There is no technical validity for that estimate. It is obvious that in a “dry tomb”
landfill, a number of the normal components of MSW will be a threat forever – not just 200
years. The metals, salts, and many organic compounds that are typically present in MSW and
that produce hazardous and deleterious leachate will be a threat forever. In that report the
US EPA is attempting to support the continued use of single composite lined landfills
12
for MSW management by claiming the wastes will be a threat for only 200 years, and the liner
will work perfectly for 1,000 years. Such claims are fundamentally flawed.
Needham et al. (2003) reported on a study commissioned by the Environment Agency of the
UK on the long-term service life of HDPE geomembrane liners. They concluded that,
“ the service life of HDPE liners depends upon the rate of generation of holes in the liner
and the acceptability of leachate or gas leakage at a particular site. A thorough review of
physical damage, material degradation processes and the development of holes by stress
cracking has been undertaken. A conceptual model of hole generation in six stages throughout
the service life of an HDPE liner is presented. Electrical leak location surveys are seen to be
effective means of identifying holes caused by physical damage during liner installation and
waste disposal, and permitting their repair. Degradation of the HDPE liner is controlled by
the liner exposure conditions, the activation energy of the antioxidant depletion process and
the oxidative resistance of the material. Where the liner is subjected to long-term stresses,
stress cracking will lead to the development of holes, and the rate of cracking will increase
once oxidation of the liner commences.”
Rowe et al. (2003) have reported on the failure of an HDPE lined leachate lagoon. They stated,
“A geomembrane – compacted clay composite liner system used to contain municipal solid
waste (MSW) landfill leachate for 14 years is evaluated. Field observations of the geomembrane
revealed many defects, including holes, patches, and cracks.
***
“Contaminant modelling of the entire lagoon liner suggests that the geomembrane liner most
likely stopped being effective as a contaminant barrier to ionic species sometime between 0 and
4 years after the installation.”
It is evident that under some situations there can be rapid failure of HDPE liners that are used in
waste management including landfill leachate lagoons and liners.
Minimum Subtitle D landfills include a composite liner composed of a flexible membrane liner
(FML) (plastic sheet) and a compacted soil layer or geosynthetic clay liner below it. While in
concept a composite liner can provide greater postponement of leakage than the sum of the
two liner components, the true composite character is difficult to achieve in practical
applications (Lee and Jones, 1992), since it requires that the plastic sheeting liner be in intimate
contact with the compacted soil layer. There are significant problems in achieving this degree
of contact in the construction of a composite liner.
The clay layer beneath the FML is compacted to achieve a prescribed initial design permeability,
which means that even when new, the soil/clay layer will transport leachate at the design
permeability. Workman and Keeble (1989) discussed the time it takes leachate to breach a clay
layer used as a liner. Through Darcy’s Law calculations it is found that a compacted soil layer
provides only a short-term slowing of the leakage of leachate through the liner; one foot of clay
compacted to 1x 10
-7
cm/sec permeability, with 0.1 foot of head, will be breached in less than
five years. There is increasing evidence that, in addition to general permeability, such liners
leak through imperfections that are created at the time of liner construction. Further, compacted
clays used as liners are subject to desiccation cracking, cation exchange shrinking, cracking due
to differential settling, impacts of chemicals, etc., creating additional points through which
leachate can leak, and allowing transport of leachate through the liner at a rate greater than
13
would be expected based on the design permeability.
NRC Committee Report. In 2007 a National Resources Council Committee (NRC 2007) issued
a report, “Assessment of the Performance of Engineered Waste Containment Barriers,” that
presents a discussion of expected performance of landfill liner containment systems.
Considerable information is presented on many of the issues discussed in this Flawed
Technology report on the near term and especially the long term of plastic sheeting and
compacted clay landfill liners and covers. The NRC (2007) report provides additional references
beyond those presented herein and discussion of the long term issues of the plastic sheeting
(HDPE) and compacted clay liners and landfill covers to contain landfilled wastes for as long
as the wastes are a threat to release pollutants to the groundwaters and the atmosphere.
Excerpts from this NRC (2007) report are presented below.
The NRC Committee report states that landfill containment systems (liners and cover) has
performed satisfactorily where the report states,
“Based on as much as 20 years of observations, the committee concluded that most
engineered waste-containment barrier systems that have been designed, constructed,
operated, and maintained in accordance with current statutory regulations and
requirements have thus far provided environmental protection at or above specified levels.”
Obrien (2009) in SWANA ARF Disposal Group Report on the Long Term Potential Problems of
Subtitle D Landfills, is attempting to use this statement to support that today’s Subtitle D
landfills are performing satisfactorily. However, Lee and Jones-Lee (2009b) have discussed a
significant problem with the NRC (2007) report in the discussion of the NRC Committee
assessment of the performance of the existing Subtitle D landfills. The basic problem with
the NRC Committee conclusion on the performance of existing Subtitle D landfills is that
the Committee failed to understand/discuss that the approach used of relying on the presence
of leachate in the leachate collection system and the failure to find leachate polluted
groundwater at the point of compliance for groundwater monitoring are not reliable indicators
for the integrity of the landfill liner system. As discussed below failure to find leachate polluted
groundwater at the point of compliance for groundwater monitoring reflects the unreliability
of groundwater monitoring wells spaced hundreds of feet apart where each well only samples
water about one foot around the well in detecting initial groundwater pollution by failed
landfill liners. These issues are discussed below.
The NRC (2007) report states,
“Over the medium and long terms, geomembrane performance may be reduced by punctures
caused by increased overburden pressure, material degradation, and high temperatures. The
estimated service lives of geomembranes decrease from 1,000 years at 10°C to only about 15
years at 60°C.”
As discussed herein and in the NRC (2007) report there is considerable uncertainty about the
performance of plastic sheeting liners in preventing leachate from leaving the landfill and
polluting groundwaters.
Desiccation Cracking of Liner. The desiccation cracking of clay liners arises from the fact
that in order to achieve the design permeability it is necessary to add water to the clay to
typically achieve slighter wetter than optimum moisture density. In time, however, due to
14
unsaturated transport of the water added to the clay, the clay can dry out, leading to
shrinkage and desiccation cracks. This situation is readily observed in some soils, where during
periods of low precipitation, soils will crack. Chapter 4 in the NRC Committee report, devoted to
reviewing the performance of liners states,
“However, the hydraulic conductivity of clay barriers is generally acknowledged to be
susceptible to significant increase as a result of processes such as desiccation cracking,
differential settlement, lateral spreading (induced tension), freezing and thawing, and root
penetration. These processes are most significant in cover systems because bottom barrier
performance is generally enhanced by increases in the confining pressure associated with waste
disposal. Earthen barriers are also susceptible to a variety of mechanical performance
problems, including erosion and cracking of earthen cover systems, disruption of base liner
barrier layers due to foundation instability, and veneer failure of cover barrier layers due to low
interface strength, clogging, or inadequate capacity of drainage layers.”
Cation Exchange-Related Failure. Some types of clays used in landfill liners, with an
expandable lattice structure, exhibit strong shrink/swell properties dependent on the type of
cation on the clay’s ion exchange sites. With sodium at the exchange site, the clay is in a
swollen state. However, in contact with water with high calcium/magnesium compared to
sodium concentrations, the calcium and magnesium will replace the sodium on the clay, and
the clay will shrink, leading to higher permeability and possible failure through cracking.
Auboiroux et al. (1999) have investigated the impact of calcium exchange for sodium in
bentonite geosynthetic clay liners for landfills. They stated,
“Results suggest that while GCL 's may be considered as useful materials for reinforcing
compacted clay layers at the base of landfills, they should not be considered as "equivalent" to
compacted clay layers, at least in terms of pollutant breakthrough times.”
Guyonnet et al. (2005) reported that,”... calcium carbonate in the bentonite, formed during
activation of the calcium bentonite, may redissolve during contact with a dilute permeant,
releasing calcium ions that exchange with sodium in the clay. This exchange leads to obliteration
of a so-called “gel” phase ~beneficial in terms of low permeability and to the development of a
more permeable “hydrated-solid” phase.”
James et al. (1997), in a study of the use of a GCL as a liner to enhance the cover over a reservoir,
reported that, “The evidence demonstrates that calcium from calcite, contained in the GCL
bentonite, exchanged with sodium and, in so doing, contributed to shrinkage and cracking.”
Jones-Lee and Lee (1993) presented a summary of the concentrations of various ions present in
leachates from 83 US landfills. The data show that some MSW leachates have higher
concentrations of calcium than sodium. In fact, the overall average calcium concentration for all
of the landfill leachates investigated was higher than the sodium concentration. This means that,
for some compacted clay liners, the low advective permeability (rate of penetration) at the time
of installation of the liner will increase as the sodium on the clay is replaced by calcium and the
clay shrinks from its original characteristics at the time of construction. This shrinking can lead
to ion exchange cracking of the compacted clay liner.
Desiccation cracking and ion exchange cracking of compacted clay layers in a composite liner
have been known since the late 1980s. However, neither the US EPA (2001a) nor state regulatory
agencies have adequately considered these issues in evaluating the prospective performance of
15
a single composite liner. Both of these phenomena can lead to a much more rapid rate of
leachate penetration through the composite liner than is typically assumed.
Permeation through the Liner. The plastic sheeting HDPE liner will allow dilute solutions of
organic solvents such as those that can be purchased in hardware stores for household use to pass
through an intact (no holes) liner. Many of these solvents are carcinogens and can be readily
transported through groundwater systems. The phenomenon in which organics pass through
intact plastic sheeting layers is known as permeation and has been recognized in the landfill liner
literature since the late 1980s (Haxo and Lahey, 1988). This is a chemical transport process in
which low molecular weight organics dissolve into the plastic liner and exit on the downgradient
side. Sakti et al. (1991) and Park et al. (1996), at the University of Wisconsin, Madison, have
reviewed the available information on permeation of landfill liners by solvents and have
conducted extensive research on it. They found that an HDPE liner would have to be over three
inches thick to prevent permeation of certain organics through it for a period of 25 years. Buss et
al. (1995) reviewed the information on the mechanisms of leakage through synthetic landfill liner
materials. They discussed the importance of permeation of organics through plastic sheeting
liners as a landfill liner leakage mechanism that does not require deterioration of the liner
properties for leakage to occur. The US EPA and other regulatory agencies continue to ignore
this mechanism of landfill liner leakage. There is need to address this issue as part of
recommending a single composite liner system for municipal solid waste landfills.
Diffusion Can Be Important. Daniel and Shackelford (1989) have reviewed the inherent leakage
rates of plastic sheeting layers and clay liners. They point out that even though plastic sheeting
layers can have low permeabilities to water on the order of 10
-12
cm/sec, compared to clay liners
which have a permeability of about 10
-7
cm/sec at the time of construction, the thin layer of
plastic that is used, coupled with its inherent chemical diffusion coefficients, cause plastic
sheeting liners of the type used in Subtitle D landfills to have diffusion-controlled breakthrough
times for waste components of about two to three years. The clay liner, however, in the landfill
cells would be expected to have diffusion-controlled breakthrough times of about 10 years.
Johnson et al. (1989) investigated the rate of penetration of chloride and volatile organic
compounds derived from a hazardous waste landfill in vertical cores of an “impervious,
unweathered, water-saturated clay.” They found that the downward transport of these
chemicals into the clay was the result of Fickian diffusion. They state that,
“For liners of typical thickness (~1 m), simple diffusion can cause breakthrough of mobile
contaminants in approximately 5 years; the diffusive flux of contaminants out of such liners
can be large.”
The diffusion of solid waste components through plastic sheeting liners discussed by Daniel and
Shackelford occurs through a different mechanism than the permeation of organic solvents
(VOCs) through HDPE liners discussed herein. As stated by Daniel and Shackelford (1989),
“No material is impervious, and the question of which liner is more effective, like most
questions, is ultimately related to one of economics and the realities of construction practices.”
Basically, regulatory agencies, such as the US EPA which has set the national landfilling
minimum standard, have been adopting landfill liner systems that will, in time, obviously fail to
prevent groundwater pollution. The US EPA stated this fact in its 1988 discussion of the
ultimate failure of composite liners as quoted above.
16
Guyonnet et al. (2001) have discussed that the current approaches to defining clay liner
equivalency based on travel times do not adequately consider the magnitude of a disposal
site’s potential impact on groundwater resources. They emphasized that “...
conclusions
relative to the superiority of one multi-layered barrier with respect to another should not only
consider hydro- dispersive aspects, but also other processes such as the mechanical and
chemical evolutions of the different barrier components. Although such phenomena are
poorly addressed by existing models, failure to take them into account, at least in a
qualitative fashion, may lead to unconservative conclusions with respect to barrier
equivalence.”
Potential Problems with Geosynthetic Clay Liners. Some landfill developers propose to use
a single composite liner for the landfill with a 60 mil HDPE plastic sheeting layer and
geosynthetic clay layer (GLC). While some states allow the substitution of a geosynthetic
clay layer for the two feet of clay specified in US EPA Subtitle D regulations, such practice
can allow more rapid failure of the composite liner than if the two feet of compacted clay had
been used. The US EPA (2001a) has reviewed the properties of geosynthetic clay liners, where
a number of the potential advantages and potential problems with substituting a
geosynthetic clay liner for two feet of compacted clay have been discussed. A key problem
with geosynthetic clay liners is that they are so thin that they have limited structural integrity
and will allow rapid penetration of leachate through the liner by diffusion. While landfill
applicants and their consultants, and unfortunately some regulatory agencies, will claim that
the permeability of a geosynthetic clay liner of 10
--9
cm/sec under one foot of head will control
the rate of leachate passing through the liner, in fact, because of diffusion, leachate can pass
through more rapidly. In addition, as discussed above, cation exchange-related shrinkage of
the bentonite in the geosynthetic clay layer can lead to higher permeability and possible
failure through cracking.
The US EPA Region 9 has conducted a review of the potential problems with the GLC liners
in a landfill liner and cover. Vaille (2008) has pointed out in comments on the proposed used
of GLC liner in the proposed Cortina Landfill to be located in Colusa County, California that
while GLC manufactures claim a permeability of 3 x 10
-9
cm/sec, validating testing of GLC
delivered to a landfill site has measured permeability of 10
-8
cm/sec. Vaille also stated,
“
In the HELP model liner/cover analysis, the geomembrane liner is assumed to have 5 flaws
of 1 cm
2
per acre and no assumption was made about flaws in the GCL liner. It is highly
possible for a tractor or other equipment to damage both the geomembrane and underlying
GCL, therefore rendering a preferential flow path for moisture. Like any thin liner, GCLs
are vulnerable to puncture and to tearing e.g., as described for a case involving accidental
puncture of a GM/GCL composite liner by a piece of maintenance equipment.
1
Therefore,
we suggest including the assumption of a GCL seam split or other damage near a
geomembrane puncture, and using a more conservative 10 flaws of 1 cm
2
per acre sensitivity
analysis for the HELP and MULTIMED models.”
1. Daniel, D.E., and Gilbert, R. B., "Practical Methods for Managing Uncertainties for Geosynthetic Clay Liners, "
Uncertainty in the Geologic Environment: From Theory to Practice, American Society of Civil Engineers, New
York, 1996.
Vaille (2008) stated with respect to the equivalency of GLC to a compacted clay liner (CCL),
"
The objective of this demonstration is to show that the GCL has equivalent or superior
hydraulic conductivity and chemical attenuation properties when compared with the soil
layer components of the liner and cover." Assessment of full technical equivalency is much
17
more complicated. A comparative assessment of GCLs to CCLs should be made, and
included in the submission, on the basis of hydraulic, physical/mechanical, and construction
criteria.
2
Caution should be exercised in substituting a GCL alone for the CCL as the low-
permeability soil component of a Subtitle D single-composite liner on the base of a landfill.
While the hydraulic efficiency of a GM/GCL composite liner is as good, or better, than a
GM/CCL composite liner, the GM/GCL composite liner is more susceptible to diffusive
transport
3
and puncture than the GM/CCL composite liner.” GM is a geomembrane liner,
FML.
3
Rowe, R.K. and Booker, J.R. (1998). "Modeling impacts due to multiple landfill cells and clogging of leachate collection
systems", Canadian Geotechnical Journal, 3 5(1): 1-14.
Dwyer, Stephen 2003. "Water Balance Measurements and Computer Simulations of Landfill Covers", Dissertation, University
of New Mexico.
Benson, C.H. et al. 2004. "Forensic analysis of excessive leakage from lagoons lined with a composite GCL".
Geosynthetics International, 11, No. 3;
Vaille stated,
“Vulnerability to chemical alterations
— Bentonite is subject to increases in hydraulic
conductivity caused by chemical alterations, particularly at sites containing calcium-rich soils.
This vulnerability increases in hydrologic settings where there is the potential for transient
wetting and drying conditions to occur. This can occur where the GCL goes though wetting and
drying cycles due to intermittent direct contact with groundwater, or where the GCL would
become saturated through contact with the unsaturated zone above the groundwater table.
When subject to such transient conditions in near surface applications, i.e. cover systems, GCL
permeability has been shown to increase, sometimes by orders of magnitude.
4
The
performance degradation is due to ion exchange problems, desiccation cracking, and
bentonite leaching from the product..”
4. Jo, Ho Young. 2005. "Long-Term Hydraulic Conductivity of a Geosynthetic Clay Liner Permeated with Inorganic
Salt Solutions",
Journal of Geotechnical And Geoenvironmental Engineering.
April.
“Low Shear Strength and Low Slope Stability
— Bentonite, the key ingredient in GCLs is well
known for its very low strength when hydrated. In particular, problems arise when GCLs
are placed on slopes in applications where they may become saturated (hydrated). Should a
GCL become saturated, its internal friction angle [a key factor in shear strength] is reduced
and may significantly reduce its slope stability, particularly under seismic conditions. Because
bentonite is so well known for its low shear strength, caution is appropriate when employing
materials such as GCLs that contain bentonite on slopes.
Vaille (2008) has stated that a discussion of the liner in relation to the physical and chemical
characteristics of the leachate should be included in evaluation of a landfill liner. He also stated a
proposal for a landfill
“must include a fully-developed groundwater monitoring plan in order to demonstrate that the
alternative liner design will ensure that the concentration values listed in Table 1 40 CFR
258.40 will not be exceeded in the uppermost aquifer at the relevant point of compliance.”
Vaille stated,
“The use of GCLs in cover systems has been problematic due to degradation of the GCL product
after installation due to cation exchange issues, root intrusion, freeze/thaw and wet/dry cycles,
and desiccation cracking. Dwyer (2003)
5
found that the saturated hydraulic conductivity of GCLs can
increase by several orders of magnitude in just a few years after installation. Generally, these issues
18
that are a problem for GCLs in cover systems are not assumed to be a problem with liners.
However, if the liner remains unprotected and within a transient active zone for an extended period
of time, these issues can lead to degradation of the GCL in the liner as well. Therefore, it is
imperative that precautions are taken to adequately protect the GCL product after its installation
until the liner is fully covered by an adequate depth of soil and/or waste. We strongly discourage
the use of a GCL product in the cover.”
Dwyer, S. F., B. R. Reavis, and G. Newman, 2000, Alternative landfill cover demonstration, FY2000 annual data report,
SAND2000-242 7, Sandia National Laboratories, Albuquerque, New Mexico.
The US EPA Region 9 comments on the proposed Cortina Landfill development summarized
above have applicability to many other landfill development situations.
The NRC (2007) report states, in a discussion of 3.3.5 Geosynthetic Clay Liner Barrier Monitoring
“Because geosynthetic clay liners (GCLs) are manufactured and thus undergo
manufacturing quality assurance, their end of construction reliability tends to be
significantly higher than that of compacted clay layers and is probably similar to that of
geomembranes. GCLs are often used beneath relatively shallow depths (e.g., less than 1 m) of
soil in cover systems. Because of serious performance concerns about GCLs buried under
shallow depths of soil covers, GCLs have been exhumed and tested after several years of
service to evaluate their integrity in the early medium term (e.g., Mansour, 2001; Henken-
Mellies et al., 2002). However, this type of examination has been conducted only for research
purposes and not as a routine part of barrier system monitoring. Recently, exposure of the
GCLs in several composite liner systems employing the GCL as the low-permeability soil
layer beneath the geomembrane has shown that GCL seams can separate as a result of
environmental effects (Thiel and Richardson, 2005). The GCL seams in these cases were
generally exposed because of other performance concerns (e.g., during repair of mechanical
defects to the overlying geomembrane). The accidental discovery of GCL seam separation
indicates the value of direct monitoring of barrier components. Most barrier system
components are hidden from view after construction, and thus component defects will not be
identified until performance problems appear elsewhere in the system.”
Leachate Collection and Removal System Problems.
The key to preventing groundwater
pollution by a dry tomb landfill, or, for that matter, by a leachate recycle (so-called “bioreactor”)
landfill, is the ability to collect all leachate that is generated in the landfill in the leachate
collection and removal system. Such systems, to the extent that they function as designed, can
reduce the total amount of pollution of groundwaters by leachate generated in a landfill. This
is particularly important during the time that the landfill is open to the atmosphere, and
precipitation that falls on the landfill becomes leachate. Leachate collection and removal
systems, however, as currently designed, are subject to many problems. In principle, leachate
that is generated in the solid waste passes through a filter layer underlying the waste which is
supposed to keep the solid waste from infiltrating into the leachate collection system (see Figure
1). The leachate collection system consists of gravel or some other porous medium, which is
designed to allow leachate to flow rapidly to the top of the HDPE liner. Once it reaches the
sloped liner, it is supposed to flow across the top of the liner to a collection pipe, where it will be
transported to a sump, where the leachate can be pumped from the landfill. According to
regulations, the maximum elevation (depth) of leachate (“head”) in the sump is to be no more
than one foot. However, leachate collection systems are well known to be prone to plugging.
Biological growth, chemical precipitates, and “fines” derived from the wastes all tend to cause
19
the leachate collection system to plug. This, in turn, increases the head of the leachate above
the liner upstream of the area that is blocked. While there is the potential to back-flush some
of these systems, this back-flushing will not eliminate the problem.
The basic problem with leachate collection systems’ functioning as designed is that the HDPE
liner, which is the base of the leachate collection system, develops cracks, holes, rips, tears,
punctures or points of deterioration. When the leachate that is passing over the liner reaches
one of these points, it starts to pass through the liner into the underlying clay layer. If the clay
layer is in intimate contact with the HDPE liner, the rate of leakage through the clay is small.
If, however, there are problems in intimate contact between the clay and HDPE layers, such
as a fold in the plastic sheeting, then the leakage through the hole in the HDPE layer can be
quite rapid. Under these conditions, the leachate spreads out over the clay layer and can leak
at a substantial rate through the clay.
The theoretical rate of leakage through a clay liner, if it is constructed properly and has, at the
time of construction, a permeability of 10
-7
cm/sec with 1 ft of head, is about 1 in/yr. Therefore,
since the clay liner should be a minimum of 2 ft thick, leachate in the areas of the liner where
there is 1 ft of head will penetrate through holes in the HDPE and then through the clay liner in
about 25 years. There are several reasons, however, why the penetration through the clay liner
could be much more rapid. These include desiccation cracking of the clay associated with the
vadose zone transport of the moisture that is used to achieve optimum moisture density at the
time of clay liner construction, which moves by gravity out of the clay into the underlying strata.
Plugging of Leachate Collection Systems. An issue that is not adequately addressed in landfill
permitting applications is that municipal landfill leachate is well-known to cause plugging of the
leachate collection and removal system, thereby allowing greater than one foot of head on the
liner on the upgradient side of the plugged area. This plugging arises from chemical
precipitation and biological growths. The buildup of head (leachate depth) on the liner leads to
greater rates of leakage than would occur if the depth of leachate were less than the one foot
allowed in Subtitle D regulations. While some landfill owners and their consultants claim that
they can clean out the leachate collection system and thereby eliminate any plugging, in fact such
cleaning can only partially address the plugging problem. Further, this plugging problem will
continue long after the end of the 30-year mandatory postclosure care period when leachate
collection system clean-out could potentially be implemented.
It is appropriate to conclude that landfill liners of the type proposed for a minimum Subtitle D
landfill, while possibly providing short-term protection of groundwater quality, are not
reliable for long-term protection and will ultimately fail to prevent leachate from passing
through them. This will result in pollution of groundwater underlying and downgradient from the
landfill area, rendering the groundwater unusable for domestic and many other uses.
Unreliable Evaluation of the Long-Term Integrity of Landfill Covers
.
Subtitle D landfills are
allowed to be closed with a landfill cover consisting of a soil layer above the wastes shaped to
serve as the base for a low-permeability plastic sheeting layer, which is overlain by a one-
to two-foot-thick drainage layer (Figure 1). Above the drainage layer is a few inches to a foot
or so of topsoil that serves as a base for a vegetative layer. The vegetative layer is designed
to promote the growth of vegetation that will reduce the erosion of the landfill cover. In
principle, this landfill cover is supposed to allow part of the moisture that falls on the
20
vegetative layer of the landfill to penetrate through the root zone of the vegetation in this
layer to the porous (drainage) layer. When the moisture reaches the low-permeability plastic
sheeting layer, it is supposed to move laterally to the outside of the landfill by flow upon the
plastic sheeting layer in the cover.
Landfill permit applicants and their consultants as well as some regulatory agency staff will
claim that the eventual failure of the landfill bottom liner system is of limited significance in
leading to groundwater pollution, since the landfill cover can keep the wastes dry, and thereby
prevent leachate generation. Figure 2 presents the processes that affect the integrity of landfill
covers. As shown there are a variety of processes that can lead to landfill cover integrity
failure.
Landfill permit applicants and their consultants, as well as some governmental agency staff
who support a single composite liner system, will, at permitting hearings, show a picture of
landfill leachate generation once the landfill is closed with a low- permeability cover. This
image shows that the leachate generation rate in the closed landfill is greatly curtailed within a
year after the cover is put in place. While they would like to have others believe that this
situation will continue to exist in perpetuity, it will not because of the eventual deterioration of
the plastic sheeting layer in the landfill cover. This issue is discussed further below.
Another deception with respect to landfill covers is that they can be effectively monitored to
detect when moisture leakage through the cover occurs. The typical monitoring approach that
is advocated by landfill owners and operators and allowed by regulatory agencies involves a
visual inspection of the surface of the vegetative soil layer of the landfill cover. However, as
discussed by Lee and Jones-Lee (1995a, 1998a, 2004a), since the low-permeability layer
(plastic sheeting) is buried below topsoil and a drainage layer, it is not possible to detect when
the plastic sheeting layer deteriorates sufficiently to allow moisture that enters the topsoil and
drainage layer to pass into the landfilled wastes.
Figure 2
Factors Affecting Landfill Cover Integrity
21
Distressed vegetation on the cover is not reliable for detection of plastic sheeting layer
failure. If cracks or depressions are observed in the topsoil layer, these are filled with soil.
Such an approach will not detect cracks in the plastic sheeting layer. As a result, the
moisture that enters the drainage layer, which comes in contact with the plastic sheeting
layer and which, when the plastic sheeting is new and constructed properly, runs off of the
landfill, will instead penetrate into the wastes. This could occur at any time during the
postclosure care period, and the increased leachate generation would be detected. However,
it could also readily occur in year 31 after closure or thereafter, when there could be no one
monitoring leachate generation, collection and removal.
Unless the landfill owner agrees to install, operate, and maintain in perpetuity, a leak-
detectable cover for the landfill, the landfill cover system will fail to prevent entrance of
moisture into the landfill and generation of leachate, even if it meets minimum Subtitle D
requirements that are typically accepted by regulatory agencies. The leachate will, in turn,
pass through the deteriorated bottom liner system into the underlying groundwaters.
Further, even if failure of the landfill cover were detected, the typical postclosure funding
that is allowed does not provide adequate funds to determine the location in the low-
permeability layer of the landfill cover that has failed and to repair it. In developing the
amount of required postclosure funding, it is assumed by the regulatory agencies that the
low-permeability plastic sheeting layer in a dry tomb landfill cover will maintain its
integrity throughout the 30-year postclosure care period, even though it is understood that
the plastic sheeting layer in a landfill cover is subject to significant stresses due to
differential settling of the wastes that can lead to its failure to prevent moisture from
entering the wastes.
Leak-Detectable Covers. The high probability of failure of the low-permeability layer of
the landfill cover is the reason why Lee and Jones-Lee (1995a) advocate the use of leak
detectable covers on landfills, which are operated and maintained in perpetuity – i.e., as
long as the wastes are a threat. This approach requires that a dedicated trust fund be
developed that is of sufficient magnitude to ensure that, at any time in the future while the
wastes are still a threat (typically, forever), the leaks in the cover can be isolated and
repaired.
This long-term financial commitment to maintaining a low-permeability cover on the
landfill would significantly increase the cost of solid waste management. This is the
political reason that regulatory agencies, from the US EPA through the state agencies,
typically do not implement the dry tomb landfilling approach so that it addresses the long-
term problems associated with this landfilling approach. Until this issue is meaningfully
addressed, today’s dry tomb landfills at best are façades with respect to their ability to
protect public health and the environment from landfilled wastes for as long as the wastes
in the landfill will be a threat.
The situation is that no political entity – from the federal administration in power through the
federal Congress, state governors and legislatures, to county Boards of Supervisors – wants to be
responsible for causing those who generate solid waste (the public and commercial and industrial
firms) to pay the true cost of its management/disposal. It is estimated that solid waste disposal
that is truly protective of public health and the environment would double to triple the cost of
22
solid waste management. Instead of increasing everyone’s cost of solid waste management
by 15 to 25 cents per person per day, the political entities are opting for short-term protection,
and passing these costs on to future generations in terms of lost groundwater resources and
adverse impacts on the health, welfare and interests of those in the vicinity of the landfill.
Alternative Cover Design. Subtitle D regulations require that the landfill cover be no more
permeable than the bottom liner. This is typically interpreted to mean that the landfill cover
should include a plastic sheeting layer as the low-permeability layer. However, Subtitle D
regulations allow alternative cover designs that provide the same degree of control of moisture
entering the landfill as a cover that contains a plastic sheeting layer. This alternative approach to
cover design requires a demonstration of equivalency to the plastic sheeting based cover. The
demonstration of equivalent performance is based on HELP model calculations which purport to
show that a proposed soil cover for a landfill will have a permeability that is equal to or less
than a cover with a plastic sheeting layer.
A critical review of the HELP model calculations shows that a key component of the calculations
of the expected amount of percolation of water through the cover into the wastes is the assumed
permeability of the low-permeability layer of the cover. Typically, landfill consultants assume
that the construction of the cover will achieve the design permeability. Further, and most
importantly, they assume that the design permeability of the cover will be maintained over the
period of postclosure care (30 years) and throughout the period that the wastes in the landfill
will be a threat. However, no information is provided on the permeability of the cover over
the period of time that the wastes in the landfill will be a threat – i.e., effectively, forever.
In the late 1980s/early 1990s, the US EPA conducted a series of seminars on RCRA/CERCLA
landfill design issues. One of these was devoted to “Design and Construction of
RCRA/CERCLA Final Covers” (US EPA, 1990). Included in the seminar notes was a section
developed by Dr. David Daniel, then of the University of Texas, Austin (Daniel, 1990), which
presented “Critical Factors in Soils Design for Covers.” Dr. Daniel, in the appendix to his
presentation, presented a paper by Montgomery and Parsons (1989), which summarized the
results of a three-year study conducted in cooperation with the state of Wisconsin on the
performance of various types of landfill soil covers. The Montgomery and Parsons study was
conducted on three different 40 ft x 40 ft test plots near Omega Hills, Wisconsin, which is near
Milwaukee. Daniel (1990) summarized the results, where, after three years,
•
“Upper 8 to 10 in. of clay was weathered and blocky
•
Cracks up to 1/2 inch wide extended 35 to 40 inches into the clay
•
Roots penetrated 8 to 10 inches into clay in a continuous mat, and some roots
extended into crack planes as deep as 30 in. into the clay”
Daniel also discussed the problems with soil/clay covers in withstanding stress-strain
relationships associated with differential settling of the wastes under the cover, where he
pointed out that differential settling can readily lead to cracks in the soil cover.
The NRC (2007) report states,
“Finally, a capability to predict the occurrence and impact of local heterogeneities in soil on the
flow through cover systems does not yet exist. Most predictions are based on models that
assume the properties of each soil layer in a cover system are homogeneous. However, the
existence of local heterogeneities resulting from compaction, settlement induced cracking, and
23
desiccation can result in significant differences between predicted and actual performance.”
There is an effort to reduce the cost of closing MSW landfills by placing solar cells in the plastic
sheeting cover of a landfill. The Center for a Competitive Waste Industry (2011) has issued a
report. “Information Alert to State Environmental Agencies Regarding Landfill Solar Panels”
that discusses the potential problems with this approach for providing landfill closure covers.
According to this report,
“Closed landfills have been proposed as the site for installing a layer of solar photovoltaic cells
with a geomembrane substrate in lieu of prescriptive Subtitle D final covers. Such integrated
solar caps would provide renewable electricity as a benefit. Less well understood is the risks
and associated costs posed to the states where these landfills are located. Because these new
caps omit so many critical features of traditional covers, the prospect cannot be ignored of future
site failures that may cost tens of millions of dollars to remediate. Current financial assurances
provide no funds for these types of costs. Therefore, rigorous reviews should be give before
permitting solar caps as legitimate alternative covers, and if they are permitted, in the face of
substantial uncertainties, additional financial assurances should be required as a condition of
the permit in order to protect the state’s taxpayers.”
This report provides a discussion of the potential problems with using landfill cover plastic
sheeting with solar cells. This report is available http://www.gfredlee.com/Landfills/CCWI-
LFSolarCap.pdf
An alternative to conventional Subtitle D landfill cover design is the development of a ET cover.
This cover approach is based on potential evapotranspiration (PET) that exceeds the actual
supply of water (precipitation). Dryer (2003) and Dryer et al. (2000) have presented
information on this approach. While the average monthly evapotranspiration exceeds the
monthly average precipitation would lead to the conclusion that no moisture would enter the
wastes through the cover, periods of above average precipitation could lead to some moisture
that penetrates through the cover into the wastes. This in turn could lead leachate generation
that can lead to groundwater pollution. The evaluation of an ET cover should not be based on
monthly average net moisture flux through the cover but on worst case situations for wet
periods.
It is inappropriate to assume that the design permeability of the soil cover for a landfill will be
applicable to controlling the amount of moisture that enters the wastes through the cover for
as long as the wastes in the landfill will be a threat. What will actually occur at proposed
landfills with alternative landfill covers is that within a few years after construction of the
cover the permeability of the cover will increase due to desiccation and differential settling
cracks. Over time, vegetation roots will also increase the permeability of the cover. Therefore,
the so-called equivalency of the soil cover to the plastic sheeting based cover will no longer
hold.
Rogoff et al. (2012) published “Can ADCs Work for Your Landfill? “that provides
background information on the issues associated with the use of alternative daily cover (ADC)
instead of the typical 6” of soil placed on the day’s waste. This article provides a good
summary of the potential and some of the problems with this approach. It however fails to
discuss the issue of the release of a slug of landfill odors when the daily cover material such
as a removable cover such as a tarp is removed in the morning before additional landfilling
occurs.
24
New SWANA Report Focuses on Landfill Long-Term Cover Management Issues
According to a feature article in the January 22, 2021 Waste Advantage Newsletter
[https://wasteadvantagemag.com/new-report-focuses-on-landfill-long-term-management-
issues/], on January 7 “A new report developed by the Solid Waste Association of North
America (SWANA) Applied Research Foundation (ARF) addresses two important questions
associated with the landfill disposal of waste – namely, what tasks will be required to manage
closed landfills following the post-closure care period to ensure continued protection of
public health and the environment and how will their associated costs be paid for? The
SWANA Applied Research Foundation (ARF) recently conducted important research on the
long-term management (LTM) that will be needed for closed landfills following the 30-year
post-closure care period required under current regulations.
“The resulting report addresses key issues such as the expected service life of the landfill’s
final cover system and the tasks that will need to be performed to ensure the long-term
protection of public health and the environment. The report also addresses the issue of how
long-term management activities can be financed.
“ ‘SWANA continues to be at the forefront of identifying solutions to challenging solid waste
issues, and this important new report provides useful information and data for solid waste
managers and their communities,’ stated David Biderman, SWANA Executive Director and
CEO. “We need to assure the public that today’s landfills will not only provide communities
with needed solid waste disposal services but that they will continue to protect public health
and the environmental for hundreds of years following their closure,” he added.
“The report provides reassuring evidence regarding the efficacy of the federal design
standards that have been established for these facilities. For example, the research study
concluded that it is unlikely that the geomembrane in the landfill’s final cover system would
need to be replaced for 2,000 years following its installation. “We appreciate the support
and involvement of our Disposal Group subscribers who submitted and voted for this
important research topic and provided funding support for the research effort,” said Jeremy
O’Brien, SWANA’s Director of Applied Research.
For more information, visit https://swana.org/resources/research ”
SWANA says of itself (https://swana.org): “The Solid Waste Association of North America
(SWANA) is an organization of more than 10,000 public and private sector professionals
committed to advancing from solid waste management to resource management through their
shared emphasis on education, advocacy and research.”
It has been found over the years that SWANA and ARF have presented distortions of
information on the characteristics and abilities of US EPA Subtitle D landfills to provide for
true, long-term protection of public health and environmental quality for as long as wastes in
the landfill present a threat. As discussed above, there is considerable information in the
professional literature that takes issue with the claim quoted above, “For example, the
research study concluded that it is unlikely that the geomembrane in the landfill’s final cover
system would need to be replaced for 2,000 years following its installation.” It is not clear if
SWANA ARF intends for that statement to mean that a plastic sheeting liner in a landfill
cover will prevent entrance of water into a landfill through holes in the cover for 2000 years
25
without failure.
Based on the information in that Waste Advantage Newsletter, in order to review this
SWANA ARF report it is necessary to become a member of SWANA ARF and pay the
membership fees. It is our finding that the release of the SWANA report is designed to be of
value to the solid waste industry and not the public that is or will be impacted by a solid waste
landfill. As discussed above there is considerable technical literature that the plastic sheeting
liner required in Subtitle D landfills will have imperfections (holes) that will allow water that
falls on the top of the liner to pass through it and enter the underlying solid wastes. This
water will generate leachate that will pass through a composite liner and enter the
groundwater rendering it unusable for domestic and many other purposes. The ARF report
is another example of SWANA ARF reports that provide unreliable information on the long
term public health and environmental protection provided by Subtitle D municipal solid waste
landfills.
Landfill Cover Area Reuse.
Waste Management, Inc. has made claims on national TV ads
that its closed landfills make ideal wildlife habitat, and sites for golf courses and public
recreation areas including dirt bike trails. Such claims appear in its “Think Green”
campaign at http://www.thinkgreen.com/ in its discussion of “Beneficial Land Reuse,” as well
as in a number of television advertisements. It cites locations at which such reuse has been
made of landfill cover areas. The unmistakable implication is that the public should not be
concerned about the potential long term threats to public health, groundwater and surface water
quality, or to wildlife, at a closed landfill. However, as discussed by Lee and Jones-Lee (1994b)
in their paper entitled, “Closed Landfill Cover Space Reuse: Park, Golf Course, or a Tomb?” many
of the touted reuse activities atop closed landfills are ill-advised at best, and such
implications are highly misleading. One reason for this is that many of the land
“enhancements” and activities being promoted stand to damage the integrity of the landfill
cover upon which the integrity of the landfill containment system depends. As discussed
elsewhere herein, in order to prevent formation of landfill gas and leachate that will
eventually escape the landfill containment, the wastes must be kept dry. Placing water
features such as ponds, wetlands, idyllic streams, or water hazards on a golf course, or deep-
rooted vegetation such as trees and shrubs, atop or in close association with landfill covers
promotes entrance of moisture into the cover.
Closing Unlined Landfills.
The final closure of unlined sanitary landfills is typically
accomplished by installing a base-to-final cover of soil of a few inches to several feet thick. This
layer is designed to provide a suitable structural base for the low-permeability layer in the cover.
On this layer is placed a 1 to 2-foot-thick compacted soil layer with a permeability, at the time
of construction, of 10
-6
to about 10
-7
cm/sec. The purpose of this layer is to reduce the
penetration of moisture into the landfilled wastes. At some locations, a plastic sheeting layer
is used instead of the compacted soil layer as the low-permeability layer in the cover.
On the low-permeability layer is placed a several-foot-thick drainage layer that is covered by
a few inches to a foot or so of topsoil. The topsoil layer serves as a base for establishing
vegetation that can reduce erosion of the landfill cover. The underlying drainage layer allows
moisture, which is needed to keep the vegetation in the topsoil layer alive, to penetrate
through the topsoil layer to the low-permeability layer where it can runoff on this layer to the sides
of the landfill. Basically this approach is a variation of the dry tomb approach, where it is
26
believed that if the moisture supply to the landfilled wastes is curtailed, the rate of landfill gas
and leachate generation will be reduced/curtailed.
This approach for final closure of an existing unlined landfill has several of the same problems
as the closure of minimum design Subtitle D landfills. Typically regulatory agencies will
allow landfill owners and their consultants to make HELP calculations on the rate of water
penetration through the compacted soil layer in the cover, where it is assumed that the design
permeability of the cover will be applicable to the infinite period of time that the closed
landfilled wastes will be a threat to generate leachate upon contact with water. However, it is
known that the compacted soil/clay layer in the landfill cover can crack within a short time after
installation and allow water that penetrates through the topsoil and drainage layer to enter the
landfilled wastes through the cracks in the low-permeability layer. The HELP model
calculations of moisture penetration into the closed landfill are unreliable a few years after
landfill closure for predicting the moisture that will enter the wastes through the cracked
compacted soil layer. This cracking is associated with desiccation of the compacted soil layer
associated with loss of the moisture that is used to achieve compaction of this layer as well
as drying of this layer during period of no/low precipitation.
If plastic sheeting is used as the low-permeability layer in the cover it will be subject to stress
cracking and free radical degradation which can occur at a higher rate than in the bottom HDPE
liner typically used at Subtitle D landfills. When this deterioration of the plastic sheeting layer
occurs, water that is supposed to be transported off the plastic sheeting layer to the sides of the
landfill will penetrate into the wastes and generate leachate. The failure of the compacted soil
layer or the plastic sheeting layer in the landfill cover will not likely be visible from the
surface of the landfill since it is buried under several feet of topsoil and a drainage layer.
Some landfill owners and their consultants claim, with support by some regulatory agency,
that the failure of the low-permeability layer in the closed unlined landfill will be detected
by groundwater monitoring. While a few downgradient groundwater monitoring wells normally
can readily detect groundwater pollution by unlined landfills, the closed unlined landfills have
the same problems of the minimum design Subtitle D landfills, where narrow plumes of
leachate will initially be generated associated with the penetration of the water through
the low-permeability layer of the cover. Rather than the pollution of groundwater occurring
under the whole area of the landfill, the new groundwater pollution in a closed landfill will occur
under the areas where the low-permeability layer in the cover fails to prevent water from
entering the wastes. Typically a much more extensive downgradient groundwater monitoring
well array is needed for a closed unlined landfill than an unlined landfill that does not
have a low- permeability layer in the cover. In developing this array, the landfill owner should
be required to have a consultant determine the number and location of monitoring wells that will
be needed to reliably detect a new leachate-polluted groundwater plume that could arise from
cracks and points of deterioration that occur in the low-permeability layer of the cover. This
evaluation should consider the site-specific characteristics of the hydrogeology of the area
underlying the landfill as well as the potential for leakage from any location in the landfill
footprint.
Landfills at Superfund Sites.
As part of remediation of Superfund and other hazardous
chemical sites, onsite or nearby landfills are sometimes used to store so-called “nonhazardous”
wastes. As discussed below, these wastes, while classified by the US EPA as nonhazardous, can
27
readily contain large amounts of known hazardous chemicals that are a threat to human health
and the environment. Further, these wastes can contain a large number of unidentified,
unregulated hazardous chemicals as a result of the limited approach that is allowed to be used to
identify constituents of concern at Superfund sites. Lee and Jones-Lee (2004b) and Lee (2003b)
have discussed the potential problems with using onsite and nearby Subtitle D landfills for
hazardous chemical site remediation. These are the same problems that occur with Subtitle D
landfills for MSW, with the addition that Superfund site onsite landfills often are a greater threat
to public health because of the types of wastes that are allowed to be deposited in these landfills.
At some Superfund sites existing waste piles (such as mine tailings) are “remediated” by
placing a low-permeability cover over the waste pile. This approach only postpones
additional groundwater pollution by the waste pile. Lee and Jones-Lee (2003) have discussed
this type of situation for the Lava Cap Mine Superfund site located in Nevada County,
California. This site is a former gold mine that has large amounts of mine tailings that contain
elevated concentrations of somewhat leachable arsenic. The US EPA, which is the lead agency
for this Superfund site investigation, concluded that capping a arsenic containing tailing pile was
the most economical method for remediation of this area. However, the economic calculation
allowed by the Agency only considered short-term effectiveness of the capping and failed to
consider that the tailings in the capped area would be a threat to generate leachate which has
arsenic concentrations that are a threat to human and some animal health. The US EPA does
not include in its economic evaluation of Superfund site remediation approaches, the eventual
failure of the landfill cap and the additional costs of site remediation that will have to be done
at some time in the future. Lee and Jones-Lee (2005a) have discussed the need to consider
both the short-term and long-term costs and impacts of landfilling of wastes in selecting
contaminated site remediation approaches.
A special case of Superfund site remediation approaches is the US EPA’s “Presumptive
Remedy” for “remediation” of municipal landfills at Superfund sites. Several years ago, the
Agency adopted the Presumptive Remedy for a MSW landfill at a Superfund site of capping
of the landfill with a low-permeability cap. Such a cap is subject to all the issues that are
discussed above for capping unlined landfills. This remedy is allowed by the US EPA without
determining whether the landfill is polluting groundwater. This approach is another of the
short-sighted approaches toward managing solid wastes, where the true long-term costs and
impacts are not considered in Superfund site investigation/remediation.
Lee (2006a) discussed the potential problems of allowing the use of the Presumptive Remedy for
remediation of three landfills located at the University of California, Davis
(UCD)/Department of Energy (DOE) LEHR national Superfund site located on the UCD
campus. Even though the hydrogeology of the strata underlying these landfills is fairly
homogeneous and can be monitored for landfill liner leakage for landfills that have a soil
layer as a cap (i.e., classical sanitary landfills), once a low-permeability cap is installed on
the landfill as part of the Presumptive Remedy approach, the ability to monitor groundwater
pollution that will occur at some time in the future becomes much more difficult. This is the
result of the low-permeability cap allowing water to enter the landfill at limited locations.
Under the soil cap approach, the precipitation could enter the landfill essentially at all
locations through the cap. With the low-permeability cap, those areas where this cap initially
fails to prevent moisture from entering the wastes will generate areas under the landfill where
leachate may pass in limited-dimension plumes. These plumes may not intersect with the
28
generally used monitoring well array for groundwater pollution from classical sanitary
landfills.
In the 1980s the US EPA and states allowed drummed liquid hazardous waste to be buried in
landfills with only a clay liner. At a number of sites it has been found that the regulatory
agencies allow a few monitoring wells spaced at considerable distances down groundwater
gradient from the drummed waste burial area, thus ignoring the fact that the initial pollution of
groundwaters by the liquid hazardous waste will occur from the corrosion of a few drums
through limited-dimension plumes that may not intersect with the monitoring wells. This makes
monitoring of the initial leakage unreliable using vertical monitoring wells spaced hundreds
of feet apart. A possible approach for monitoring of the initial leakage in this type of situation
would be through the use of the SEAMISTTM system, in which, through horizontal drilling
under the landfill liner, an array of vapor phase monitoring wells can be constructed and
monitored to detect hazardous chemicals with an appreciable vapor pressure. Information
and an evaluation of this system is available from the US Department of Energy (US DOE,
1995).
Unreliable Groundwater Monitoring
The Subtitle D requirements for groundwater monitoring – “The design must ensure that the
concentration values listed in Table 1 of this section will not be exceeded in the uppermost
aquifer at the relevant point of compliance” – requires that a highly reliable groundwater
monitoring system be developed for Subtitle D landfills. The point of compliance for
groundwater monitoring can be no more than 150 meters from the groundwater gradient edge
of the waste deposition and must be located on the landfill owner’s property. In principal, if such
a program is developed, then the inevitable failure of the landfill liner system will not lead
to offsite groundwater pollution. Landfill developers at landfill permitting hearings frequently
state that the proposed groundwater monitoring system for the proposed landfill will be
consistent with the groundwater monitoring requirements prescribed under 40 CFR Part 258,
§258.51, and has been designed to provide a sufficient number of wells for detection and
assessment monitoring. The landfill developer then typically proposes a groundwater
monitoring system that consists of several groundwater monitoring wells located at hundreds
to a thousand or more feet apart at the point of compliance. A critical evaluation of the
potential reliability of this monitoring approach shows that it has a very low probability of
detecting leachate-polluted groundwaters when they first reach the point of compliance for
groundwater monitoring at minimum Subtitle D landfills.
One of the most significant deficiencies in implementing Subtitle D landfilling regulations is
in the permitting of groundwater monitoring systems for the purpose of detecting the inevitable
failure of the single composite liner to prevent landfill leachate from passing through the liner
into groundwater systems underlying the landfill. Lee and Jones-Lee (1993a, 1998b) presented
comprehensive reviews of groundwater quality monitoring issues for Subtitle D landfills. As
they pointed out, a fundamental problem with typical groundwater monitoring programs for
minimum Subtitle D landfills is that they have been developed based on perceptions of leakage
from
unlined
landfills without proper consideration of the manner in which
lined
landfills
leak and pollute groundwater. Conventional unlined sanitary landfills are expected to leak
leachate over a considerable part of the bottom of the landfill. Therefore, even though the
lateral spread of a plume of leachate-contaminated groundwater can be very limited depending
on the aquifer characteristics (Cherry, 1990), the plume of leachate-contaminated groundwater in
29
some types of geological/hydrogeological strata would move as a wide front downgradient
of the unlined landfill (Figure 3). Under those conditions, well spacing may not be critical for
the detection of groundwater contamination by leachate. However, this is not the character of
initial leakage from plastic sheeting lined landfills.
Figure 3.
Pattern of Landfill Leakage – Groundwater Contamination from
Unlined Landfills (after Cherry, 1990)
The NRC (2007) Committee reports fails to mention/discuss this issue which results in the Committee
failing to properly evaluate the performance of existing Subtitle D landfills in preventing groundwater
pollution.
Initial Liner Leakage can Produce Narrow Plumes of Leachate-Polluted Groundwater.
Bumb et al. (1988) and Glass et al. (1988) discussed that the initial leaking of leachate from
lined landfills will occur from point sources in the liners, rather than uniformly from the landfill
bottom as may be expected from unlined landfills. The initial leaks will occur from holes, rips,
tears and points of deterioration in the plastic sheeting liner. That fact changes the significance
to groundwater monitoring of Cherry’s (1990) finding that the lateral spread of a plume of
leachate-contaminated groundwater is limited. In a study of the lateral dispersion of leachate
plumes from lined landfills, Smyth (1991) of the Waterloo Centre for Groundwater Research,
University of Waterloo, reported that a 0.6-m (2-ft)-wide point-source tracer spread laterally to
a width of only about 2 m (6 ft) after traveling 65 m (213 ft) in a sand aquifer system. Thus, it
is clear that leakage from point sources such as holes in liners can move downgradient as
narrow “fingers” of leachate (Figure 4) rather than in the traditionally assumed fan-shaped
plumes such as shown in Figure 3. This means that conventional wells used for monitoring of
the pollution of groundwaters caused by lined landfills must be placed close enough together
at the point of compliance to detect narrow fingers of leachate, if the monitoring program is to
comply with Subtitle D requirements for the detection of incipient groundwater pollution from
waste management units at the point of compliance.
30
Figure 4. Pattern of Landfill Leakage – Groundwater Contamination from Lined
Landfills (after Cherry, 1990)
The typical groundwater monitoring well used today has a four- to eight-inch diameter
borehole. Such wells are normally purged prior to the quarterly or so sampling, by removal of
three to five borehole-volumes of water. Thus, the zones of capture for such monitoring wells
are on the order of a foot around each well. Since the lateral spread of a finger plume of leachate-
contaminated groundwater from a lined landfill is dependent on aquifer characteristics and can
be minimal, especially for leaks arising on the downgradient edge of the waste deposition area,
monitoring wells that are spaced hundreds of feet apart at the downgradient edge of some lined
landfills have a low probability of detecting the finger plumes of leachate produced by leaks in
the liner system (Figure 4). Those finger plumes of leachate could travel long distances before
groundwater pollution by the landfill is detected.
Parsons and Davis (1992) discussed issues of monitoring well spacing and zones of capture of
monitoring wells associated with waste management units. As they discussed and as illustrated
in Figure 5, in order to have a high probability of detecting leachate leakage from a waste
management unit, the spacing of standard monitoring wells at the point of compliance must be
such that zones of capture overlap. Thus, in order to be effective in achieving the groundwater
monitoring performance standard of Subtitle D, for some landfills, conventional vertical
groundwater monitoring wells would have to be spaced no more than a few feet apart along the
entire downgradient edge of the landfill, creating a “picket fence” of wells.
On May 2008 the CA Department of Toxic Substances Control (DTSC) and the US EPA
Region 9 held a Remediation Technology Symposium (the agenda for which is available at
http://www.dtsc.ca.gov/HazardousWaste/upload/Remediation_Technology_Symposium_Age
nda.pdf). At that symposium Einarson (2008) made a presentation entitled, “Site
Characterization and Monitoring in the New Millenium,” devoted to problems with
conventional groundwater monitoring approaches used at hazardous chemical sites. He
31
Figure 5
Zones of Capture of Standard Monitoring Wells Must Overlap
to Detect Leakage from Lined Landfills (after Parsons and Davis, 1992)
discussed the fact, as Cherry (1990) had nearly two decades ago, that groundwater pollution
plumes emanating from plastic-sheeting-lined landfills tend to have limited lateral spread.
Because of this characteristic, groundwater monitoring wells spaced hundreds of feet apart at
the point of compliance for groundwater monitoring will have a low probability of detecting
groundwater polluted by landfill leachate when it first reaches the point of compliance for
groundwater monitoring.
Landfill groundwater monitoring systems for a single composite liner based on vertical
monitoring wells located more than a few feet apart at the point of compliance for monitoring
is best characterized as “cosmetic” with respect to reliable detecting groundwater pollution by
landfill leachate when it first reaches the point of compliance for monitoring.
The problems of the unreliability of groundwater monitoring in plastic sheeting lined landfills
to detect groundwater pollution before widespread offsite groundwater pollution has occurred
are well-recognized. A number of states, including Michigan in its Rule 641, require double
composite liners for municipal solid waste landfills (see Figure 6). These liners are similar to
those required for hazardous waste landfills. They require that a leak-detection system be used
between the two composite liners to determine when the upper composite liner has failed. This
approach, where the lower composite liner is a pan lysimeter for the upper composite liner, is
a far more reliable monitoring approach for detecting liner leakage than the single composite
liner with wells spaced along the point of compliance. The leachate in each major cell of the
landfill should be monitored at least quarterly for the full suite of pollutants.
32
Figure 6
Double Composite Liner Landfill Containment System
Monitoring of Some Fractured Rock Aquifers Nearly Impossible. The ability to define the
shape and movement of a contaminant finger-plume from a lined landfill depends on the
hydrogeological characteristics of the aquifer-strata. In homogeneous, isotropic “sand”
systems, the vertical and horizontal spread of point source discharges/leaks from a given point
can be estimated with some degree of reliability. However, the hydrogeology of many locations
in which landfills are sited is sufficiently complex so that predictions of the spread of a leachate
plume are fairly unreliable. The presence of fractured bedrock, fissures, cavernous calcareous
strata, and non-isotropic lenticular aquifers (such as former river beds) make the reliable
prediction of flow paths from point-source leaks from lined landfills more difficult or even
impossible and make the monitoring of groundwater for incipient leachate pollution highly
unreliable and virtually impossible.
Haitjema (1991) stated
“An extreme example of Equation (1) (aquifer heterogeneity) is flow through fractured rock.
The design of monitoring well systems in such an environment is a nightmare and usually not
more than a blind gamble.” * * *
“Monitoring wells in the regional aquifer are unreliable detectors of local leaks in a landfill.”
“Even the fact that a monitoring well intercepts a fissure/crack does not mean that the leachate
in that fissure system is reliably sampled during groundwater monitoring. The amount of water
extracted during sampling is typically quite small; the result is that the zone of capture around
the monitoring well, even in a fracture, is often limited. Thus, leachate-contaminated
groundwater can be present in a fracture without its being detected by the monitoring programs
typically used. Therefore, in addition to misconceptions about the nature of the spread of
33
leachate from lined landfills, an incomplete or unreliable assessment of the geological features
of the subsurface system and complex hydrogeology can further reduce the probability that the
groundwater monitoring well array will intercept any initial plume of leachate-contaminated
groundwater at the point of compliance for the MSW landfill monitoring program. This
situation raises significant questions about whether single composite lined landfills should be
allowed to be located above fractured rock aquifer systems, because of the inability to reliably
monitor groundwater pollution in such systems.”
Ponce (2010) in his discussion of the potential problems of the proposed Campo Landfill has
discussed the problems that can occur in siting a landfill on a fractured rock aquifer system. As
discussed this proposed landfill is to be located on top of a highly fractured aquifer system near
the adjacent properties of private land owners whose domestic water supply is derived from a
sole source aquifer. He stated that the fracture traces provide pathways for rapid transport of
leachate polluted groundwater to adjacent property groundwaters that are used for domestic
purposes. Contrary to the statements made by the landfill applicant, the monitoring of the
groundwaters that become polluted by landfill leachate is nearly impossible to achieve reliable
detection of the polluted groundwater before it trespasses onto adjacent properties.
Lee and Jones-Lee (2010a) in their review of the draft Supplemental Environmental Impact
Statement (DSEIS) for the proposed Campo Landfill discussed the inadequate and unreliable
information provided by the landfill applicant on the ability of the proposed Campo Landfill
liner and landfill cover systems as well as the proposed groundwater monitoring systems to
prevent/detect groundwater pollution by landfill leachate for as long as the wastes in this
proposed landfill will be a threat to generate leachate.
Ponce (2010) stated with regard to the siting of the proposed Campo Landfill,
“In summary, the proposed Campo landfill site lies: (1) on top of a fractured rock aquifer, (2)
on a headwater basin where very intense storms are possible, (3) within close reach of the
groundwater, and (4) in a region prone to strong earthquakes. This poses a high risk of
contamination of the designated sole-source aquifer. Significantly, the conjunction of four
natural geologic loads or hazards foretells of disasters waiting to happen. Thus, the project
presents a serious threat to the public health and safety of nearby residents, both on and off the
reservation, as well as to residents of neighboring Mexican communities.”
Lee and Jones-Lee (2007a,b), in their Groundwater Quality Protection Issues review,
summarized their experience in investigating the potential impacts of landfills that are underlain
by a fractured rock or fractured clay aquifer system. This is a fairly common situation, which
can readily lead to groundwater pollution that cannot be reliably monitored. An example of this
type of situation occurred under the Sydney Tar Ponds in Sydney, Nova Scotia, Canada. Lee
and Jones-Lee (2006b) and Lee (2006b,c,d) have discussed the situation that has developed
where about 100 years of steel-making with essentially no pollution control led to pollution of
the estuarine sediments near Sydney, Nova Scotia, with PAHs, PCBs and a variety of other
pollutants. It is estimated that to remediate this situation will require about $400 million. One
of the problems at this site is that it is underlain by fractured rock, where in some areas there is
flow from the fractured rock into the sediments, and in others, there is flow from the polluted
sediments into the fractured rock. The latter provides a pathway for pollutants to pass from the
sediments under any barriers that are constructed above the fractured rock, and eventually
pollute the estuarine waters downstream of the barriers. Additional information on this situation
is available on the Sierra Club of Canada’s website, www.safecleanup.com.
34
Regulatory Agency Should Evaluate Ability of Groundwater Monitoring System to Detect
Initial Groundwater Pollution
. It is recommended that regulatory agencies, as part of the
permitting of a proposed landfill, conduct a site-specific evaluation of the ability of the
proposed monitoring well array to detect leachate-polluted groundwaters at the point of
compliance all along the downgradient edge of the landfill from leaks that occur from holes,
rips, tears or points of deterioration in the HDPE liner. In making this evaluation it should be
assumed that the leak would occur through a two-foot long area at any point in the landfill
footprint, including especially near the downgradient edge of the landfill.
Further, the regulatory agency should determine the spacing of vertical monitoring wells at the
point of compliance that should occur in order to have at least a 95 percent probability of
detecting such leaks when they first reach the point of compliance for groundwater monitoring.
Conducting such an evaluation for most Subtitle D landfills will show that the proposed
monitoring well array along the down groundwater gradient edge of the landfill is not reliable for
protecting offsite groundwaters from pollution by landfill leachate. For those landfills sited
above fractured rock aquifers, the regulatory agency should be required to discuss in detail how
leachate-polluted groundwaters that enter the fractured rock aquifer will be detected with a
reliability of at least 95 percent.
Potential Change in Direction of Groundwater Flow
.
Another issue that needs to be
considered in permitting landfills is the potential for a change in groundwater flow direction
under and near the landfill. Because of the potential for adjacent and nearby properties to
construct groundwater wells that could influence the local direction of groundwater flow in the
vicinity of the proposed landfill, it will be essential that an ongoing groundwater flow direction
evaluation be conducted to determine if new offsite production wells change the direction
of groundwater flow and thereby lead to a requirement for additional monitoring wells in the
new downgradient direction. That which is perceived to be down groundwater gradient at the
time of landfill permitting will not necessarily be downgradient in the future. This type of
monitoring program review will need to be conducted effectively forever, because of the very
long period of time that the proposed Subtitle D landfill has the potential to pollute
groundwaters with landfill leachate.
Evaluation of Leachate Density.
According to Cherry (pers. comm., 1991), leachate from
municipal landfills can contain sufficient amounts of salt to cause them to be somewhat more
dense (heavier per unit volume) than the groundwaters of the area. This would cause a finger-
plume of leachate to sink along its horizontal trajectory until it becomes sufficiently diluted
so that its density matches that of the area groundwater. The hydrogeology and the groundwater
characteristics of the area beneath and downgradient from a landfill must be defined with a high
degree of certainty as part of permitting a landfill groundwater monitoring system, if a
potentially meaningful groundwater monitoring program is to be developed to detect landfill
leakage. Particular attention needs to be given to the depth of monitoring well screens that are
designed to intercept the layer of leachate-polluted groundwater. The vertical position of the
leachate plume that will occur at the point of compliance for groundwater monitoring should
be predicted as part of permitting a landfill. Based on this prediction, the screening of
monitoring wells to detect the maximum concentration of the leachate-polluted groundwaters at
the point of compliance should be determined.
Some regulatory agencies allow monitoring wells that include well screening length over the
35
depth of the aquifer. Substantial long-screened monitoring wells could withdraw from the
aquifer large amounts of water that is not likely polluted by landfill leachate, thereby diluting the
leachate-polluted water, which could lead to the inability to reliably detect a leachate plume that
occurs in a narrow vertical band underlying the point of compliance for groundwater
monitoring. A nested well sampling of various depths should be used, rather than a long-screen
well.
State’s Responsibility to Require Reliable Groundwater Monitoring.
In a personal
communication to G. F. Lee regarding the eventual leakage of single composite landfill liners
and the unreliability of the groundwater monitoring systems being permitted by states, US EPA
Headquarters Solid Waste staff (Geshwin) indicated that the inadequate groundwater monitoring
systems being permitted by state regulatory agencies are not the result of a deficiency in RCRA
Subtitle D regulations. Rather, he indicated that it was the responsibility of the state regulatory
agencies to ensure that the groundwater monitoring system permitted for a landfill will detect
leachate-polluted groundwater when it first reaches the point of compliance for groundwater
monitoring.
Responsibility for Long-Term Monitoring.
Landfill proponents sometimes state that
groundwater monitoring for the Detection Monitoring Program will be performed on a periodic
basis during the active life of the landfill, as required by 40 CFR Part 258, Section 258.54(b).
The active life of a landfill is the period during which wastes are received by it. The regulatory
agency, as part of permitting a landfill, needs to specify who will be responsible for monitoring
groundwaters during the 30-year postclosure period, which begins at the end of the active life
of the landfill, and during the hundreds to a thousand or more years that the landfill will be a
threat to generate leachate that will pollute groundwaters.
The NRC (2007) Committee report states with regard the Monitoring Periods,
“The optimum time for monitoring varies with the facility, type of waste, climate, and the
observed performance. Yet funding is often not available to continue monitoring until the site no
longer poses risk to human health and the environment, and no national policy exists to assure
that such funding will be available.”
Recommendation 6: EPA should develop financial assurance mechanisms to ensure that
funding is available for monitoring and care for as long as the waste poses a threat to human
health and the environment.”
Frequency of Groundwater Monitoring.
Landfill owners typically attempt to gain regulatory support for reducing the frequency of
monitoring of groundwaters during the postclosure period. The approach that should be
followed to enable reduced frequency of groundwater monitoring (such as from quarterly to
semi-annually) should be based on an evaluation of the ability to predict with a high degree
of reliability the composition of the groundwaters that will be found at the next monitoring
event. If it is found that it is possible to reliably predict the groundwater composition within
a 95 percent confidence interval, then the frequency of monitoring can be reduced. However,
if at any time in the future the predictability of the monitoring results no longer continues,
then the frequency of monitoring should be increased. The same approach should be used to
adjust the frequency of landfill gas monitoring and monitoring of the integrity of the landfill
containment system.
36
Vertical Migration of Leachate-Polluted Groundwater in Wells
Einarson (2008) discussed the concern about the potential for vertical transfer of water and
associated pollutants within monitoring and production wells, as well as other wells, that are
screened in two aquifers or that are not effectively sealed between the aquifers. There is need
to consider the potential for transfer of water and pollutants between aquifers within a
monitoring well at a landfill site. While it is often assumed by consultants to landfill applicants
as well as by some regulatory agency staff that a low-permeability layer prevents the pollution
of a lower aquifer, Einarson pointed out that there is often vertical transfer between stacked
aquifers within monitoring wells. Fairly well-known, but frequently ignored, is the fact that
the conventional approach for sealing wells with bentonite may not be effective in the short-
term, or in the long term, in hard-water systems because of cation exchange reactions between
sodium bentonite and calcium ions that lead to shrinking and cracking of the seals. Those issues
have been reviewed by Lee and Jones-Lee (2006a), who also provide references to the work of
others on the topic.
Leachate Management
Lee and Jones-Lee (1996) have discussed MSW leachate management. Fickes has discussed
approaches often used by landfill owners/operators to dispose of MSW leachate. Lee (2011d)
has discussed that this article fails to discuss the potential public health and environmental
problems with the associated with the approaches that are used to manage MSW.
Unreliable Information on Detection of Landfill Liner Failure
A comment that is sometimes made by landfill proponents, their consultants, and some
regulatory agency staff, in an attempt to support the reliability of single composite liners, is that
there are no recorded instances where a single composite liner has been found to have failed.
However, Lee and Jones-Lee (1999a) have discussed the inappropriateness of making this
statement in support of the near-term, much less the long-term, ability of single composite
liners to prevent groundwater pollution by landfill leachate for as long as the wastes in the
landfill will be a threat. As Lee and Jones-Lee point out, in 1999 single composite liners had
only been a national requirement for six years. With adequate quality assurance/quality control
(QA/QC) in the construction of a single composite liner, leakage through that liner should not
have occurred in 11 years. It should take longer than this to penetrate the clay component of
the liner. Further, as discussed above, with inadequate QA/QC and/or inappropriate waste
deposition which results in puncturing the plastic sheeting layer, and cracks developing in the
clay layer underneath the areas of puncture, the plumes of leachate-polluted groundwater
would either not yet have reached the point of compliance for groundwater monitoring or
would not be detected at that point by the monitoring wells which are spaced too far apart
relative to their zones of capture.
What is known (pers. comm., New York DEC staff) is that double composite lined landfills
constructed in a number of areas (such as New York state) have leaked leachate through the
upper composite liner into the leak detection system between the two liners within a few years
after construction. This is likely the result of inadequate QA/QC in upper composite
liner construction and/or inappropriate waste placement in the landfill.
The failure to detect minimum Subtitle D landfill liner failures in the short period of time that
such liners have been used is no indication of the long-term behavior of these liners in preventing
groundwater pollution by landfill leachate for as long as the wastes in these landfills will be a
threat.
37
Impact of Seismic Activity on Integrity of Landfill Containment Systems
Anderson (1995) published a summary review of the California Integrated Waste Management
Board (CIWMB)’s evaluation of the impact of seismic activity on the integrity of MSW landfill
containment systems based on the CIWMB staff’s site inspections of about a dozen landfills
following an earthquake. Anderson reported that the containment system of many of the
landfills inspected showed damage that was attributed to the earthquake. He reported,
“Damage to landfills observed by the IWMB staff is categorized into four groups: 1. cracking
of daily, intermediate, or final covers; 2. damage to liners; 3. damage to environmental
collection and control systems; and 4. damage to infrastructure such as water tanks and on-
site structures.”
His review included a discussion of each of those categories. In addition to visual damage to the
landfill containment system, there can be subsurface damage to the leachate collection
system, liners, and other components that may not become apparent for many years. Such
hidden damage is of particular concern at minimum design, single-composite-lined, Subtitle D
landfills. As discussed herein, liner failure in a minimum design Subtitle D landfill will most
likely first be detected in offsite production wells. This is expected because the typical
groundwater monitoring wells arrays allowed by regulatory agencies consist of vertical
monitoring wells spaced hundreds of feet apart at the point of compliance for groundwater
monitoring. Such a system has a low probability of meeting the Subtitle D requirement to detect
leachate-polluted groundwater when it first reaches the point of compliance.
Ponce (2010) reported that the proposed Campo Landfill that is to be located on an Indian
Reservation in South San Diego County near the border with Mexico that this area is prone to
have strong earthquakes. He stated with respect to the potential for a strong earthquake to impact
the integrity of the landfill waste containment system,
“The neglect of the February 24, 1892 earthquake, of Magnitude 7.8, the largest on record, is a
serious omission of the DSEIS. The Maximum Credible Earthquake (MCE) may have to be
recalculated. Strong ground motions can reset the pressure in the fractured rock aquifer and
can cause very large temporary increases in water pressure. No liner taking a direct hit can
withstand these pressure increases. “
Landfill Gas and Airborne Emission Problems
Municipal solid wastes and some industrial nonhazardous wastes contain organic compounds
that are converted in a landfill by bacteria to methane and carbon dioxide (landfill gas). A
general discussion of the generation of landfill gas in classical MSW sanitary landfills without
low permeability cover is presented in “Landfill Gas Overview” which is available at
www.landfill-gas.com. As discussed herein the classical landfill gas generation duration in
sanitary landfills is not to today’s dry tomb type landfill that are closed with low permeability
covers.
The presence of methane in landfill gas represents an explosive hazard and contributes to
global warming. There have been explosions in dwellings on properties adjacent to landfills
due to landfill gas subsurface migration to adjacent properties. Hodgson et al. (1992) have
reported on landfill soil gas migration and VOC migration into a house near the landfill. In order
to detect subsurface methane migration, landfill developers propose to ensure that the
concentration of methane gas generated by the landfill does not exceed 25 percent of the lower
explosive limit (LEL) for methane in landfill structures and that the concentration of
38
methane gas does not exceed the LEL for methane at the landfill property boundary. While
controlling landfill gas emissions to 25 percent of the lower explosive limit for methane, if
adequately implemented, will eliminate the potential for explosions, it means that the landfill
owner plans to have appreciable concentrations of landfill gas at adjacent property owners’
property line. This approach is strongly contrary to the health, welfare and interests of adjacent
property owners/users due to other gases in the migrating landfill gas.
As landfill gas is generated within the landfill, it attempts to migrate in all directions, escaping
through the bottom, sides and top surfaces. Some landfill developers install gas monitoring
wells every 1,000 feet or so and test them quarterly for the presence of methane, using
monitoring probes installed in the soil between the landfill unit and the property boundary or
on-site structures (office, maintenance and scale). The spacing of landfill gas monitoring
wells 1,000 feet apart is grossly inadequate to detect landfill gas migration through the
subsurface soil under the conditions that will exist at many landfills. The escape of landfill
gas from a proposed landfill will not be uniform across all areas of the landfill liner system
that is used on the subsurface sides of the landfill. It will occur in areas where the liner has failed
due to landfill construction problems, landfill operation problems and points of deterioration in
the liner. This can lead to plumes of landfill gas that can pass between monitoring wells
spaced 1,000 feet apart. This, in turn, can be a threat to those who construct dwellings near
the landfill property line.
The rate of landfill gas production is dependent on the moisture content of the wastes, where dry
wastes produce little landfill gas. Landfill developers typically present estimates of the period
of time that landfill gas will be generated in a proposed dry tomb landfill. As discussed by Lee
and Jones-Lee (1999b), these estimates typically ignore the fact that, once the landfill is closed
and the low permeability cover is installed, the rate of landfill gas generation will be greatly
reduced or even stop as the wastes dry out, but landfill gas generation can begin to occur again
when the low-permeability layer in the cover no longer keeps moisture out of the wastes.
Another issue that is not adequately addressed in the permitting of dry tomb Subtitle D
landfills is that much of the waste placed in today’s landfills is in plastic bags. Since these
plastic bags are only crushed and not shredded, the crushed bags will “hide” the fermentable
components of the waste that can lead to landfill gas formation. The net result is that, rather than
landfill gas production following the classic generation rates and durations that were developed
based on unbagged wastes or situations where much of the wastes in the landfill were able to
interact with the moisture that enters the landfill during the first decade or so of landfill
operation, the period of landfill gas production will be extended until the plastic bags
decompose. This can readily be many decades, to a hundred or more years.
Prosser and Janechek (1995) have discussed that gaseous emissions from landfills are a threat to
cause groundwater pollution that will not likely be detected by the groundwater monitoring
wells, since gas migration can be in a direction different than down groundwater gradient.
Richgels (2000) has provided additional information on landfill gas pollution of groundwaters
based on his experience in investigating the situation near the Kiefer Landfill in Sacramento,
California. The focus of his discussion is estimating reasonably foreseeable releases from
municipal solid waste landfills. The California State Water Resources Control Board
(SWRCB/CIWMB, 2006) landfilling regulations (Title 27) require that landfill owners make
estimates of the potential for a particular landfill to release landfill gas and/or leachate to the
39
environment. This information, in turn, is used to establish the magnitude of funding needed to
remediate these releases should they occur at some time in the future.
Richgels (2000) has pointed out that landfill gas emissions, including the associated VOCs, from
today’s lined landfills are a much greater threat to cause widespread groundwater pollution
than the expected initial near-term leakage of leachate through the HDPE compacted clay
liner system. He recommends that landfill gas collection systems be developed that are designed
and operated to more effectively control landfill gas emissions than is often done today.
His recommendations include placing the leachate collection and removal system under vacuum
to remove any landfill gas that collects in this system. This approach would tend to reduce the
penetration of landfill gas through holes, rips, tears, etc., in the HDPE liner that can lead to
groundwater pollution.
It is important to point out that the VOCs in landfill gas, such as the chlorinated solvents TCE,
PCE and the transformation product vinyl chloride, which are often significant threats to cause
groundwater pollution, can cause large-scale pollution of groundwaters by hazardous
chemicals at concentrations above current drinking water MCLs – i.e., small amounts of landfill gas
with its associated VOCs can pollute large amounts of groundwater. A National Academy of
Sciences report (NAS, 2006) indicates that the current US EPA MCL for TCE may not be
protective and therefore may need to be lowered.
While Richgels discussed the penetration of landfill gas through holes in the HDPE liner, in
addition, as discussed above there can be permeation of these VOCs through intact liners (no
holes). The thin film of leachate passing over the HDPE liner at the base of the leachate
collection and removal system would contain landfill gas components that would permeate
through the liner, leading to the potential for groundwater pollution by the VOCs.
Landfill gaseous emissions contain a variety of volatile hazardous chemicals that are a threat to
cause cancer and other diseases in those living in or using areas near a landfill. While landfills
contain landfill gas collection systems, such systems, even at the time of construction, are not
fully effective in preventing landfill gas and other volatile waste components from escaping
from the landfill through the landfill cover. Further, over time, the landfill gas collection
system’s reliability will deteriorate, or it may even become nonfunctional, leading to large-
scale uncontrolled releases of landfill gas through the landfill cover and liner system.
Raloff (2001) and Ding et al. (2007) have reported that MSW landfills that mercury disposed in
the waste stream make the mercury more hazardous through conversion to methyl mercury
that is present in landfill gas emissions. MSW landfills represent another source of
widespread contamination of the environment and fish with mercury that is a hazard to those
who use fish as a food. This situation supports restricting the disposal of mercury containing
wastes in MSW landfills.
Threat of Landfill Gas to Wildlife
. Many reuse activities touted for lands atop closed
landfills are inappropriate and, indeed, pose a hazard because of landfill gas emission. It is
known that even if a closed landfill incorporates a highly efficient landfill gas collection
system, some landfill gas escapes through the cover. That gas contains hazardous and otherwise
deleterious components including VOCs, many of which are carcinogens, and pose a threat to
40
wildlife and other animals that may be in the area, such as those depicted in Waste
Management ads grazing on the landfill cover vegetation and inhabiting the area. Landfill gas
measurements are typically made several feet above the landfill surface where there has been
some dilution of the gas with ambient air, rather than at the ground surface where many of the
wildlife live or eat. The wildlife that lives or grazes at the land surface are thus exposed to
higher concentrations of landfill gas and greater exposure to associated carcinogens than would
be reflected by those measurements.
Landfill Odor Control Problems and Impacts
.
One of the components of landfill gas that is
especially of concern to those living or working near a landfill is the malodorous compounds
present in the gas. Municipal solid waste landfills are notorious for causing severe odor
problems that can occur at considerable distances (sometimes miles) from the landfill. Landfill
developers state at permitting hearings that the landfill operator will place daily and
intermediate cover over the wastes, and additional control of odors will occur through limiting
the size of the tipping face (where wastes are deposited each day). Some landfill developers
will also state that if odor increases, additional cover material will be placed over the offensive
material and/or a US EPA-approved deodorizer will be installed to control the odor. When
the landfill closes, the thick final landfill cover will further control the odors.
While typically landfill proponents will, as part of attempting to gain a permit, make such claims
about controlling odors, frequently landfills with grossly inadequate buffer lands will cause
odors on adjacent properties. While the trespass of landfill odors on adjacent properties is
sometimes characterized as a “nuisance,” in fact landfill odors represent significant health
hazards. Shusterman (1992), a physician with the California Department of Health Services, has
published a paper on the health threat that odorous conditions represent to those who experience
obnoxious odors. Subsequently, Schiffman and Nagle (1992) and Schiffman et al. (1995,
2000, 2001a,b) have published several papers on the impacts of odors on human health,
which demonstrate that obnoxious odors have significant health impacts on some
individuals. In addition to the health impacts of landfill odors, landfill gas releases that occur
with the odors are known to contain carcinogens and other chemicals that, while not odorous, are
a threat to human health. Landfill odors on adjacent properties are a good indicator that there
are non-odorous compounds in the air that are a threat to health. With respect to using US
EPA-approved deodorizers to “control the odor,” such an approach is often not effective.
Further and most importantly, while a deodorizer potentially can mask offsite odors, it does
not control the hazardous chemicals that are present in the landfill gas emissions that reach
offsite properties.
According to Waste Age (2009a), the Pennsylvania Department of Environmental Protection
(DEP) has fined the Seneca Landfill in Butler County, Pa., $22,000 for odor control
violations.
“Over the past six months, DEP has responded to numerous odor complaints from residents
living near the landfill,” said DEP Regional Director Kelly Burch in a press release.
“Inspectors traced the odors back to the landfill and the facility’s failure to implement its
odor control plan fully. Seneca has corrected the violations, but DEP inspectors will
continue to monitor the landfill as they do with all others.”
One of the major problems with controlling landfill odors is that regulatory agencies are
often not effective in requiring that a landfill owner control odors so that they do not occur on
41
adjacent properties. It is suggested that if a landfill is proposed to be permitted, a condition of
the permit include the potential to permanently close the landfill and require the landfill
owner to remove all wastes deposited in the landfill should landfill odors be detected at adjacent
property owners’ property lines more than once in a year. This approach would provide the landfill
owner with the incentive to ensure that its so-called “odor control” approach is, in fact, effective
in controlling odorous releases from the landfill.
ATSDR (2006) has developed a “Landfill Gas Primer - An Overview for Environmental Health
Professionals,” that provide information on landfill gas health related issues. This report is a
source of information on a number of issues that need to be reviewed in considering the
potential impacts of landfill gas releases to the environment. However, this report is significant
deficient in discussing the generation of landfill gas in Subtitle D dry tomb type MSW landfills.
The US EPA sponsored the development of the Landfill Gas Emissions Model (LandGEM). to
estimate landfill gas generation rates. Alexander et al. (2005) have developed a guidance
manual for use of this model. The information presented in gas generation as presented in
Figure 8 (discussed below) is applicable to the classical sanitary landfills that were developed
prior to the implementation of the dry tomb landfills in the early 1990s. As discussed herein,
since the implementation of Subtitle D landfills requirements by the mid 1990s, the development
of landfill gas in MSW landfills has changed dramatically. With the closure of Subtitle D
landfills with closure with low permeability covers that restrict moisture from entering the
landfill, the amount of landfill gas will be greatly reduced the rate of landfill gas generation
due to the limited amount of moisture that enters the landfill under the conditions of an
effectively developed and maintained landfill cover. Under these conditions, landfill gas
generation can be effectively ceased until there is inadequate maintenance of the cover to
prevent moisture from entering the landfill. As shown in Figure 8 at that time which can be many
decades after landfill closure, landfill gas generation can become sufficient to become a
significant threat to the public and the environment.
Another deficiency with the ATSDR landfill gas report is the failure to adequately discuss
the role of subsurface gas release from a landfill as a cause of groundwater pollution. As
discussed herein subsurface gas migration can be a highly significant cause of groundwater
pollution.
Overall, landfill gas production in a dry tomb landfill is unreliably predicted over the period
that the fermentable wastes will persist in a Subtitle D landfill. Further and most importantly,
essentially no provisions are made to manage the landfill gas problems that will occur in dry
tomb Subtitle D landfills over the time that the wastes in the landfill will be a threat to generate
landfill gas.
Landfill Dust Control Problems.
Dust emissions from landfills can be a severe problem that can
impact adjacent properties. There are several aspects of the dust control issue that need to be
evaluated. First, the landfill owner should be required to control all dust emissions from the
landfill so that no dust from the landfill is deposited on adjacent properties. Some landfill
operators use landfill leachate for dust control. While in the past this was a common practice, in
many states it is no longer allowed, since it can lead to polluted stormwater runoff. Leachate
should not be used for dust control, since leachate contains a variety of hazardous and deleterious
chemicals that can be present in stormwater runoff from the areas to which the leachate is
applied.
42
Some landfill owners/operators’ proposed potential use of a “dust palliative” can lead to
significant public health and environmental problems. The G. F. Lee was a member of a US
EPA expert panel on evaluating the potential public health and environmental impacts of
various types of chemicals that are used for dust control. As part of this effort, Lee and
Jones-Lee (2004c) developed a report discussing the potential public health and
environmental problems associated with the chemicals, including wastes that are used as dust
suppressants. It was the use of wastes for dust control that led to the Times Beach, Missouri,
dioxin situation, where waste products (still bottoms) from a chemical manufacturing operation
were used as dust suppressants on roads. Similar situations have occurred where transformer
oils containing PCBs have been used as dust suppressants on roads. At this time, dust
suppressants are largely unregulated with respect to environmental pollution. All dust
suppressants used at a landfill should be evaluated in accordance with the procedures discussed
by Lee and Jones-Lee (2004c).
Stormwater Runoff Pollution Impacts and Control
Stormwater runoff from landfills can have a significant adverse impact on the water quality
of the receiving waters for the runoff with respect to their use for domestic water supplies and
their ability to support aquatic life. Stormwater runoff from landfill properties can contain a variety
of regulated and many unregulated pollutants that are a threat to the health of those who use
the treated waters for domestic purposes and to aquatic life. Also, while not necessarily a
human health threat, MSW contains a large number of chemicals that can be highly detrimental
to the use of MSW leachate polluted waters for domestic purposes. Of particular concern are
those chemicals that can cause tastes and odors.
During the active life of a landfill (when wastes are being deposited in the landfill), waste-
derived constituents can escape from the landfill active face through windblown transport;
via bird, insect and vermin transport; and by stormwater runoff from the landfill. While typical
state and local landfilling regulations require that the active face of the landfill be kept to a
“small” area, there is still escape of waste-derived constituents which can be transported by
stormwater to offsite watercourses.
A source of pollutants for stormwater runoff from landfill property is leachate spills on the
ground surface. These spills are associated with inadequate handling of leachate from the
leachate collection system discharge point to the location where it is transported offsite, or at the
onsite treatment works. Also of concern is the breakage of leachate transmission pipes that
results in the discharge of leachate to the ground surface. These types of problems are especially
prevalent in climates where freezing of the leachate pipes can occur.
Often large parts of a landfill will be above the existing ground surface, where there is the
potential for seeps of leachate to occur through the sides of the aboveground parts of the
landfill, which could pollute stormwater runoff from the landfill surface. Seeps are of concern
since the leachate in seeps contains hazardous and deleterious chemicals. These seeps can
occur at any time over the hundreds of years that the wastes in the landfill will be a threat.
Other sources of pollutants in landfill stormwater runoff includes garbage truck traffic,
landfill equipment such as bulldozers, compactors etc, spills of fuels and engine oil where
the old oil is allowed to be dumped on the ground etc can be sources of pollutants for runoff
from landfills. The use of pesticides/herbicides to control insects/weeds at the landfill can
be a source of pollutants in stormwater runoff that can be adverse to drinking water quality
43
and a threat to aquatic life in the receiving waters for the runoff.
The area where waste is dumped for load inspection can be a source of stormwater runoff
pollutants if the wash-down water is not adequately controlled. A similar situation can exist
in areas where mud on truck tires is washed off to keep from transporting landfill-area-
derived mud to the public roads.
Current federal and many state stormwater runoff regulations governing landfills do not
require that the stormwater runoff from a landfill area be treated to reduce the waste-derived
chemicals to meet water quality criteria and drinking water maximum contaminant levels
(MCLs). The only treatment typically provided is a settling basin that will detain low
volumes of stormwater runoff and remove some particulate matter in the runoff.
Under the current US EPA regulations with no assured funding beyond 30 years after closure
of the landfill, there are significant questions about whether the limited stormwater
runoff monitoring and maintenance of detention basins that are designed to only contain the
25-year, 24-hour storm will be contained/maintained for as long as the wastes in the landfill are a
threat to generate leachate, which for dry tomb type landfills can be forever. The 25-year, 24-hour
storm limitation in the design of the detention basins means that larger storms will discharge
pollutants to nearby watercourses without even removal of the large size erosion particles
and wastes. If two storms occur, one shortly after the other, where the detention basins still
have appreciable water from the first storm, means that the second storm’s runoff will likely
pass through the detention basins even if neither storm exceeds the design capacity of a 25-
year, 24-hour storm.
While the pollutants in leachate used for dust control or from seeps would accumulate in the
landfill stormwater detention basins for storms of magnitude less than the 25-year, 24-hour
discharge, storms of greater than this magnitude could tend to flush out the pollutants in the
detention basins onto downstream properties. Further, there will be need for ad infinitum
maintenance of the detention basins to ensure that as they accumulate sediments they do not
lose their capacity to control runoff from the landfill area for storms less than the 25-year, 24-
hour event.
For those landfills with a single composite liner, the leachate pollution of shallow
groundwater can be a source of surface water pollution if the polluted shallow groundwater
enters the surface waters through above-water surface springs or below-water surface discharges
to streams, rivers, lakes and nearshore/offshore marine/estuarine waters.
The nature of stormwater runoff impacts is that of pulses of pollutants can be disruptive to a
water supply’s ability to adequately treat the stormwater runoff-polluted water to maintain high
water quality in the treated waters. At this time the information on the water quality impacts of
stormwater runoff from landfill is not sufficiently known to be able to predict the potential
impacts of landfill stormwater runoff on receiving water quality. However, it is well known
that municipal solid waste landfills contain large amounts of chemicals that have the
potential to adversely impact domestic water supply water quality and the aquatic life
resources of waterbodies.
Monitoring Stormwater Runoff from Hazardous Chemical Sites. Lee and Jones-Lee (2009c,
2010b) have developed several papers/reports devoted to discussing deficiencies in stormwater
44
runoff water quality monitoring at hazardous chemical including Superfund sites. As these
papers/reports discuss there are significant problems with the adequacy of stormwater runoff
from municipal and industrial landfills and other hazardous chemical sites including so-called
“brownfield” areas where hazardous and deleterious to water quality chemicals are located in
soils and in waste management facilities. At many such sites they have found that the regulatory
agencies responsible for establishing the stormwater runoff water quality monitoring programs
fail to establish adequate and reliable monitoring of hazardous and deleterious chemicals in the
runoff that have the potential to cause significant water quality impairments in the receiving
waters for the runoff.
An extreme example of this type of problems is the stormwater runoff monitoring at the
University of California (UCD) Department of Energy (DOE) NPL Superfund site located on
the UCD Davis campus. UCD proposed and the California Central Valley Regional Water
Quality Control Board (CVRWQCB) accepted that stormwater runoff from this Superfund site
be monitored as though it were a municipal small source of stormwater runoff in which a grab
sample of stormwater runoff is taken at any time during the runoff event for two storms per
year. The UCD/DOE LEHR Superfund site has radioactive, hazardous chemicals including
VOCs, heavy metals including mercury in the surface soils and former waste disposal areas
including three UCD campus waste closed unlined sanitary type landfills. These landfills and
other waste disposal areas at the LEHR site have polluted the area groundwaters with several
hazardous chemicals above the drinking water MCLs.
The stormwater runoff from the LEHR site has total recoverable mercury at times about 10 times
the receiving waters for the stormwater runoff (Putah Creek) discharge limit of 50 µg/L
established by the US EPA in the California Toxics Rule. This discharge limit is known to be
about 10 times the concentration of mercury that can bioaccumulate in some edible fish to be a
human health threat to pregnant women and fetuses who consume some of fish. Putah Creek is
a Clean Water Act Section 303(d) water quality limited waterbody due to excessive
bioaccumulation of mercury in some Creek fish. This situation requires that a TMDL be
developed to control mercury discharges to the Creek and in-Creek sources. The primary sources
of mercury for the Creek are discharges of stormwater runoff to the Creek from former mercury
mines in the Putah Creek watershed. OEHHA consumption guidance for Putah Creek fish is
provided in Lee and Jones-Lee (2010c).
During 1995-2010 the Davis South Campus Superfund Oversight Committee (DSCSOC) was
the US EPA Technical Assistance Grant (TAG) that was the public advisory group that
conducted LEHR Superfund site review of the adequacy of site investigation/remediation. Dr.
G. F. Lee was the DSCSOC TAG supported technical advisor. He developed a series of reports
on the deficiencies in the LEHR site stormwater runoff water quality monitoring which is
located at, http://www.gfredlee.com/dscsoc/doc.htm.
DSCSOC repeatedly commented to the regulatory agencies on the deficiencies in the stormwater
runoff water quality monitoring at the LEHR Superfund site and recommended that the
stormwater runoff from the site be monitored in accord with US EPA (1992) guidance for
monitoring of stormwater runoff from industrial sites. This guidance was unknown to the
regulatory agency staff (Remediation Program Managers, RPMs) responsible for LEHR site
investigation/remediation. The US EPA stormwater runoff water quality monitoring guidance
requires the monitoring program recommended by the U.S. EPA for industrial sites which
45
involves collecting samples of true first-flush runoff and runoff at several times during the runoff
event. Further, a sufficient number of events must be monitored in this way each year to properly
characterize the hazardous chemical content of the stormwater runoff. This monitoring program
should be used for monitoring of hazardous chemical sites including all MSW active and closed
landfill areas. In addition to the suite of chemical parameters this monitoring should include
measuring aquatic life toxicity using the US EPA standard three species test procedure available
at http://cfpub.epa.gov/npdes/wqbasedpermitting/wet.cfm.
Inadequate Stormwater Runoff Parameter Monitoring
. Current water quality regulatory
programs only regulate 100 to 200 of the many thousands of chemicals present in municipal
and industrial solid wastes that can be legally added to the waste stream that is deposited in
MSW landfills. The monitored/regulated chemicals in landfill leachate and stormwater runoff
represent a very small part of the chemicals present in MSW that are a threat to public health
and the environment. The regulation of landfill stormwater runoff water quality impacts occurs
under the US EPA National Stormwater Runoff permit system. Nationally and in states,
stormwater runoff from a landfill is regulated as an “industrial” source. Critical review of the
existing landfill stormwater runoff monitoring requirements shows that they are seriously
deficient in providing the monitoring needed to insure with a reasonable degree of certainty
that the landfill stormwater runoff will not pollute the waters receiving the runoff from the
landfill. MSW and its leachate contain thousands of chemicals that are not
monitored/regulated, which are a threat to public health and the environment. Some of the
unmonitored constituents can be adverse to public health at very low concentrations. Dr.
Christian Daughton (2005), Chief of the Environmental Chemistry Branch, National
Exposure Research Laboratory, Office of Research and Development, US EPA, Las
Vegas, Nevada, has discussed the inadequacy of water quality monitoring programs in
identifying pollutants in wastewaters/stormwater runoff for the range of chemicals that could be
impacting public health and the environment. In his presentation he stated,
“Further Truisms Regarding Environmental Monitoring
•
What one finds usually depends on what one aims to search for.
•
Only those compounds targeted for monitoring have the potential for being identified and
quantified.
•
Those compounds not targeted will elude detection.
•
The spectrum of pollutants identified in a sample represent but a portion of those
present and are of unknown overall risk significance”
Figure 7 presents a diagram of this situation. This figure is from web page: “The Critical Role of
Analytical Chemistry,” C.G. Daughton, July 2002.
[http://www.epa.gov/nerlesd1/chemistry/pharma/critical.htm]
Background information on unrecognized/unregulated chemicals as environmental pollutants
is available at http://www.epa.gov/nerlesd1/chemistry/pharma/ and at
http://www.epa.gov/nerlesd1/chemistry/ecb-posters.htm.
In addition, Lee and Jones-Lee (2005b) have recently published a review on unrecognized
pollutants.
46
Figure 7
Chemical Analysis Output for a Typical Environmental Sample
“TARGET” RECOGNIZABLE Large portion of naturally occurring and
ANALYTES ARTIFACT anthropogenic chemicals of varied toxicity
TICs = tentatively identified compounds, from: C.G. Daughton, US EPA (July 2002)
Safe Drinking Water Act Source Protection Issues
The federal Safe Drinking Water Act as amended in 1996 established the requirements that each
state must develop a source water quality protection program that identifies the potential
sources of pollutants in a domestic water supply watershed that are a threat to the water supply
water quality. It should be understood that the US EPA Subtitle D regulations and state
regulations governing developing MSW landfills do not adequately consider the protection
of domestic water supply water from landfill area stormwater runoff-derived pollutants. The
US EPA national stormwater runoff water quality regulations also do not adequately and
reliably establish stormwater runoff water quality management programs to protect domestic
water supplies from landfill waste-derived pollutants.
The Safe Drinking Water Act regulates the degree of treatment that is needed to produce an
acceptable treated water. This Act, while helping state regulatory agencies and water utilities
assess potential pollutant sources that could adversely impact domestic water supply water
quality, has no regulatory authority to restrict land use in a water supply watershed. Since
neither the US EPA Subtitle D landfill regulations nor the US EPA stormwater runoff water
quality regulations can be used to adequately protect domestic water supply water quality, the
burden of watershed water supply water quality will fall to the water utility and those concerned
with protecting water quality in a domestic water supply. Water utilities should work with the
watershed area planning agency to restrict the development of new sources of pollutants that
are a significant threat to the water supply water quality. The development of new landfills
in a small domestic water supply watershed is a situation where water utilities should work with
local zoning agencies to restrict the development new landfills in their watershed. This is
prudent public health and aquatic life water quality protection policy.
The agencies responsible for the domestic water source water quality assessment should identify
MSW landfills as a potential long-term source of a wide variety of pollutants that must be
carefully monitored during the active life of the landfill and the postclosure period; i.e., while the
wastes are still a threat to generate leachate when contacted with water. As an example of this
situation, Meriwether County, Georgia, adopted a zoning ordinance that prohibits the siting of
MSW landfills in small domestic water supply watersheds, which is in accord with protection
of the water quality impacts of landfill releases of waste-derived constituents. Lee (2005) and
Lee and Jones-Lee (2008) has reviewed this situation, where they points out that this approach
is appropriate as part of domestic water supply source water quality protection from pollution from
landfills.
47
Inadequate Postclosure Monitoring and Maintenance
The 30-year funding period for postclosure monitoring and maintenance of Resource
Conservation and Recovery Act Subtitle C and D landfills that was specified by Congress
was one of the most significant errors made in developing RCRA Subtitle C and D landfilling
regulations. Those who were responsible for developing this approach did not have an
understanding of how waste-associated constituents would degrade/transform in a dry tomb
landfill. The US Congress General Accounting (now Accountability) Office (GAO, 1990), in
the Executive Summary of its report “Funding of Postclosure Liabilities Remains Uncertain,”
under a section labeled “Funding Mechanisms Questionable,” concluded that,
“Owners/operators are liable for any postclosure costs that may occur. However, few funding
assurances exist for postclosure liabilities. EPA only requires funding assurances for
maintenance and monitoring costs for 30 years after closure and corrective action costs
once a problem is identified. No financial assurances exist for potential but unknown corrective
actions, off-site damages, or other liabilities that may occur after the established postclosure
period.
Further, the US EPA Inspector General (US EPA, 2001b) in a report, “RCRA Financial
Assurance for Closure and Post-Closure,” developed similar conclusions:
“There is insufficient assurance that funds will be available in all cases to cover the full period
of landfill post-closure monitoring and maintenance. Regulations require postclosure
activities and financial assurance for 30 years after landfill closure, and a state agency may
require additional years of care if needed. We were told by several state officials that many
landfills may need more than 30 years of post-closure care. However, most of the state
agencies in our sample had not developed a policy and process to determine whether post-
closure care should be extended beyond 30 years, and there is no EPA guidance on determining
the appropriate length of post-closure care. Some facilities have submitted cost estimates that
were too low, and state officials have expressed concerns that the cost estimates are difficult to
review.”
As indicated by Skinner, current Executive Director of SWANA (quoted above),
“The problem with the dry-tomb approach to landfill design is that it leaves the waste in an
active state for a very long period of time. If in the future there is a breach in the cap or a
break in the liner and liquids enter the landfill, degradation would start and leachate and
gas would be generated. Therefore, dry-tomb landfills need to be monitored and
maintained for very long periods of time (some say perpetually), and someone needs to be
responsible for stepping in and taking corrective action when a problem is detected. The
federal Subtitle D rules require only 30 years of post-closure monitoring by the landfill operator,
however, and do not require the operator to set aside funds for future corrective action. Given
the many difficulties of ensuring and funding perpetual care by the landfill operator, the
responsibility of responding to long-term problems at dry-tomb landfills will fall on future
generations, and the funding requirements could quite likely fall on state and local
governments.”
Typically those developing a landfill propose to only be responsible for providing the financial
assurance for: closure; postclosure and corrective action for the 30-year minimum period.
Hickman (1992, 1995, 1997) and Hickman and Lanier (1998), in a series of articles (“Financial
Assurance-Will the Check Bounce?”, “Ticking Time Bombs?”, “No Guarantee,” “A Broken
Promise Reversing 35 Years of Progress”), has discussed the inadequate approaches for
48
postclosure funding under Subtitle D regulations. Lee and Jones-Lee (1992, 1993b, 2004d)
and Lee (2003c) have published a number of reviews on the need for longer-term postclosure
care, as well as the use of more reliable financial instruments to provide funding during the
postclosure care period than is typically provided today.
Lee and Jones-Lee (2012f) and Jones-Lee and Lee (2014) have developed discussions of the
impacts of inadequate landfill postclosure funding on public health and the environment. They
point out that as part of permitting a MSW landfill adequate funding of postclosure monitoring,
maintenance and remediation of the landfill should be provided for as long as the wastes in the
landfill are a threat to generate leachate or landfill gas when contacted by water that inters the
landfilled wastes through the landfill cover or groundwater seepage into the landfill. They
suggest that the cost of MSW to the residential and commercial generator should be increased
to insure that adequate funds will be available to provide a dedicated trust or similar reliable
funding source to address all potential worst case scenario issues that can lead to environmental
pollution by the landfilled wastes.
Lee and Jones-Lee (2004d) have discussed the unreliable information that some private landfill
owners and their consultants are foisting on regulatory agencies where they claim that it is
possible to predict, based on landfill monitoring, the duration of postclosure care. This is an
attempt to try to limit the long-term liability of landfill owners for postclosure care. As
discussed by Lee and Jones-Lee (2004d), such claims ignore the processes that will take place
in a dry tomb type landfill. Figure 8 provides a diagram of the expected situation with respect
to landfill gas formation and leachate generation in a closed dry tomb landfill.
Figure 8.
Comparison of Pattern of Landfill Gas Generation over Time at
Classical Sanitary Landfill and “Dry Tomb” Landfill
(from Lee and Jones, 1991)
49
A similar relationship has been developed by the California Integrated Waste
Management Board (CIWMB, 2004). Once the landfill is closed with a low-permeability
cover, the rate of landfill gas generation and leachate production will drop off and eventually
stop if the landfill cover is effective in limiting moisture from entering the landfill. This is
because both leachate generation and landfill gas production are dependent on moisture in the
wastes.
Christensen and Kjeldsen, (1989) have discussed the role of moisture in influencing landfill gas
production. These relationships are shown in Figure 9. However, in time, as the low- permeability
plastic sheeting layer in the cover deteriorates and moisture enters the landfill, landfill gas and
leachate generation will start to occur again. There is no reliable way, under current dry tomb
Subtitle D landfill cover design and monitoring, to predict when the postclosure dormant period
will end and landfill gas and leachate production will begin to occur again.
Figure 9
Impact of Moisture on Landfill Gas Formation
(from Christensen and Kjeldsen, 1989)
50
The CIWMB, in accord with California Title 27 landfilling regulations of requiring postclosure
monitoring and maintenance for as long as the wastes in the landfill will be a threat, is in the
process of developing an approach to secure assured funding for postclosure monitoring and
maintenance of closed landfills. Landfill owners, especially private owners, have voiced
opposition to this approach. Lee and Jones-Lee (2007b) have provided the CIWMB with
Regulatory Agency Should Define Who Will Provide Postclosure Care for as Long as the
Wastes Will Be a Threat
.
As part of permitting a landfill, the regulatory agency should provide
information on who will provide the following for as long as the wastes in the landfill will be a
threat.
:
• Monitoring the groundwater monitoring wells and the gas monitoring wells,
• Removing leachate from the leachate collection sumps,
• Repairing the cover when there is erosion of it and it fails to prevent moisture from entering
the landfill that generates leachate,
• Cleaning out the leachate collection system associated with chemical and biological
plugging of this system,
• Operating and maintaining the landfill gas collection system,
•
Performing groundwater remediation when the pollution of groundwater by landfill leachate
is discovered in a monitoring well or more likely in an offsite production well,
obviously
pollute groundwater during the time that the wastes in the landfill will be a threat.
Since the wastes in a dry tomb landfill will be a threat to generate leachate and landfill gas
for well beyond the 30 years of minimum postclosure monitoring and maintenance that the
landfill proponent will be obligated to cover, regulatory agency staff should estimate the
period of time that postclosure funding will be needed (including the technical basis for
developing this estimate), how much funding will be needed to address all plausible worst-
case failure scenarios for the landfill cover, bottom liner, and groundwater and gas monitoring
systems, and the source of the funds for the required postclosure monitoring, maintenance
and remediation.
From an overall perspective, minimum Subtitle D landfill design, closure and postclosure
monitoring and maintenance will result in the development of a landfill that will pollute
groundwater by landfill leachate during the period of time that the wastes in the landfill will
be a threat. This pollution will be a significant threat to the health, welfare and interests of the
residents and property owners in the area.
O’Brien Executive Director ARF of Solid Waste Association of North America has published
an article that discusses some aspects postclosure issues for MSW landfills. As discussed by
Lee and Jones-Lee (2011a) the SWANA/O’Brien article on postclosure issues fails to
adequately discuss the need for adequate postclosure funding/care for as long as the wastes
in the landfill will be a generate leachate when contacted by water.
Recently various individuals who work with/for landfill developers publish articles that fail
to adequately and reliably discuss landfill postclosure issues. Jones-Lee and Lee (2012) have
discussed the paper by Morris on the expected performance of Subtitle D landfill during the
post closure. As with many other recent articles of this type Morris has failed to discuss the
true long term problems of closed subtitle D landfills.
Lee and Jones-Lee (2012a) have developed a comprehensive discussion of the potential
51
public health, groundwater resource and other problems with Subtitle D MSW landfills. This
discussion was featured in a MSW Management blog as Editor (2012). Lee and Jones-Lee
(2012b) also developed a checklist of issues that need to be considered in developing new or
expanded MSW landfills that considers both active life and postclosure issues.
O’Brien Executive Director ARF of Solid Waste Association of North America has published
an article that discusses some aspects postclosure issues for MSW landfills. As discussed by
Lee and Jones-Lee (2011a) the SWANA/O’Brien article on postclosure issues fails to
adequately discuss the need for adequate postclosure funding/care for as long as the wastes
in the landfill will be a generate leachate when contacted by water.
Recently various individuals who work with/for landfill developers publish articles that fail
to adequately and reliably discuss landfill postclosure issues. Jones-Lee and Lee (2012) have
discussed the paper by Morris on the expected performance of Subtitle D landfill during the
post closure. As with many other recent articles of this type Morris has failed to discuss the
true long term problems of closed subtitle D landfills.
Lee and Jones-Lee (2012a) have developed a comprehensive discussion of the potential
public health, groundwater resource and other problems with Subtitle D MSW landfills. This
discussion was featured in a MSW Management blog as Editor (2012). Lee and Jones-Lee
(2012b) also developed a checklist of issues that need to be considered in developing new or
expanded MSW landfills that considers both active life and postclosure issues.
Hazardous versus Nonhazardous Waste Classification
The typical approach that is used by regulatory agencies and landfill proponents is to say that
no “hazardous wastes” will be deposited in a Subtitle D landfill. However, that statement is
based on the fact that an arbitrary and often not protective approach is used to define
“hazardous” waste. An understanding of the basis of this classification shows that the US
EPA’s approach allows substantial amounts of hazardous chemicals to be added to so-called
“nonhazardous” waste (Subtitle D) landfills. Further, the US EPA’s classification system
provides for no recognition of so-called “nonhazardous” waste containing constituents which
are highly detrimental to the use of the groundwaters that are polluted by leachate from such
wastes, rendering the waters unusable for domestic and many other purposes. As discussed by
Jones- Lee and Lee (1993), the presence in a water supply well of municipal solid waste and
other waste leachate, with no “hazardous” chemicals above the US EPA criteria that are used
to make the distinction between hazardous and nonhazardous, can still cause the water supply
well to have to be abandoned because of the aesthetic problems of taste and odor, color, iron,
manganese, hydrogen sulfide, corrosion, scaling, etc.
The most significant problem with the US EPA’s classification of hazardous versus
nonhazardous waste is the use of the leaching test – originally, the EP-Tox test, and now the
toxicity characteristic leaching procedure (TCLP). The test is patterned after dredged sediment
elutriation. While the dredged sediment elutriation conditions make sense for dredged sediment
open-water disposal, similar conditions have no validity for the leaching of constituents in a solid
waste landfill. The liquid-to-solid ratios used, redox conditions, pH and exposure surface area
of the solid particles are all highly arbitrary. The EP-Tox test, now TCLP, is a political test
designed to limit the size of the hazardous waste stream that must be managed as hazardous
waste. The tests have little or nothing to do with properly evaluating chemicals that could affect
52
groundwater quality.
The UA EPA Science Advisory Board in a letter to Carol M. Browner, Administrator US EPA
discussed the need for the agency to update its procedures for the TCLP. The agency has
continued to fail to address the unreliability of the TCLP for characterizing solid wastes as a
hazardous waste.
The interpretation of what constitutes excessive leaching in the EP-Tox test and TCLP is another
example of an arbitrary approach on the part of the US EPA in defining hazardous waste. The
allowed attenuation factor (5-to-1 dilution is assumed) will, for some hydrogeological
groundwater systems, be overprotective, and for others, under-protective. Yet the
characteristics of the hydrogeology of the site are not taken into account in interpreting the results
of the test to determine whether a waste can be placed in a nonhazardous waste landfill. Lee and
Jones-Lee (2009d have provided a discussion of the unreliability of the TCLP based procedure
leaching of a solid waste, soil, and sediments including cement “stabilized” wastes in evaluating
the potential hazard of chemicals in the wastes.
There is considerable unreliable information on the potential for municipal solid waste
leachate to pollute groundwaters, rendering them unusable for domestic and many other
purposes. Jones- Lee and Lee (1993) have presented a review of the potential for MSW
leachate to pollute groundwaters. As they discuss, MSW leachate typically contains high
concentrations of conventional and so-called “non-conventional” pollutants. The conventional
pollutants include heavy metals, a variety of organics, and various salts, some of which are
hazardous to the health of those who consume water that has been polluted by municipal
landfill leachate.
Non-conventional contaminants are largely organic chemicals that have not been defined, and
whose potential hazards to public health and groundwater quality are not known. Typically the
organic Priority Pollutants – those organics that are identified and quantified – represent a very
small fraction of the total organic matter present in leachate as measured by chemical oxygen
demand and total organic carbon. It is estimated that from 90 to 95 percent of the organic
materials in municipal landfill leachate are of unknown composition. Those chemicals have not
been identified, and obviously their potential impacts on public health and groundwater quality
are unknown.
Controversy exists on whether the disposal of electronic wastes in MSW landfills increases the
potential for MSW landfill leachate to be a greater threat to cause groundwater pollution by
heavy metals. This issue has been reviewed by Lee and Jones-Lee (2009e) where they discuss
that SWANA as presented by Obrien and the US EPA have used a technically invalid approach
based on the TCLP test results to evaluate whether MSW leachate is a threat to pollute
groundwater with sufficient heavy metals to be a threat to the health of those who use the
groundwater for domestic water supply. Lee and Jones-Lee (2009e) indicate that at this time it
is not known that the disposal of electronic wastes in MSW landfills increases the potential
for increased heavy metal pollution of groundwater. They recommend that electronic wastes
be prohibited from the MSW waste stream as prudent public health and groundwater resource
protection policy.
Following the failure of coal ash containment system at a TVA coal fired electric generating
53
station there has been considerable interest in the potential threat that coal ash landfill, waste
ponds etc. represent to the environment. The Environmental Integrity Project has developed a
comprehensive report, “Risky Business Coal Ash Threatens America’s Groundwater Resources
at 19 More Sites” (2011).
http://www.environmentalintegrity.org/documents/121311eipthirddamagereport.pdf
that provides a detailed discussion of these issues.
Inadequate Waste Screening for Prohibited Wastes.
Landfill operators are required to have a
prohibited waste control program on site to detect and deter attempts to dispose of unacceptable
wastes at the landfill (such as hazardous wastes that are not conditionally exempt small quantity
generator wastes). Frequently, inadequate information is provided on the program that the
landfill developer plans to implement that would prevent unacceptable wastes from being
deposited in the landfill. The approach of having the scale personnel examine from three to five
random loads on a random day once per week is far from adequate in evaluating whether the
municipal solid waste stream deposited at the landfill contains wastes that cannot be legally
deposited in the landfill.
Hazardous Characteristics of MSW.
While municipal landfills are not allowed to accept
“hazardous waste,” they can and do accept a wide variety of hazardous chemicals or materials
which contain hazardous chemicals. Common household items such as batteries, fluorescent
light bulbs and cleaning fluids contain such hazardous chemicals. One of the groups of
chemicals of particular concern is the heavy metals, such as lead, cadmium, etc., which are
known to be highly toxic to people. SWANA (2004) issued a report which claims that the
concentrations of heavy metals in today’s municipal landfill leachate are not a threat to cause
groundwater pollution. However, as discussed by Lee (2004), the SWANA analysis of the
situation is flawed in that they used a regulatory approach adopted by the US EPA to define the
critical concentrations of heavy metals in landfill leachate that are a threat to domestic water
supplies. As discussed by Lee (2004, 2006e), these critical concentrations are at least 100 times
the drinking water maximum contaminant levels (MCLs). Further, the US EPA’s approach for
waste classification as hazardous versus nonhazardous ignores the fact that there are geological
strata (such as fractured rock) where there can be rapid, little-attenuated heavy metal movement
through groundwater systems to domestic water supply wells.
The facts are that the heavy metals in MSW leachate today are a threat to cause groundwater
pollution which is adverse to public health and domestic water supply water quality. The US
EPA (1988a), in reviewing this situation, concluded that the contamination of a groundwater by
MSW leachate renders the groundwater and the area of contamination of the aquifer unusable for
domestic purposes, where a water supply well that intercepts leachate-polluted groundwater
has to be abandoned – i.e., cannot be cleaned up to acceptable public health standards.
Those familiar with groundwater monitoring near landfills understand that today’s chemical-
based approach – where a few regulated chemicals are monitored, compared to the thousands
to tens of thousands of chemicals that are present in the wastes that are a threat to public health,
groundwater resources and the environment – is significantly deficient and is not protective
of public health or the environment. Lee and Jones-Lee (1994c), in a paper, “Does Meeting
Cleanup Standards Mean Protection of Public Health and the Environment?” have discussed this
issue, pointing out that waters that have been contaminated by wastes that meet all MCLs
can still be a significant threat to public health, through the hazards of unregulated chemicals
54
for which there are no MCLs.
The US Congress General Accounting Office (GAO) has indicated that there are in excess of
75,000 chemicals used in US commerce today. The current US EPA and state regulatory agency
“laundry list” of chemicals that are analyzed associated with a solid waste landfill represents
100 to possibly 200 of these chemicals. There are thousands to tens of thousands of
chemicals present in municipal solid waste and industrial so-called “nonhazardous” waste of
the type that could be disposed of in a municipal solid waste landfill, that need to be, but that
are not now required to be monitored, either directly or by their impacts, through biological
assessment techniques, in order to protect public health and the environment.
As an example of the lack of adequate monitoring of the characteristics of municipal landfill
leachate, Gintautas et al. (1992) reported finding a phenoxyalkanoic acid herbicide in municipal
landfill leachate which had not been previously reported. They concluded that the chlorinate 2-
phenoxypropionic herbicides are ubiquitous in MSW landfill leachates in the US. These
herbicides are used on residential lawns for control of broadleaf plants (dandelions). Since grass
clippings are allowed in the municipal solid waste stream, chemicals used on the lawn would be
present in grass clippings that are deposited in the landfill. However, neither the US EPA nor
the state regulatory agencies are requiring the analysis of leachate for the wide variety of
chemicals that are used on residential properties and in the home that become part of the
municipal solid waste stream.
Daughton (2004a,b), made a presentation, “Ubiquitous Pollution from Health and Cosmetic
Care: Significance, Concern, Solutions, Stewardship – Pollution from Personal Actions.” This
presentation covered information on pharmaceuticals and personal care products (PPCPs) as
environmental pollutants. He also discussed the relationship between endocrine disrupters and
PPCPs. (A copy of Daughton’s presentation, which consisted of 64 PowerPoint slides, is
available upon request from gfredlee33@gmail.com.) Daughton pointed out that there is a wide
variety of chemicals that are introduced into domestic wastewaters and wastes that are being
found in the environment. These include various chemicals (pharmaceuticals) that are
derived from usage by individuals and for pets, disposal of outdated medications in sewerage
systems and solid waste streams, release of treated and untreated hospital wastes to domestic
sewerage systems, transfer of sewage solids (“biosolids”) to land, industrial waste streams,
releases from aquaculture of medicated feeds, etc. Many of these chemicals are not new
chemicals. They have been in wastewaters and municipal solid wastes for some time, but
are only now beginning to be recognized as potentially significant water pollutants. They are
largely unregulated as water pollutants.
According to Daughton (2004a),
“Since the 1970s, the impact of chemical pollution has focused almost exclusively on
conventional “priority pollutants,” especially on those collectively referred to as
“persistent, bioaccumulative, toxic” (PBT) pollutants, “persistent organic pollutants”
(POPs), or “bioaccumulative chemicals of concern (BCCs). The “dirty dozen” is a
ubiquitous, notorious subset of these, comprising highly halogenated organics (e.g., DDT,
PCBs). The conventional priority pollutants, however, are only one piece of the larger risk
puzzle.”
Daughton has indicated that there are over 22 million organic and inorganic substances, with
55
nearly 6 million commercially available. The current water quality regulatory approach
addresses less than 200 of these chemicals, where in general PPCPs and many other
chemicals are not regulated. According to Daughton, “Regulated pollutants compose but a
very small piece of the universe of chemical stressors to which organisms can be exposed on
a continual basis.” Daughton has indicated that one of the routes of environmental exposure is
through trash placed in municipal solid waste landfills. He specifically singles out “leaching
from municipal landfills” as an origin of PPCPs in the environment. He characterizes
municipal landfills as “pollution postponement.” MSW landfills receive substantial amounts
of pharmaceuticals and other unregulated/unmonitored chemicals that become present in
landfill leachate. In addition to being present in surface waters and groundwaters polluted by
landfill leachate near the landfill, the disposal of MSW leachate in POTWs (municipal
wastewater treatment plants) contributes to the pollution of the environment through discharges
of “treated” wastewaters to surface waters. Additional information on PPCPs is available at
www.epa.gov/nerlesd1/chemistry/pharma/index.htm.
The March 17, 2010 Ground Water Protection Newsletter contained the following information
on pharmaceuticals in MSW leachate.
“Maine Study May Help Bid For State Limits On Landfilling Pharmaceuticals
A new study detecting common prescription drugs in the leachate from municipal waste
landfills in Maine could aid efforts by supporters of state legislation to create industry-funded
drug takeback programs, with proponents in Maine already citing the results to bolster their
claims that existing approaches to drug disposal put the environment at risk.
Maine's study appears to be the first to show significant levels of pharmaceuticals in landfill
leachate -- the liquid that seeps to the bottom of landfills and is commonly sent to municipal
wastewater treatment plants. Traditional wastewater treatment methods do not remove all
chemicals in pharmaceuticals and personal care products, and supporters of drug takeback
programs say having drug manufacturers collect excess pharmaceuticals and incinerate them
as hazardous waste would help reduce threats to surface and groundwater contamination.“
Re-printed in part from the Water Policy Report, Association of State and Interstate Water
Pollution Control Administrators, February 2010
Periodically, previously unrecognized significant environmental pollutants are being found in
surface waters or groundwaters. Two recent examples of this situation are perchlorate and the
polybrominated diphenyl ethers (PBDEs). With respect to perchlorate as a widespread water
pollutant, Silva (2003) of the Santa Clara Valley Water District in California, has discussed the
potential for highway safety flares to be a significant source of perchlorate (ClO
4
-
)
contamination to water, even when the flares are 100-percent burned. According to Silva,
“A single unburned 20-minute flare can potentially contaminate up to 2.2 acre-feet [726,000
gallons] of drinking water to just above the California Department of Health Services’ current
Action Level of 4 µg/L [for perchlorate].”
Silva points out that, “More than 40 metric tons of flares were used/burned in 2002 alone
in Santa Clara County.” Silva also indicates that fully burned flares can leach up to almost
2,000 µg of perchlorate per flare. The spent/used highway flares are often disposed of as trash
in municipal landfills. This can be a source of perchlorate in MSW leachate. California’s Office
of Environmental Health Hazard Assessment (OEHHA, 2004) has proposed a public health goal
for perchlorate of 6 µg/L. As of December 2003, there were 354 public wells in California
56
with perchlorate above the proposed limit of 6 µg/L.
Another widespread “new” pollutant has been recently discussed by Hooper (2003) of the
Hazardous Materials Laboratory, Department of Toxic Substances Control, California EPA. He
states,
“Over the past 25 years, tens of thousands of new chemicals (7 chemicals per day) are
introduced into commerce after evaluation by USEPA. Few (100-200) of the 85,000
chemicals presently in commerce are regulated. We have reasons to believe that a much larger
number than 200 adversely affect human health and the environment.”
As an example of unidentified hazardous chemicals in the environment, Hooper discussed
finding PBDE (polybrominated diphenyl ether) in human breast milk and in San Francisco Bay
seals. Archived human breast milk shows that this is a problem that has been occurring for
over 20 years. According to McDonald (2003) of the California Environmental Protection
Agency, Office of Environmental Health Hazard Assessment,
“Approximately 75 million pounds of PBDEs are used each year in the U.S. as flame retardant
additives for plastics in computers, televisions, appliances, building materials and vehicle
parts; and foams for furniture. PBDEs migrate out of these products and into the
environment, where they bioaccumulate. PBDEs are now ubiquitous in the environment and
have been measured in indoor and outdoor air, house dust, food, streams and lakes,
terrestrial and aquatic biota, and human tissues. Concentrations of PBDE measured in fish,
marine mammals and people from the San Francisco Bay region are among the highest in the
world, and these levels appear to be increasing with each passing year.”
The California Office of Environmental Health Hazard Assessment (OEHHA 2006) has
published a review on the potential for PBDEs to be environmental pollutants and the health
hazards associated with them. Renner (2000) published a review on PBDEs, which provides
additional information on their sources, occurrence and potential significance as environmental
pollutants. PBDEs are similar to PCBs and are considered carcinogens. Some of the PBDEs
are being banned in the US and in other countries. PBDEs are present in the municipal solid
waste stream.
The perchlorate and PBDE situations are not atypical of what could be expected based on the
approach that is normally used to define constituents of concern in water pollution control
programs. Based on the vast arena of chemicals that are used in commerce, many of which
could be present in aquatic systems through wastewater discharges and so-called nonhazardous
solid wastes, it is likely that many other chemicals will be discovered in the future that are a
threat to aquatic ecosystems and public health through surface water and groundwater
pollution.
Figure 10 presents a summary, derived from a report, of current information on numbers of
chemicals from various sources that are of concern as potential pollutants. While this figure is
developed for California coastal areas it will have applicability to many other areas. Some of these
unregulated chemical sources will be a source for unregulated chemicals in MSW landfills.
In summary, MSW leachate contains a vast array of unrecognized hazardous chemicals that are a
threat to public health and the environment through pollution of domestic water supplies. Lee and
Jones-Lee (2005b) have recently published a review on unrecognized pollutants.
57
Figure 10
Chemical Sources for California Coastal Water
While often not considered and largely unregulated, municipal solid waste leachate contains a
variety of human and animal fecal waste and other wastes that contain disease organisms, such as
bacteria, viruses, cyst-forming protozoans and intestinal parasitic worms. Of particular concern
are sewage sludge and diapers. As discussed below, vermin (small animals, including insects) and
birds can transport disease organisms from the solid wastes to the areas near the landfill, thereby
exposing people and animals to disease organisms.
Construction and Demolition Waste Landfilling
Associated with the construction of new structures are various types of waste materials that are
landfilled. Redevelopment of areas often requires demolition of existing structures wastes that also
need to be landfilled. This leads to construction and demolition (C&D) wastes as a special category
of solid waste materials that are landfilled. There are no federal regulations governing the
landfilling of C&D wastes. Each state has developed its own regulatory approach. These
approaches range from deposition of C&D wastes in MSW landfills, to landfilling with limited
environmental protection with respect to liners for leachate collection, groundwater monitoring,
etc. There is a basic problem with the regulation of the landfilling of C&D wastes, in that some
regulatory agencies consider C&D wastes to be “inert,” and therefore a limited threat to cause
environmental pollution. However, there is substantial evidence that C&D wastes generate
leachate that is a threat to cause water pollution.
ICF Inc. (1995a), under contract with the US EPA Office of Solid Waste, conducted a review of
the characteristics of leachate generated by construction and demolition waste landfills.
Construction and demolition landfill leachate sampling data were collected from 21 C&D
58
landfills. Data were provided for 305 parameters. Potentially significant concentrations, compared
to drinking water maximum contaminant levels (MCLs), were found of 1,2- dichloroethane,
methylene chloride, cadmium, iron, lead, manganese and total dissolved solids (TDS).
ICF Inc. (1995b) conducted a review of the “damage cases” caused by construction and demolition
waste landfills. ICF Inc. (1995b) identified 11 damage cases where there was groundwater
contamination by the C&D landfill. Constituents causing groundwaters to exceed the drinking
water MCL were iron, manganese, TDS and lead. According to ICF Inc. (1995a), there were over
1,800 C&D landfills operating in the United States in the mid-1990s. Therefore, only a small
number of the C&D landfills have been examined for groundwater pollution.
The state of Ohio Environmental Protection Agency, Division of Solid Wastes, has been
conducting studies on the characteristics of C&DD waste leachate. This agency has developed,
“A Comparison of Selected Parameters From Ohio Construction & Demolition Debris Leachate
with Ohio Municipal Solid Waste Leachate - June 2009” and Ohio EPA 2007 C&DD Leachate
Raw Chemical Analytical Data [Excel].” The results are available in Ohio EPA (2009).
Waste Age (2009b) has reported that the St. Louis Post-Dispatch reported, “Dangerously
High” Methane Levels Recorded at St. Louis from a former C&D landfill.
According to this article,
“The Missouri Department of Natural Resources (DNR) issued a statement on Friday that
recent tests had shown methane gas levels at the St. Louis Demolition Landfill are
“dangerously high.” DNR officials warned that methane levels are well above the regulatory
limit and, in some cases, are concentrated enough to be explosive. The landfill is located in
the northern part of St. Louis and is near several residential areas.
Subsequent testing by firefighters did not indicate elevated methane levels in houses in the
nearby Baden neighborhood, according to the St. Louis Post-Dispatch. Testing continues and
residents are being offered methane detectors as a precaution.
The St. Louis Demolition Landfill was built 50 years ago, predating current landfill
regulations. It has not accepted waste for 12 years. The city of St. Louis (which purchased the
landfill 30 years ago) has been working with DNR to try and cap the site.”
In addition to the recognized pollutants in household items, there is increasing recognition that
homes contain a wide variety of chemicals that when placed in a landfill will cause
environmental pollution. As discussed above, Daughton (2002; 2004a,b) has reviewed the
fact that the current water quality monitoring programs for characterizing landfill leachate
in groundwaters polluted by landfills are significantly deficient in describing the full range
of pollutants that are a threat to public health and the environment.
PFAS Pollutant. Per- and polyfluoroalkyl substances (PFASs) are an example of previously
unrecognized hazardous chemicals that have become widely found in the environment. A
search of the Internet shows that PFASs, manufactured and used in a variety of industrial and
commercial products since the 1940s, have only in recent years become recognized as
widespread pollutants. The US EPA published “Basic Information on PFAS”
(https://www.epa.gov/pfas/basic-information-pfas) in which it was noted that PFAS can be
found in food packaged in PFAS-containing materials, processed with equipment that used
PFAS, or grown in PFAS-contaminated soil or water. They are found in a wide variety of
59
commercial household products, as well as fire-fighting foams, and production facilities and
industrial applications. They can, therefore be expected to be present in locations such as
landfills in which household and hazardous materials are disposed. The US EPA information
also noted that PFAS are very persistent in the environment and the human body and can
accumulate over time; there is evidence that exposure to PFAS can lead to adverse human health
effects. On March 6, 2019 the California Water Resources Control Board (CWRCB, 2019) held
a public meeting during which representatives of federal and state agencies discussed what is
known about the occurrence and hazards of PFAS compounds. At this time there is an intensive
international investigation on environmental and public health issues associated with PFAS
substances, including those present in municipal and industrial landfills. Additional
information on environmental quality issues associated with these substances is available at
https://www.waterboards.ca.gov/pfas and https://www.epa.gov/pfas.
In the fall of 2019, the US EPA awarded, as part of its Science to Achieve Results (STAR)
program, eight grants to conduct research to better understand the environmental risks posed by
per- and poly-fluoroalkyl substances (PFAS), and identify practical approaches to manage their
potential environmental impacts [https://cfpub.epa.gov/ncer_abstracts/index.cfm/fuseaction/
recipients.display/rfa_id/643/records_per_page/ALL]. Those ongoing projects focus on PFAS in
landfill gas; landfills as sources of PFAS in groundwater; occurrence, fate, transport, and treatment
of PFASs in landfills and landfill leachate; destruction of PFAS in leachate and groundwater;
PFAS in municipal wastewater effluent and biosolids; and treatment/destruction of PFAS in
groundwater, wastewater, sludges, soils, and landfill leachate. Links to additional information on
each of those projects and progress reports, as well as to the publications emanating from those
ongoing studies are available at https://cfpub.epa.gov/ncer_abstracts/index.cfm/fuseaction/
publication.forward?RequestTimeout=180.
PCBs in Caulk in Older Buildings.
Recently, it has become more widely recognized that
construction and demolition wastes can contain appreciable concentrations of PCBs. For
many years PCBs were used in sealants in concrete joints and wooden structures. This means
that construction and demolition wastes can contain PCBs. This issue has been recognized in
Europe, Australia and other countries. There are a number of papers and reports on this issue
from other countries, which provide additional information on the presence of PCBs in various
types of structures. Of particular concern are the publications by Åstebro et al. (2000), BUWAL
(date unknown) and CFMEU (date unknown). A comprehensive review of what was known in
2004 about PCBs in structures as a diffuse source of PCBs for the environment has been
developed by Kohler et al. (2005). Klosterhaus et al. (2011) have presented a report of the
study of PCBs in stormwater runoff from currently standing buildings. They report that the
PCBs found in urban stormwater runoff can be derived from demolition of older building from
the PCB in the caulk in these buildings.
According to the US EPA, “Caulk is a flexible material used to seal gaps to make windows, door
frames, masonry and joints in buildings and other structures watertight or airtight. At one time
caulk was manufactured to contain PCBs because PCBs imparted flexibility. The US EPA has
developed Preventing Exposure to PCBs in Caulking Material at,
http://www.epa.gov/pcbsincaulk/caulkexposure.htm discusses that PCBs are found in high levels
in building caulk. Caulk containing high levels of PCBs (polychlorinated biphenyls) has been
found in many schools and other buildings built or remodeled before 1978. Because PCBs can
60
migrate from the caulk into air, dust, surrounding building materials, and soil, EPA is concerned
about potential PCB exposure to building occupants.
In general, schools and buildings built after 1978 do not contain PCBs in caulk. On September
25, 2009, EPA announced new guidance for school administrators and building managers with
important information about managing PCBs in caulk and tools to help minimize possible
exposure. Through EPA's Regional PCB Coordinators, the Agency will also assist communities
in identifying potential problems and, if necessary, developing plans for PCB testing and removal.
The Agency has prepared a Fact Sheet (PDF) “Questions and Answers information is provided
in, http://www.epa.gov/pcbsincaulk.”
Additional information on the potential presence of PCBs in C & D wastes is presented by Lee
and Jones-Lee (2010 d, e). Studies in the San Francisco Bay area have been found that urban
stormwater runoff contains sufficient PCBs to contribute to excessive PCBs concentrations in
receiving water fish. One of the sources of the PCBs in urban stormwater runoff has been found
to be runoff from residential/commercial/industrial demolition areas where there is release of
PCBs from caulking compounds used as sealant at wood and concrete joints.
Dr. Lee has been involved in investigating the occurrence of PCBs in water, wastes, and fish since
the late 1960s. Veith and Lee (1970) study and paper were among the first published on PCBs as
water pollutants in US waters. Dr. Lee has continued to be active in investigating PCBs pollution
since that time. A summary of work on his PCBs pollution studies is available in Lee (2006h).
Lee and Jones-Lee (2015) have prepared guidance on evaluating the potential pollution of
waterbodies that lead to excessive concentrations of PCB in fish tissue that are a threat to those
who use the fish as food.
The authors of this flawed technology report have been involved in the review of several C&D
landfilling situations. These include evaluating the potential threat of expanding the
Taylorsville Road Hardfill Landfill in Huber Heights, Ohio (Lee 2002a). It was concluded
that the expansion of this landfill was a threat to the domestic groundwater supply water
quality for Huber Heights. Lee have been involved in the review of two proposed C&DD
landfills in Morrow County, Ohio (Lee 2006f), and in evaluating the potential impact of city of
New Orleans hurricane Katrina household and commercial wastes and demolition wastes that
were deposited on top of the city’s unlined, closed MSW Gentilly Landfill (Lee, 2006g,h,i).
In both cases, the state regulatory agencies allow landfilling of C&D wastes in landfills that only
have a compacted soil liner. In the case of the Gentilly Landfill, the Louisiana Department
of Environmental Quality (LDEQ) issued a permit which enabled the city to increase the height
of the Gentilly Landfill from 18 feet to 130 feet above ground level. LDEQ also significantly
relaxed the restrictions on the types of so-called C&D landfill wastes that could be deposited
at this landfill to include painted furniture, mattresses and many other types of household items
that were destroyed by the flooding of homes associated with the hurricane Katrina situation.
Dubey, et al.(2007) reported on the “
Quantities of Arsenic-Treated Wood in Demolition Debris
Generated by Hurricane Katrina,” According to the article abstract,
“The disaster debris from Hurricane Katrina is one of the largest in terms of volume and
economic loss in American history. One of the major components of the demolition debris is
wood waste of which a significant proportion is treated with preservatives, including
61
preservatives containing arsenic. As a result of the large scale destruction of treated wood
structures such as electrical poles, fences, decks, and homes a considerable amount of treated
wood and consequently arsenic will be disposed as disaster debris. In this study an effort was
made to estimate the quantity of arsenic disposed through demolition debris generated in the
Louisiana and Mississippi area through Hurricane Katrina. Of the 72 million cubic meters of
disaster debris generated, roughly 12 million cubic meters were in the form of construction
and demolition wood resulting in an estimated 1740 metric tons of arsenic disposed.
Management of disaster debris should consider the relatively large quantities of arsenic
associated with pressure-treated wood.”
An issue of increasing concern about waste wood is the potential for treated wood to leach
arsenic, copper and chromium. Townsend and his associates at the University of Florida
have conducted a number of studies on the leaching of these chemicals from treated wood
(Townsend,
et al. 1998; Jambeck et al. (2008), Khan, et al. 2004, et al. 2008 and
Engelhaupt,2007). They have found that the chemicals are somewhat leachable over a long
period of time and represent a threat to groundwater quality. Lee (2007) has discussed the
importance of properly managing waste treated wood in appropriately designed and monitored
landfills, in order to prevent groundwater pollution by chromium and arsenic.
McDilda (2010) presented a discussion of the potential pollution of groundwaters by chromium
used to treat wood to control decay. This report discusses the threat that allowing treated wood
in C & D landfills. The disposal of chromate copper treated wood is one of the types of wastes
of greatest concern for disposal in C & D landfills.
Zhour and Algazi (2011) present a report on the approach followed in California to manage
treated wood wastes. DTSC treated wood regulations allow that treated wood wastes may be
disposed of either in a hazardous waste landfill or in a composite lined portion of a solid waste
landfill approved to accept it by the appropriate Regional Water Quality Control Board
(RWQCB).
An issue of particular concern at C&D waste landfills is the management of hydrogen sulfide
emissions from the landfill. Wallboard (which is composed of calcium sulfate), in the
presence of decomposable organic matter and water, can produce large amounts of hydrogen
sulfide, where the sulfate in wallboard is reduced by bacteria to sulfide. The US EPA
(2005) is developing a guidebook on managing hydrogen sulfide at C&D waste disposal
facilities. This guidance discusses the potential for hydrogen sulfide generated from the
decomposition of wallboard in C&D landfills to not only cause an airborne nuisance to nearby
individuals, but, at high concentrations, also a health threat. This guidance discusses approaches
that can be used to minimize hydrogen sulfide production at C&D landfills.
The state of California does not have specific C&D landfilling regulations. It does have
regulations governing the disposal of “inert” wastes. Inert waste is defined as “that subset of
solid waste that does not contain hazardous waste or soluble pollutants at concentrations in
excess of applicable water quality objectives, and does not contain significant quantities of
decomposable waste” (SWRCB Division 2, Title 27, §20230). Inert wastes do not require
deposition in a managed area. It is, however, up to the proponent for managing such waste to
demonstrate that the wastes comply with the inert waste definition. Since many construction
62
and demolition wastes have leachable components, much of this type of waste is placed in
MSW landfills in the State. In some areas of the State, MSW landfills require a double
composite liner.
The only water quality threat posed by these inert wastes is siltation according to Marshack
(1989) of the State Water Resource Control Board,
Marshack (1989) has discussed the approach used to determine whether a waste is an “inert
waste.” The California Department of Health Services and the State Water Resources Control
Board have established regulations which provide detailed criteria on how wastes are to be
classified, with the exception of the “designated waste” category. According to Marshack,
“The lower boundary of this category is described only as the limit above which a waste could
impair water quality at the site of discharge. This boundary can be more clearly defined by
establishing ‘Designated Levels’ for specific constituents of a waste which provide a site
specific indication of the water quality impairment potential of the waste. [The Marshack
(1989)] report provides a methodology for calculating such levels. Designated Levels are
calculated by first determining the bodies of water that may be affected by a waste and the
present and probable future beneficial uses of these waters. Next, site-specific ‘water quality
goals’ are selected, based on background water quality or accepted criteria and standards,
to protect those beneficial uses. Finally, these water quality goals are multiplied by factors
which account for environmental attenuation and leachability. The result is a set of Soluble
and Total Designated Levels which are applicable to a particular waste and disposal site and
which, if not exceeded, should protect the beneficial uses of waters of the State. Wastes having
constituent concentrations in excess of these Designated Levels are assumed to pose a threat
to water quality and are, therefore, classified as ‘designated wastes’ and directed to waste
management units which isolate these wastes from the environment.”
According to this approach, inert wastes would be those that do not contain soluble
components at concentrations that, when deposited at a particular location, would leach
constituents that, through the Designated Level Methodology, would be considered a threat to
ground and surface water quality in the disposal area. Implementation of this approach
requires a site specific evaluation of the leaching characteristics of the types of wastes that are
proposed to be classified as inert wastes, the hydrogeology of the proposed inert waste
deposition area, as well as information on the present and probable future designated
beneficial uses of the ground and surface waters that would be impacted by materials
potentially released from the inert wastes. Wastes that do not meet the inert waste
classification must be deposited in a managed waste disposal landfill, such as an MSW landfill
or hazardous waste landfill.
Buske, et al. (2005) have presented a discussion of the characteristics of landfill odors and
some of the approaches for assessing the magnitude of odor, and its control. The focus of
their discussion is the potential adverse impacts of using fines from C&D wastes as landfill
daily cover. They report that this approach has led to severe, persistent offsite odors, where it
was necessary to terminate this approach.
It is evident that C&D wastes should not be considered inert. These wastes can leach
components that can cause groundwater pollution. They should be managed in properly sited,
designed, operated and closed landfills that receive postclosure care (maintenance and
63
monitoring) for as long as the wastes in the landfill are a threat, upon contact with water, to
generate leachate.
A subsequent section of this report (Improving Public Health and Environmental Protection from
Inadequately Developed Landfills) discusses improving public health, groundwater resource and
environmental quality protection associated with inappropriately sited and inadequately
designed, operated and closed landfills and those landfills for which there is inadequate
postclosure monitoring and maintenance for as long as the wastes in the landfill will be a threat.
This section has particular applicability to C&D landfills, where regulatory agencies in a state
do not adequately regulate such landfills to protect public health and the environment.
An important difference between minimum design Subtitle D landfills and the C&D landfills that
are allowed in a number of states is that the Subtitle D landfills with their single composite liner
can postpone pollution of groundwaters for many years, while C&D landfills with only a
compacted soil/clay liner will start to pollute the underlying groundwater aquifer system within
a short time after waste deposition occurs in the landfill.
Aluminum Production Wastes
Stark and his associates have published several papers, Calder and Stark (2010), Stark et al.
(2012), Jafari, Stark, and Roper (2013), (2014) on the problems caused by depositing aluminum
production in municipal landfills. Calder and Stark (2010) in the paper abstract, “Aluminum
Reactions and Problems in Municipal Solid Waste Landfills,” Practice Periodical of Hazardous,
Toxic, and Radioactive Waste Management” stated,
“Abstract: Aluminum enters municipal solid waste _MSW_ landfills from untreated raw
curbside trash _MSW_, industrial waste, and aluminum production wastes variously called
dross, baghouse fines, salt cake, and other designations. Aluminum related reactions can arise
and become problematic for landfill operations by generating undesirable heat, liquid leachate,
and gases, such as hydrogen, hydrogen sulfide, carbon monoxide, and ammonia. Temperature
excursions up to _150°C _300°F_ and landfill gas pressures exceeding 210 kPa have been
observed. Water from the MSW, precipitation, injection, and/or surface water management can
result in sufficient water to trigger problematic aluminum related reactions. Another source of
water in a MSW landfill is leachate recirculation, which is not recommended if substantial
aluminum is present in the landfill mass because it can lead to a problematic aluminum related
reaction. This paper examines the chemical reactions involving aluminum in landfills and the
negative consequences of introducing aluminum into MSW landfills regardless of its origin.
Proposals for mitigating aluminum reactions are also presented.”
As discussed in their paper the reactions of aluminum production wastes generate elevated
temperatures in MSW landfills that can damage the HDPE landfill liner. While aluminum
production wastes are not classified as a hazardous wastes and managed accordingly and not be
allowed to be deposited in MSW landfills.
Hazards of Living/Working near Landfills
There are questions about the potential hazards of using a closed landfill as a playfield for
children, constructing a school or playground adjacent to a closed (inactive) landfill, or
purchasing residential property near an active and/or closed landfill. The public is justifiably
concerned about the hazards of living next to, locating a school next to, or locating a playfield
on a former landfill. Landfills, even those that contain so-called “nonhazardous” wastes,
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contain a variety of hazardous chemicals that, if not properly managed, can pollute
groundwaters, soil and the atmosphere and therefore be a threat to those using properties near
the landfill.
An issue of concern is whether those who live near landfills show evidence of adverse health
effects. Lee and Jones-Lee (2007c) have recently discussed this issue. It is known from a
number of studies conducted by the Centers for Disease Control (Anderson, pers. comm., 1999)
that some populations living near landfills have shown a greater incidence of some diseases.
Elliott et al. (2001) have reported that children of people living near landfills in England tend
to have a higher rate of birth defects than the general population. Environmental Health
Perspectives has published a paper (Kouznetsova, et al., 2007) which relates residential
proximity to hazardous waste sites to hospitalization associated with diabetes. A review of the
various studies that have been conducted, however, reveals that the epidemiological approach for
discerning health effects associated with populations living near landfills is not sufficiently
sensitive to reliably determine whether releases from the landfill are at least in part
responsible for the health effects. A complicating factor is that those living near landfills
frequently are economically disadvantaged and of a different ethnic mix than the general
population. Further, data that have been developed on this issue have often been devoted to
former (closed) landfill situations, where there is far greater limiting of landfill emissions
than will occur, at least initially, with today’s Subtitle C and D landfills.
In the Lee and Jones-Lee (2007b) discussion of the hazards of living/working near landfills and
hazardous chemical sites, they state,
“It is well-established that airborne releases from hazardous chemical sites (including active
and inactive landfills) can have a significant adverse impact on the population within the
sphere of influence of the site.”
The Agency for Toxic Substances and Disease Registry (ATSDR, 2006) has developed a
discussion on gaseous emissions from landfills, in which it state,
“Many of the typical landfill gases, notably the alkyl benzenes and the sulfur compounds (both
organosulfides and acid gases), may present an odor problem that can cause adverse
health effects such as mucous membrane irritation, respiratory irritation, nausea, and
stress. If an individual has a pre-existing health condition (e.g., allergies, respiratory illness),
these additional health impacts can be significant.”
Lee and Jones-Lee (2007b) further state,
“With respect to the populations at risk from airborne releases of hazardous chemicals from a
hazardous chemical site/landfill, as a first estimate, it would be all individuals who
experience odors from the site. While many of the chemicals that are responsible for illness are
non-odorous, typically, airborne releases from hazardous chemical sites/landfills have
odorous components which are readily detectable. It is for this reason that hazardous
chemical site and municipal, industrial and hazardous waste landfills should be practicing
sufficient odor control so that there is no detectable odor at the site boundary – i.e., no trespass
of odorous emissions onto adjacent properties. The odor control should not be done through
masking agents, but with treatment technologies that destroy the odor and, it is to be hoped, the
hazardous chemicals associated with the odor as well.
It should not be assumed that the typical testing for airborne releases of hazardous chemicals
65
associated with the evaluation of the impact of a landfill or other hazardous chemical site on
adjacent properties is adequate to detect airborne hazardous chemicals released from the site.
For some hazardous chemicals the analytical method detection limits are not adequate to
detect the hazardous chemicals at concentrations of concern, either individually or in
combination with other chemicals. The evaluation of whether odorous chemicals are being
released from a site should be based on a properly documented assessment by individuals
with above-average olfactory sensitivity.”
Graiver et al. (2009) has reported that H6N2 sub-type of the avian influenza virus can remain
infectious in MSW landfill leachate for up to 600 days. They conclude that the disposal of
bird flu infected birds
carcasses
in MSW does not represent a threat to other birds.
Recommended Approach.
The recommended approach for utilizing landfill covers and areas
adjacent to landfills for situations where children can be exposed to waste-derived constituents
should involve a detailed, third-party, independent review of the magnitude of the releases
that are occurring from the landfill to the atmosphere, to surface water runoff and to
groundwater. This should require at least a one-year detailed monitoring effort that is
conducted from the perspective of trying to find problems. This perspective is important
since, in many cases, studies sponsored by landfill owners, as well as the studies conducted
by consultants who typically work for potential site developers, are biased toward not finding
problems – i.e., doing the minimum necessary to get by current regulatory agency
requirements.
There is need for the site investigations to be conducted by a third-party managed team, where
the management team has a proper balance of individuals who are knowledgeable and
interested in full protection of public health and the environment. This does not mean that the
team should be dominated by what are sometimes called “environmental activists.” Some
individuals who operate in this arena tend to distort the technical information available, and
thereby have limited credibility in striking a proper balance.
Landfill Siting Issues
The US EPA, as part of the development of Subtitle D landfill regulations, failed to address
one of the most important issues that should be addressed in developing a minimum Subtitle
D landfill – namely, the siting of the landfill at geologically suitable sites for a landfill of this
type. While the Agency does require that minimum Subtitle D landfills not be sited too
close to airports, where there could be major bird problems for aircraft, or too near an earthquake
fault or within a flood plain, the Agency did not address the issue of siting minimum Subtitle D
landfills where the underlying geological strata do not provide natural protection of the
groundwaters from pollution by landfill leachate when the landfill liner systems eventually
fail. In accordance with current regulations, minimum Subtitle D landfills can be sited over
highly important aquifers that serve as a domestic water supply source for an area. They
can also be sited in fractured rock and cavernous limestone areas, where it is impossible, through
the use of vertical monitoring wells, to reliably monitor the pollution of groundwaters by landfill
leachate.
As discussed Anderson (1995) seismic activity in the vicinity of a landfill has been found to
damage landfill containment systems. These impacts can occur in landfills located outside
the areas where the US EPA Subtitle D landfills prohibit landfill siting.
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The US EPA in developing Subtitle D landfill regulations, also failed to address one of the most
important reasons why landfills lead to a justified NIMBY (“Not In My Back Yard”)
attitude. US EPA Subtitle D regulations allow the deposition of wastes very near the landfill
property owner’s property line.
Justified NIMBY
Hirshfeld et al. (1992), of Duke University, in a paper, “Assessing the True Cost of Landfills,”
have summarized the potential impacts of landfills that should be addressed as part of landfill
development. They point out that the environmental and social costs of landfills are usually
ignored, which in turn inhibits the development of other waste management options, such as
waste reduction, recycling and resource recovery. They divide the impacts of landfills into
“physical” impacts and “social” impacts. The physical impacts are related to ground and surface
water pollution by leachate migration, atmospheric releases of landfill gas, and fires. Landfill
gas is known to cause explosions resulting in loss of life and property, and damage to vegetation.
Hirshfeld et al. also point out that the non-methane organic compounds in landfill gas contain
toxic chemicals that are a threat to cause cancer. Further, other components in landfill gas,
such as hydrogen sulfide and organosulfur compounds can cause unpleasant odors associated
with landfills.
The social impacts of landfills include increased traffic, visible air pollution, noise, aesthetic
degradation and limited land utility. The social-impacts cost of landfills, according to
Hirshfeld et al., is “(1) the cumulative decrease of surrounding property values; (2) the cost
associated with land utility effects, also known as an ‘opportunity cost’; and (3) a
‘hastening cost’.” Several of these issues are discussed further below.
The state of Washington Department of Ecology in its Beyond Waste Project is conducting a
comprehensive review of solid waste management practices in the state. As part of this effort a
series of documents has been developed which discuss solid waste management issues. One
of these publications, “Disposal – Yesterday, Today and Tomorrow” (Smith, 2004) states,
“The extent to which today's landfills adequately protect human health and the environment is a
subject of debate, however. Requirements that govern siting, operation, closure, and post-
closure are stringent and extensive. While the newest landfills are state-of-the-art facilities,
they are far from benign in their impacts. Landfills may still affect the air, land, and water but
to a significantly lesser degree than before today’s standards went into effect.”
Typically, landfill proponents will characterize local opposition to a landfill as an ill-founded
“Not In My Back Yard” (NIMBY) response of the public in the region. The authors have yet
to find an individual located near a proposed landfill who does not become a “NIMBY.”
However, it is the authors’ experience that, with few exceptions, all of those within a few
miles of a proposed landfill are justified in their NIMBY response.
The authors have been involved in investigating over 80 landfills located in various parts of
the US and in several other countries. They have also served as consultants to public groups
and agencies on the potential impacts of proposed and existing landfills. Several years ago
they published two papers, “Addressing Justifiable NIMBY: A Prescription for Siting
MSW Landfills,” (Lee and Jones-Lee, 1994d) and “Landfill NIMBY and Systems
Engineering: A Paradigm for Urban Planning” (Lee et al., 1994), which discuss when NIMBY
is justified.
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The above-cited papers and presentation slides provide a discussion of the potential impacts of
landfills and, most importantly, how many of these impacts can be controlled through proper
landfill siting, design, operation, closure and postclosure monitoring and maintenance. As
discussed by Lee and Jones-Lee (1994d), one of the key areas that can significantly reduce
justified NIMBY is the provision for adequate buffer land between where wastes are deposited
and adjacent properties. This buffer land is needed to dissipate the releases of waste-derived
components in leachate (“garbage juice”) and landfill gas.
Fickes in a recent article discussed several of the so-called “nuisance” impacts of MSW
landfills with emphasis on approaches that are used to attempt to control the adverse impacts
of releases such as odors, dust, etc from MSW landfills. Lee (2011g) discussed that this
article fails to discuss the problems with each of these types of releases that cause justified
NIMBY by those who own/use properties near a MSW landfill.
Lee and Jones-Lee (2007d) have presented a discussion of the issues that need to be
considered in evaluating the potential impacts of a landfill on those within the sphere of
influence of the landfill. This review provides guidance on how those concerned about the
siting of a landfill in their area should proceed to evaluate its potential impacts on their health,
groundwater resources and interests.
Table 2, from the Lee et al. (1994) paper, lists the potential adverse impacts of landfills. As
discussed above, the current typical municipal solid waste stream contains a wide variety of
known and yet-to-be-identified hazardous and otherwise deleterious chemicals that are a threat
to public health and the quality of groundwater that is used for domestic and agricultural
purposes.
Table 2
Adverse Impacts of “Dry Tomb” Landfills on Adjacent/Nearby
Property Owners/Users
_________________________________________________________
•
public health, economic and aesthetic aspects of groundwater and
surface water quality
•
methane and VOC migration - public health hazards, explosions
and toxicity to plants
•
illegal roadside dumping and litter near landfill
•
truck traffic
•
noise
•
dust and wind-blown litter
•
odors
•
vectors, insects, rodents, birds
•
condemnation of adjacent property for future land uses
•
decrease in property values
•
impaired view
_________________________________________________________
From Lee et al. (1994)
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Inadequate Buffer Lands
.
Landfill developers state that appropriate buffer zones have been
planned for a proposed landfill, where a few hundred feet are allowed between where the wastes
will be deposited and adjacent properties. While landfill developers claim that appropriate buffer
zones have been planned, in fact even the most elementary understanding of the distances over
which modern landfills can be adverse to adjacent property owners/users’ health, welfare and
interests shows that often several miles of buffer land is needed to dissipate the releases from a
landfill on the landfill owner’s property so that they are not adverse to adjacent property
users/owners.
Other Impacts of Landfill Releases and Activities.
Landfills can have a variety of additional
impacts, such as fugitive trash, vermin, birds, noise, lights, etc., which are deleterious to the
interests of those in the sphere of influence of the landfill. One of the major deficiencies of
Subtitle D landfilling regulations is that the US EPA failed to address the justified NIMBY
issues by failing to require that landfill owners provide adequate buffer lands between where the
wastes will be deposited and adjacent properties. The typical approach that landfill
owners/operators claim they will use as part of gaining a permit for siting a landfill, of
limiting the size of the working face where each day’s garbage is deposited, and then at the end
of the day covering the daily deposited garbage with a thin layer of soil or other material, can,
if fully implemented, reduce the magnitude of many of the adverse impacts associated with
releases from the landfill during its active life, but does not eliminate them so that they are not
adverse to adjacent property owners/users in those situations where there are inadequate
buffer lands between the waste deposition area and adjacent properties. With at least a mile of
land between where wastes are deposited and adjacent properties, it is possible to reduce the
magnitude of justified NIMBY. To completely eliminate justified NIMBY would require, at
many landfill locations, several miles of buffer lands owned by the landfill owner between
where wastes can be deposited and adjacent properties.
Vermin-Disease Vectors. Vermin include animals such as rats and other rodents, and insects
such as flies. In addition to being a nuisance, vermin can be vectors (carriers) of disease
organisms and hazardous chemicals. Birds (gulls, crows, etc.) can be a significant problem at
landfills, where large numbers will congregate and circle the landfill area, defecating on nearby
residents and their properties, as well as schools, etc.
Noise Pollution. Hirshfeld et al. (1992) discuss landfill noise as part of their discussion of
“Social Impacts” of landfills:
“Noise at landfills can be noticeable in nearby residential areas. The USEPA (1975) notes that
excessive noise can have many undesirable effects on those exposed to it. In most cases,
however, the noise is simply regarded as an annoyance.”
Noise pollution of the areas near a proposed landfill is a justified issue of concern because of the
often limited buffer land between where wastes will be deposited and adjacent properties. This
means that adjacent property owners can potentially experience noise pollution on their
properties by the proposed landfill.
Light Pollution. Another issue of concern to the public is that some landfills operate at night,
where nearby property owners would experience pollution by lights at the landfill. Some
landfill operators plan to operate heavy equipment at night, under lights, for compaction of
the wastes that had been received that day. This can lead to significant disruption of the
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interests of the nearby property owners/users, which should be controlled/prohibited.
Stormwater Flooding Problems. Frequently, landfill applicants will state that a landfill
facility will be designed, constructed and maintained with a run-on control system to prevent
flow onto the active portion of the landfill during the peak discharge from a 25-year storm,
and a run-off control system from the active portion of the landfill to collect and control at
least the water volume resulting from a 24-hour, 25-year storm. Some members of the public
are concerned about a proposed landfill causing increased flooding of their property through
diversion of stormwater. While, the landfill developer plans to collect all stormwater that
occurs on the landfill property in detention basins, this collection only applies to storms that
result in a magnitude of less than the 25-yr, 24-hr discharge. Storms of greater magnitude
than this will result in runoff from the landfill property onto adjacent properties.
Some landfills are constructed with a berm around the landfill property to divert waters
around the property that now run onto this property. This berm could lead to increased
flooding problems downstream of the proposed landfill. This would be of justifiable
concern to the public, unless the landfill owner is required to manage the waters that now run
onto the landfill property, which would be diverted around it by a berm, in such a way as to
restore the current flow regime and amount downstream of the proposed landfill. Without
requiring this approach, some downstream property owners could be adversely affected by the
proposed stormwater management approach.
Decreased Values of Nearby Property
.
One of the major concerns of property owners with the
establishment of a landfill in their area is the decrease in their property values. Establishing a
landfill with inadequate buffer lands between the waste deposition area and adjacent properties
leads to decreased property values. This is a consequence of landfill owners/operators’ failing to
adequately control landfill releases to the air (odors, explosive gases, hazardous volatile
chemicals, etc.) and groundwater (pollution), and landfill-associated activities such as truck
traffic, noise, lights etc. While some landfill owners will claim that establishing a proposed
landfill will not affect nearby property values, this is not in accord with the results of the studies
conducted by Hirshfeld et al. (1992). They reported, based on studies at various locations, that
decreased property values have been found as far as three miles from the landfill.
Hite et.al., (2000) have discussed the potential impact of MSW landfills on nearby property
values where they conclude that MSW landfills decrease the property values near the landfill.
Individuals who own land immediately adjacent to a proposed landfill, as well as most others
who own property within several miles of a landfill, can be expected to have their property
values significantly decreased by the development of the landfill. This is of particular economic
significance to some property owners, since their property could be developed with substantial
residential and commercial activities if it were not for the presence of the landfill.
Host Fees.
A tactic that is widely used by landfill developers is to offer the local community
a “host fee” of a dollar or so per ton of waste deposited in a landfill, which the community can
use for various purposes. In developing this arrangement, the landfill developer is careful not
to site the landfill near the properties of those community officials who are responsible for
voting to accept the host fee. The magnitude of the host fee made available is typically small
compared to the ultimate cost that will have to be spent in mitigating the effects of the
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landfill and the Superfund-like groundwater cleanup costs that will occur for future
generations. Further, it is rare, if ever, that the host fee is used to compensate those within the
sphere of influence of the landfill for their lost property value and other adverse impacts on
their health, groundwater resources and interests.
Lee (2010a, 2010b, 2010c, 2010d) has reviewed the permitting of the expansion of the Allied
Imperial landfill expansion located in Imperial County, County where he found that the County
Board of Supervisors ignored the fact that the existing landfill was not adequately sited and
monitored to detect its impact on public health, agricultural crop production and the
environment through gaseous and leachate releases to nearby properties. The proposed
expansion of this landfill will continue this situation. It appears that the County Board is more
interested in receiving host fees associated with the landfill expansion than protecting public
health and the environment.
Lee (2011a) has provided additional comments on why the proposed Gregory Canyon Landfill
that is to be located in northern San Diego County, California should not be permitted. These
include that the eventual failure of the landfill liner system and the unreliable groundwater
monitoring will not protect an important domestic water supply source in the area of the landfill.
Even though it is well established that landfill located in areas will eventually pollute
underlying groundwater by landfill leachate landfill developers and regulatory agencies allow
MSW minimum design landfills to be developed in desert areas. A recent example is the
Jungo Landfill that is to be located in northern Nevada. The Nevada Land and Resource, Inc.
of Carson City, NV (owner) and Recology of San Francisco, CA (operator) proposed to
construct and operate a Class I municipal solid waste (MSW) landfill facility, referred to as
the Jungo Landfill, approximately 25 miles west of the city of Winnemucca, NV. The
Nevada Division of Environmental Protection (NDEP) Bureau of Waste Management
provides information concerning that proposed landfill and its permitting process for that
landfill. This proposed landfill would rail haul about 4,000 tons per day of San Francisco bay
area garbage for 100 years. On behalf of the Humbodt NV County Commissioners Lee and
Jones-Lee (2011) provided a detailed discussion of the long term public health and
environment problems of this proposed landfill. Nevada Department of Environmental
Protection approved the operation of this landfill ignoring the long term impacts o the
proposed landfill on the groundwater resources of the area
.
Impact on the Three Rs
Today’s initially cheaper-than-real-cost solid waste management by deposition of MSW in
minimum Subtitle D landfills is strongly contrary to effective conservation and reuse of solid waste
components. Lee and Jones-Lee (2000) have discussed the importance of reducing, reusing and
recycling (the “Three Rs”) as much of the components of solid waste as possible as a resource
conservation measure and for protection of groundwater resources, public health and the
environment, under the conditions where the true cost of landfilling of solid waste in dry
tomb landfills is paid as part of disposal fees.
Environmental Justice Issues
A key issue that needs to be evaluated with respect to environmental justice is whether the
siting of a landfill will result in impacts that violate Title VI requirements for protection of
minorities against sources of environmental problems. Property owners should have the right
to be able to use and develop their property without the adverse impacts of a landfill. Lee
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and Jones-Lee (2004e) have discussed an environmental justice situation with respect to
locating a MSW landfill in Mobile, Arizona.
Professional Ethics Issues
It is appropriate to inquire why there is not greater discussion of the significantly flawed
approach of Subtitle D landfilling. It is the authors’ experience that these issues are well-
understood by many of those in regulatory agencies and in the landfill consulting community;
however, as discussed by Lee and Jones-Lee (1995b), there is a significant professional ethics
issue associated with the permitting of landfills, where those who develop landfills for public and
private agencies do not discuss these problems, since it would mean that their firm would not
gain further work from landfill developers.
Landfill permitting in the US is conducted in an adversarial arena, where landfill applicants and
their consultants discuss only the positive aspects of a proposed landfill, and do not discuss the
problems associated with the landfill. This provides the regulatory agencies responsible for
permitting landfills with an unreliable information base upon which to make decisions on the
permitting of a landfill. Lee and Jones-Lee (1995b) recommend that the current adversarial
landfill permitting approach be replaced by a publicly conducted interactive peer review process,
where both the positive and negative aspects of a proposed landfill can be discussed. Adoption
of this approach would greatly improve the reliability of the information provided to regulatory
agencies as part of permitting of landfills.
An issue of concern in the permitting of landfills is whether consulting firms that work for
landfill developers can serve as independent reviewers of a proposed landfill, advising regulatory
agencies, county boards, etc., on the potential impacts of a particular landfill. Lee and Jones-Lee
(2006c) have discussed this situation, pointing out that it is extremely difficult if not
impossible for consulting firms or individuals that normally support the development of
landfills to perform true, independent assessments of landfills, since such reviews could
readily lead to their not being able to gain future contracts with landfill developers.
Developing Protective Landfills
Lee and Jones-Lee (2013) have developed a comprehensive review of the approach that can
be followed to develop MSW landfills that will be protective of public health and the
environment for as long as the wastes in the landfill will be a threat. There are a number of
approaches that members of the public potentially impacted by a landfill can work toward
achieving, which will improve the ability of landfills to provide containment of the wastes for
as long as the wastes in the landfill will be a threat. These are briefly summarized below.
Siting.
The landfill should be sited so that it provides, to the maximum extent possible, natural
protection of groundwaters when the liner system fails. Siting landfills above geological strata
that do not have readily monitorable flow paths for leachate-polluted groundwaters should be
avoided. Of particular concern are fractured rock/clay and cavernous limestone areas, as well
as areas with sandy lenses.
Design.
The landfill should be a double composite lined landfill, with a leak detection system
between the two liners.
Closure.
A leak detectable cover should be installed on the landfill which will indicate when
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the low-permeability layer of the landfill cover fails to prevent moisture from entering the
landfill.
Monitoring
.
The primary monitoring of liner leakage should be based on the double composite
liner, where the lower composite liner is the leak detection system for the upper composite
liner. If vertical monitoring wells are used, then the spacing between the vertical monitoring
wells at the point of compliance should be such that a leak in the HDPE liner caused by a 2-
ft-wide rip, tear or point of deterioration at any location in the landfill would be detected at the
point of compliance with a 95-percent reliability.
Landfill Gas Collection.
For those landfills that contain wastes that can produce landfill gas, a
landfill gas collection system should be designed, installed and maintained for as long as the
wastes in the landfill have the potential to generate landfill gas. The landfill gas collection
system should be designed to have at least a 95-percent probability of collecting all landfill gas
generated at the landfill. It is recommended that the gas collection system for a closed landfill be
operated under vacuum, including in the leachate collection and removal system, to reduce the
penetration of landfill gas through the liner system, which could lead to groundwater pollution.
Maintenance.
The maintenance of the landfill cover, monitoring system, gas collection
system, etc., should be conducted for as long as the wastes in the landfill will be a threat, with
a high degree of certainty of detecting landfill containment system and monitoring system
failure.
Funding.
The funding for closure, postclosure monitoring, maintenance and groundwater
remediation should be established at the time the landfill is developed, from disposal fees that are
deposited in a dedicated trust fund of sufficient magnitude to address plausible worst-case
scenario failures for as long as the wastes in the landfill will be a threat. Unless appropriately
demonstrated otherwise, it should be assumed that the period of time for which postclosure care
funding will be needed will be infinite.
Adoption of these approaches (or as many of them as possible) will significantly improve the
ability of landfills to protect groundwater quality, public health and the environment for as
long as the wastes in the landfill will be a threat.
Improving Public Health and Environmental Protection from Inadequately Developed
Landfills.
In those situations where a landfill will be developed that does not provide for full
public health, groundwater resource and environmental protection, such as a minimum design
Subtitle D landfill with a single composite liner, the following approach should be
incorporated into the permitting of the landfill. In order to significantly improve public health,
groundwater and surface water quality protection, a landfill proponent should be required to:
•
Conduct sufficient additional hydrogeological investigations to be able to reliably predict
(under plausible worst case conditions - most protective) the pathways for adjacent property
groundwater pollution, when offsite groundwaters will likely be polluted and when surface
water springs and streams in the area of the landfills will be polluted by landfill leachate that
penetrates the landfill liners.
•
Establish a proactive, comprehensive offsite water quality monitoring program of all
offsite water supply wells, springs and surface water streams within several miles of the proposed
landfill, which will detect incipient groundwater and surface water pollution by landfill
73
leachate. This distance should be determined based on the hydrogeological conditions that exist
in the area of the proposed landfill.
MSW and other types of landfills will contain wastes that generate leachate that will be a
significant threat to pollute groundwaters and surface waters in the vicinity of the landfill. This
leachate will contain chemicals that can cause groundwater consumed by humans and animals
to be a health threat. In addition, leachate-polluted groundwater will contain chemicals that
will cause tastes and odors and make the leachate-polluted groundwater unusable for domestic
and many other purposes, including as a water supply for animals. Such pollution will cause
the well to have to be abandoned.
Landfills that are designed to meet the Subtitle D minimum requirement of a single composite
liner will ultimately allow leachate generated within the landfill to penetrate into the
groundwater system underlying the landfill. Typically associated with this type of landfill
are the highly unreliable groundwater monitoring systems that are allowed by regulatory
agencies, involving vertical monitoring wells spaced hundreds to thousands of feet apart at the
point of compliance for groundwater monitoring. The hydrogeology of the groundwaters
underlying many proposed landfills is complex, with sand layers and fractured rock/clay. The
groundwater under such landfills will carry leachate-polluted groundwater that develops under
the landfill to groundwaters that underlie adjacent properties and, at some landfill locations, to
surface waters. At some time in the future, the groundwaters under adjacent properties will
be polluted by chemicals in the landfill leachate. This will render the offsite groundwater a
health threat and unusable for domestic and many purposes. Surface waters polluted by
polluted groundwaters will be a threat to domestic water supplies and to aquatic life.
Need for Improved Hydrogeological Characterization
.
The complex hydrogeology
underlying and in the area of many proposed landfills makes the transport of leachate-polluted
groundwater to offsite areas difficult to assess/monitor. Typically the degree of
characterization of the geological strata underlying a proposed landfill is inadequate to
predict potential pathways and the rate of movement of leachate-polluted groundwater that
will occur under the landfill to offsite areas. As part of providing an appropriate degree of
offsite groundwater resource and public health protection, it is reasonable to require that a
landfill proponent be required to characterize the hydrogeology of the landfill’s area
sufficiently well so that reliable estimates of the direction, rate and degree of pollution of
adjacent and nearby properties’ groundwaters can be made once the liner system has failed to
collect all the leachate generated in the landfill. This information is essential to developing an
appropriate groundwater monitoring system to detect when the leachate-polluted groundwater
first reaches the point of compliance for groundwater monitoring down groundwater gradient
from the landfill.
S. Hubbard (2006) senior scientist at the Lawrence Berkeley National Laboratory presentation,
"Toward X-Ray Vision: Geophysical Signatures of Complex Subsurface Processes" provides
information on the kind of studies that are needed to adequately characterize the hydrogeology
of landfill and hazardous chemical sites. Information on this presentation is available at,
http://esd.lbl.gov/about/staff/susanhubbard/2010_birdsall_dreiss.html. Her report covering this
presentation is available as Hubbard and Rubin (2006). And other papers/reports at,
http://esd.lbl.gov/about/staff/susanhubbard/publications.html
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The landfill permitting agency(s), as part of consideration of permitting a landfill, should
require that a comprehensive hydrogeological investigation be conducted at the landfill site so
that there is a reasonable degree of scientific certainty in predicting the potential pathways
by which leachate-polluted groundwaters that occur at any location under the landfill liner
can trespass under adjacent properties.
The hydrogeological investigation should also provide a plausible worst-case estimate of the
concentrations of selected leachate chemicals that could occur at adjacent property lines and
how fast leachate-polluted groundwater would reach the adjacent property lines when the liner
system fails to collect all leachate generated in the landfill. Requiring this degree of
hydrogeological characterization is in accord with most landfill permitting agencies’
mission of public health and groundwater resource protection.
A proposed landfill should not be permitted until the additional hydrogeological information
is made available and independently reviewed for its technical adequacy and reliability. This
information on the
•
pathways for leachate-polluted groundwaters to move from under the landfill to
offsite properties,
•
when pollution of offsite groundwaters is expected to occur, and
•
the potential concentrations that will occur under adjacent properties of various types of
pollutants that are present in the expected leachate is needed to determine whether a
proposed landfill should be permitted. If it is permitted, then with this information
the potentially impacted public, regulatory agencies and others would have a better
understanding of the threat that the landfill represents to the groundwater resources
under their property and the surface water resources of the area.
Subtitle D Landfills in Other Countries
Following the adoption of the Subtitle D regulations by the US EPA in 1992 several other
countries have adopted landfilling regulations patterned after the Subtitle D regulations where
a single composite liner is allowed in MSW landfills. Lee (2002b, 2011c) has discussed why
this should not be done based on the long term failure of this landfill liner system to prevent
groundwater pollution as well as the unreliability of the detection of landfill leachate pollution
of groundwater by monitoring wells spaced a hundred or so feet apart at the point of
compliance for groundwater monitoring. Lee and Jones-Lee on their website,
www.gfredlee.com in the Examples of Specific Landfill Studies section at,
http://www.gfredlee.com/plandfil2.htm#examples have presented their reports on these
situations. As an example of inappropriate MSW landfilling Lee (2009a,b) they have
reviewed the potential impact of a proposed MSW landfill in Thorhild County Alberta,
Canada. They found that this landfill, if permitted, would be a significant threat the domestic
and animal water supply and to aquatic life in surface waters of the area of the landfill.
Lee and Jones-Lee (2009f) have conducted a review of the Environment Alberta, Canada
proposed revised landfilling regulations. These proposed regulations are highly deficient in
developing landfills that will be protective of public health, ground and surface water sources,
and the interests of those in the sphere of influence of the landfill. They reported that the
major deficiencies as presented in the following summary.
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Comments on Environment Alberta July 1, 2009 Draft Standards for Landfills
The Canadian Province of Alberta proposed to update its landfilling regulations. Lee and
Jones-Lee (2009f) commented on the deficiencies in the proposed regulations as follows.
•
25 year Post-closure period is grossly inadequate to protect public health, groundwater
and surface water quality and the interests of those in the sphere of influence of the
landfill.
•
Leachate composition not reliable to determine duration of post-closure period for
landfill monitoring and maintenance. Draft regulations should specify that the post-
closure period for landfill shall be for as long as the waste in the landfill can potentially
generate leachate that can pollute groundwater or surface waters.
•
Clay liners and natural clay deposits specified in draft regulations not protective of
groundwater quality for as long as the wastes in the landfill can generate leachate.
The specified clay deposits and packed clay liners only delay when groundwater
pollution occurs, they do not prevent.
•
Groundwater monitoring wells spaced up to 200 metres apart at the compliance
boundary will have a low probability of detecting leachate polluted groundwater when
it first reaches the compliance boundary. Should use double composite liner with leak
detection layer between the composite liners. When leachate found in the leak detection
layer the landfill cover needs to be improved to stop leachate from entering the leak
detection layer.
•
30 metres of buffer land between the landfill waste footprint and adjacent property lines
is grossly inadequate to prevent trespass of waste derived materials and landfill gas
including odors on to adjacent properties. This highly limited amount of buffer land will
be a health threat to those who own/use adjacent and nearby properties. At least a mile
(several kilometers) of buffer land should exist between where the wastes are deposited
and adjacent property lines.
•
Landfill gas subsurface migration should recognize that subsurface landfill gas
migration can be a significant cause of groundwater pollution including up groundwater
flow direction from the landfill.
•
Surface water quality monitoring should continue for as long as the wastes in the landfill
can generate leachate when contacted by water to detect when seeps (breakout) leachate
occurs from the sides of the above the ground surface of the landfill.
•
The end of the Post-Closure Period report shall contain the detailed results of the studies
that were conducted to show that the wastes in the landfill no longer have the potential
to generate leachate when contacted by water.
In February 2010 Alberta released its updated landfilling regulation where essentially none
of the deficiencies listed above have been addressed. It is disappointing that a governmental
agency in a developed country would propose such obviously deficient updated landfill
regulation.
In 2012 the Alberta Environment approved the permitting of the proposed Thorhild Landfill
stating that the staff found that the proposed landfill complied with the minimum Alberta
Landfill standards. This situation caused the Concerned Citizens of Thorhild County to file
an appeal of this approval with the Alberta Environmental Appeal Board. Lee and Jones-Lee
developed a review of the technical basis for the approval of the Thorhild Landfill permitting
where they developed a series of reports as Lee and Jones-Lee (2012 c,d,e, and 2013)
discussing the inadequate review of the potential impact of the proposed Thorhild Landfill on
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public health, groundwater and surface water quality and the impact of the proposed landfill
on the interests of those in the sphere of influence of the landfill.
Offsite Groundwater, Water Supply Well, and Surface Water Monitoring.
In addition to greatly improving the information on the hydrogeology of a proposed landfill
site and the surrounding area, there is need to require that the landfill owner establish
comprehensive offsite groundwater monitoring of all water supply wells within the sphere of
influence of the proposed landfill. This sphere should be considered to be several miles in any
direction from the landfills, dependent upon the hydrogeological conditions that exist in the
area. The purpose of this monitoring program would be to detect incipient pollution of existing
water supply wells located on nearby properties. This approach is justified as part of
providing improved public health and groundwater resource protection and assurance to the
potentially impacted public that the landfill has not yet polluted their groundwater. It would
provide a means of verifying the reliability of the predicted pollution of offsite groundwater.
In addition to the landfill compliance monitoring wells at the point of compliance for
groundwater monitoring, additional groundwater monitoring wells should be developed
along the most probable pathways for leachate-polluted groundwaters to move toward
offsite properties. If leachate-polluted groundwater is detected in any compliance
monitoring wells and/or the pathway monitoring wells, then the landfill owner should be
required to begin groundwater remediation, likely through pump and treat of the leachate-
polluted groundwaters. This remediation would be designed to stop further offsite movement
of leachate-polluted groundwaters. This is important because, as discussed by Rowe (1991),
MSW leachate-polluted aquifers can never be remediated to a sufficient extent to enable the use
of groundwater that has come in contact with the polluted but “remediated” part of the
aquifer to be a reliable, safe source of domestic and animal water supply.
This monitoring program should be conducted quarterly for a broad range of parameters until a
sufficient database has been developed so that the concentrations of the monitored
parameters can be reliably predicted for the next quarterly monitoring. After one year of
reliably predicting the results of the quarterly monitoring, the frequency of monitoring of
offsite potentially impacted wells can be reduced to semiannually.
In order to protect surface water quality from pollution by landfill leachate, comprehensive
monitoring of all springs and streams within several miles of the landfill should be required
for those hydrogeological situations where polluted groundwaters could discharge to surface
waters.
This monitoring would provide an early warning of pollution of surface waters by landfill
leachate. The pollution of surface waters can affect both domestic water supply water quality
as well as aquatic life-related beneficial uses of a waterbody. For many constituents, the
water quality criterion for protection of aquatic life is one or more orders of magnitude lower
than the drinking water MCL.
This monitoring program should be funded by the landfill owner but carried out by third-party
consultants that report the results to a Monitoring Committee consisting of the regulatory
agencies, property owners and the landfill owner. This monitoring program should be conducted
forever – i.e., as long as the landfill has the potential to generate leachate that can pollute
77
groundwaters underlying the landfill.
The offsite well monitoring would be for all existing and any new water supply wells that are
developed in the future. This approach is justified since those who own properties adjacent
to and near the landfill are entitled to continuing to have groundwaters under their property that
are free of landfill leachate.
Monitoring of the characteristics of the leachate generated in a landfill should include a broad
range of potential pollutants that can be expected to be generated based on the characteristics
of the wastes accepted at the landfill. The monitoring of groundwaters and surface waters
should include a broad range of potential pollutants and potential transformation products.
An expert panel would advise the Monitoring Committee on the parameters that should be
included in the monitoring. The required monitoring parameters should be reviewed each year
by the panel to determine if there are any new potential pollutants that should be added to the
list of parameters.
Lee and Jones-Lee (2006c) have provided guidance to public groups and agencies on issues
that need to be considered in selection of an independent consultant to assist in evaluation of
the potential impacts of a proposed landfill. The key to this selection is to find someone
knowledgeable on landfill containment/pollution issues who has not and does not expect to
work for landfill developers. As they discuss those who work for landfill developers cannot
expect to do further work on behalf of landfill developers if they discuss the full potential
impacts of a proposed landfill. Lee and Jones-Lee (2007d) have provided guidance on the issues
that typically need to be considered in evaluating the potential impacts of proposed landfill and
landfill expansions that conform to Subtitle D regulations. Lee and Jones-Lee (2005c) have
developed a summary of issues on developing Municipal Solid Waste Landfills – Water
Quality Issues, in the: Water Encyclopedia:
Hazardous Waste Landfilling
RCRA distinguishes between hazardous and nonhazardous wastes. As discussed above, the
distinction between the two types of wastes is somewhat arbitrary and certainly does not prevent
hazardous chemicals from being deposited in so-called nonhazardous waste (Subtitle D)
landfills. The US EPA has developed regulations for landfilling of hazardous wastes in
Subtitle C landfills. This type of landfill involves a double composite lined system for
waste containment. Further, the US EPA requires some pretreatment of some of the hazardous
waste components that are placed in Subtitle C landfills, to reduce their mobility. This
pretreatment, however, does not prevent the development of leachate associated with water
percolating through the landfilled wastes, which can enter the underlying groundwaters as
the Subtitle C landfill liner system deteriorates.
Lee and Jones-Lee (2009g) have conducted a review of the potential hazards of developing
a Toxic Substances Control Act (TSCA Chemical Waste Unit landfill for disposal of
wastes solids that contain PCBs to the domestic groundwater supply for Dewitt County,
Illinois. They reported that the proposed landfill which is supported by the US EPA Region
5 staff has provided unreliable information on the ability of TSCA PCB landfill to prevent
groundwater pollution by PCBs.
Lee (2006j) has provided a comprehensive discussion of the potential problems associated
78
with the Peoria Disposal Company’s existing and proposed expansion of a Subtitle C hazardous
waste landfill located near Peoria, Illinois. As discussed, Subtitle C landfills have essentially
the same problems as Subtitle D landfills, of ultimate failure of the landfill liner and cover
systems while the wastes in the landfill are still a threat to generate leachate upon contact with
water. There is, however, a potential advantage of Subtitle C landfills, as well as Subtitle D
landfills that are constructed with a double composite liner system, in that, when leachate is
detected in the leak detection zone between the two composite liners, it is known that the upper
composite liner has failed or is failing, and it is only a matter of time before the lower composite
liner also fails, if it has not already done so.
As discussed above, when leachate is detected in the leak detection zone between the two
composite liners in either a Subtitle C or a double composite lined Subtitle D landfill, there is
need to stop leachate production through repairing the low-permeability plastic sheeting layer
in the landfill cover. To address the chronic problem of periodic failure of the plastic sheeting
layer in the cover which could lead to groundwater pollution, it is recommended that a leak
detectable cover be installed on all double composite lined landfills prior to or at the time when
leachate is detected in the leak detection system between the two composite liners.
This approach requires that adequate postclosure funding be available, throughout the period
that the wastes in a Subtitle C or D landfill are a threat, to install and operate the leak
detectable cover. Leak detectable covers can and should also be installed on all Subtitle D
landfills when it becomes obvious that the landfill cover system is no longer preventing
leachate generation caused by moisture penetrating through the cover into the wastes. This
approach, however, requires that the leachate collection system continue to be operated and
maintained throughout the essentially infinite period of time that the wastes in the landfill
are a threat to generate leachate upon contact with water.
Peoria County, Illinois proposed a new MSW landfill that is to be located in an area of former
coal mining. Lee (2011c) has provided detailed comments on the potential public health and
environmental problems with this landfill.
Addressing the Flawed Technology of Subtitle D Landfilling
The potential problems with dry tomb type landfilling were noted at the time that this approach
was first proposed in the early 1980s. At that time the authors had just completed research on
behalf of the US EPA National Groundwater Research Program located at Ada, Oklahoma,
devoted to factors influencing the ability of compacted clay liners for landfills to prevent
groundwater pollution. The authors were involved in the review of a proposed hazardous waste
landfill located in eastern Colorado. They also were involved in reviewing several other
hazardous waste and municipal waste landfills in other parts of the country. Based on their
research and the proposed landfills that were being developed at that time with compacted clay
liners, Lee and Jones (1984) developed a review paper, “Is Hazardous Waste Disposal in Clay
Vaults Safe?” that was published in the Journal of the American Water Works Association.
Subsequently the Water Resources Division of the AWWA judged this paper as the best paper
published in the Journal during 1984. The thrust of this paper was that the attempt to isolate
solid wastes in dry tomb type landfills was doomed to ultimate failure.
As it stands now, the current regulatory approaches allowed by the US EPA and states can at best
provide for protection of public health and the environment from hazardous and deleterious
79
components of municipal and industrial wastes for a relatively short period of time compared
to the time that the landfilled waste components will be a threat. Unfortunately, the early
warnings on the flawed technology of dry tomb landfilling were ignored with the result that
the US is building up a massive legacy of municipal landfills that will become “Superfund”
sites. There is need to rewrite Subtitle D so that truly protective landfills can be developed
that will protect public health, groundwater resources and the environment for as long as the
wastes in the landfill will be a threat.
As discussed by Lee (2010e) in correspondence with L. Jackson current US EPA
Administrator there is an urgent need for the U.S. (as well as other countries) to begin to
manage non- recyclable municipal and industrial solid wastes, construction and demolition
wastes and hazardous wastes in landfills that are sited, designed, operated, maintained and
closed, with adequate postclosure care/funding for as long as the wastes are a threat, where
the generators of the wastes are required to pay the full cost of appropriate waste management
and thereby stop the current practice of passing a substantial part of the costs on to those who are
within the sphere of influence of a landfill as well as future generations. There is obvious need
for a major overhaul of Subtitle D MSW landfilling to abandon dry tomb landfilling in favor
of increased practice of the three Rs and development of landfills that can be used to treat the
non-recyclable MSW to produce non-polluting residues.
Fermentation Leaching of MSW (Bioreactor Landfills)
There is growing recognition that rather than trying to keep the wastes dry forever, the landfill
should become a reactor system where the components in the solid wastes can be treated while
the liner system still maintains its integrity. This has led to what are called “bioreactor”
landfills where moisture (recycled leachate) is added to the landfill to enhance landfill gas
production and to leach the leachable components of the wastes. However, as discussed by
Jones-Lee and Lee (2000, 2010c), many of the so-called bioreactor landfills that are being
developed today that are occurring in minimum design Subtitle D landfills with a single
composite liner tend to increase the potential for groundwater pollution by the leachate
generated in the landfill. Jones-Lee and Lee (2000) and Lee and Jones-Lee (1993c) have
discussed how landfills can be developed that will treat municipal solid wastes to produce a non-
polluting residue and protect groundwaters from pollution during the treatment. Unfortunately,
O’Brien (2010) Solid Waste Association of North America has published a review of current
bioreactor landfill technology that fails to address many of the key long term issues that need
to be addressed in evaluating/developing bioreactor landfills that will produce stabilized wastes
that are not threat to pollute groundwater and generate landfill gas. The deficiencies in the
O’Brien review are discussed by Lee and Jones-Lee (2010c).
They describe a fermentation leaching approach where shredded wastes are placed in a double
composite lined landfill with a leak detection system between the two composite liners.
Shredding the wastes before they are placed in the landfill eliminates the impact of plastic-
bagged garbage hiding wastes from added moisture, and provides for a more even flow of
moisture through the wastes for promoting fermentation and leaching. As part of
implementing this approach, there is need to develop a plumbing header system to distribute
the recycled leachate over the wastes, providing for fairly even distribution of the recycled
leachate through the shredded wastes.
When the production rate of landfill gas slows, leachate recycle should be terminated, and a
80
clean-water rinsing of the residual, non-fermentable waste components should occur (where no
recycle is practiced), and the collected rinse water is treated, presumably at a POTW. The
addition of clean water to the landfill will leach soluble and mobile components from the wastes
that could otherwise, at some time in the future, lead to groundwater pollution when the liner
system is no longer effective in collecting leachate.
As with all MSW landfilling, a dedicated trust should be established that is of sufficient
magnitude to address all plausible worst-case-scenario failures that can occur for as long as the
wastes in the landfill are a threat. For this approach, this would likely be for five to ten years
after the rinse water collected in the leachate collection system shows little or no potential to
pollute groundwater. As discussed above, without following the fermentation leaching
approach, the period that the wastes will be a threat is, effectively, forever. The fermentation
leaching approach that Lee and Jones-Lee advocate provides an opportunity to effectively treat
the wastes while the liner systems are likely to retain their integrity, and thereby shorten the
period that the landfill is a threat to cause groundwater pollution.
Reinhart et al.(2012) have discussed the potential role of modern landfills can have in waste
management where they review several of the issues that need to be considered in
improving the landfilling of MSW.
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of their investigations into issues pertinent to evaluating potential impacts of proposed and
existing municipal landfills, as well as review papers/reports that Lee and/or Lee and Jones-Lee
have developed on a particular aspect of evaluating landfill impacts. The Lee, and Lee and
Jones-Lee review papers/reviews contain references to peer-reviewed literature that serves as a
technical basis for their synthesis of the professional literature on the topic discussed.
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Lee, G. F., “Improving Public Health and Environmental Protection from the Proposed Morrow
County C&DD Landfills,” Report of G. Fred Lee & Associates, El Macero, CA, February 14
(2006f). http://www.gfredlee.com/Landfills/CDD-LF-Improvement.pdf
Lee, G. F., “Summary of Findings on the Environmental Impacts of the Proposed C&D
Landfill on top of the Closed Gentilly Landfill,” Submitted to Louisiana Department of
Environmental Quality, Baton Rouge, LA, February (2006g).
http://www.gfredlee.com/Landfills/FindingsGentilly.pdf
Lee, G. F., “Comments on ‘Potential Impact by the Old Gentilly Landfill on the Environment
Due to the Placement of the New Type III C&D Landfill - Document Review,’ Prepared by
NISTAC, Dated February 8, 2006,” Report prepared by G. Fred Lee & Associates, El Macero,
CA, October (2006h). http://www.gfredlee.com/Landfills/FindingsGentilly.pdf
Lee, G. F., “Comments on the Louisiana Department of Environmental Quality’s ‘Decision for
Utilization of Gentilly Landfill “Type III” for the Disposal of Hurricane Generated Debris,’
Dated August 28, 2006,” Comments Submitted to Louisiana Department of Environmental
Quality by G. Fred Lee & Associates, El Macero, CA, October (2006i).
http://www.gfredlee.com/Landfills/LDEQ-Decision-comments.pdf
89
Lee, G. F., “Comments on the Potential Impacts of the Peoria Disposal Company Landfill
Expansion on Public Health, Groundwater Quality and the Environment,” Submitted on behalf
of the Peoria Families Against Toxic Waste (PFATW) and the Heart of Illinois Sierra Club to
the Peoria County Board, Peoria, IL, March (2006j).
http://www.gfredlee.com/Landfills/PDCRpt-final.pdf
Lee, G. F., “Experience in Working with PCB Pollution Issues,” Report of G. Fred Lee &
Associates, El Macero, CA (2006h).
http://www.gfredlee.com/HazChemSites/PCBExperience.pdf
Lee, G. F., “Comments on Alternative Management Standards for Treated Wood Waste,”
Comments Submitted to Nicole Sotak, Chief, Environ. Analysis & Reg. Section, CA Dept. Toxic
Substances Control, Sacramento, CA, Report of G. Fred Lee & Associates, El Macero, CA,
January 8 (2007). http://www.gfredlee.com/Landfills/CDD-LF-Improvement.pdf
Lee, G. F., "Summary of Comments on Waste Management’s Thorhild Landfill Re-Zoning
Application Binder," PowerPoint Slide Presentation to Thorhild County Council, Alberta,
CAN, April 24 (2009a). http://www.gfredlee.com/Landfills/Thorhild-Powerpoint.pdf
Lee, G. F., “Comments on Waste Management’s Thorhild Landfill Re-Zoning Application
Binder Dated February 2009,” Report to Concerned Citizens of Thorhild County, Alberta,
CAN, submitted by G. Fred Lee & Associates, El Macero, CA, April 24 (2009b).
http://www.gfredlee.com/Landfills/CommentsWMThorhildLF.pdf
Lee, G. F., “Comments on ‘Imperial County Planning and Development Services Agreement
for Conditional Use Permit (CUP) #07-0027 for a Class III (Non-Hazardous) Solid Waste
Landfill (Imperial Landfill), Conditional Use Permit #07-0027, Planning & Development
Services Department (07/30/10) (Final CUP)’,” Prepared for Robert McFarland for
submission to Imperial County, CA Board of Supervisors, Report of G. Fred Lee & Associates
El Macero, CA, August 17 (2010a).
http://www.gfredlee.com/Landfills/Comment-Allied-CUP.pdf
Lee, G. F., “Comments on the ICF Comments on the Dr. G. Fred Lee Report, ‘Review of the
Potential Adverse Impacts of the Proposed Expansion of the Allied Imperial Landfill,’
Submitted to Imperial County, CA Board of Supervisors Hearing on Permitting of the Allied
Imperial Landfill Proposed Expansion, Prepared for Robert McFarland for submission to
Imperial County, CA Board of Supervisors, Report of G. Fred Lee & Associates El Macero,
CA, August 15 (2010b). http://www.gfredlee.com/Landfills/Comment-ICF-Comm.pdf
Lee, G. F., “Review of the Potential Adverse Impacts of the Proposed Expansion of the Allied
Imperial Landfill,” Report for McFarland FLA, for presentation to Imperial County Board of
Supervisors at June 29, 2010 Board hearing on Allied Imperial Landfill expansion, G. Fred
Lee & Associates, El Macero, CA, June 24 (2010c).
http://www.gfredlee.com/Landfills/Allied_LF_exp_rpt.pdf
Lee, G. F., “Review of the Potential Adverse Impacts of the Proposed Expansion of the Allied
Imperial Landfill,” PowerPoint slides for presentation to Imperial County Board of
90
Supervisors at June 29, 2010 Board hearing on Allied Imperial Landfill expansion, G. Fred
Lee & Associates, El Macero, CA, June 24 (2010d).
http://www.gfredlee.com/Landfills/Allied_LF_exp_sli.pdf
Lee, G. F., Correspondence with US EPA L. Jackson & Office of Solid Waste & Emergency
Response (OSWER), and Response to SWSER Request for Comments Regarding
Deficiencies in Subtitle D MSW Landfilling, Comments of G. Fred Lee & Associates, El
Macero, CA, December-August (2010e).
http://www.gfredlee.com/Landfills/OSWER_Forum.pdf
Lee, G. F., "Issues of Managing Landfill Leachate: Comments on Waste Age Wire Article by
M. Fickes," Report of G. Fred Lee & Associates, El Macero, CA, June 29 (2011a).
http://www.gfredlee.com/Landfills/LFLeachateComFickes.pdf
Lee, G. F., “Controlling Nuisances at Landfills: Comment on Waste Age Wire Article by M.
Fickes,” Report of G. Fred Lee & Associates, El Macero, CA, June 27 (2011b).
http://www.gfredlee.com/Landfills/LFNuisancesComFickes.pdf
Lee, G. F., “Comments on Potential Public Health and Environmental Problems with Proposed
Peoria City-County Landfill No. 3,” Comments submitted to Peoria County, IL Siting
Committee on behalf of Heart of Illinois Group Sierra Club and Peoria Families Against Toxic
Waste,” G. Fred Lee & Associates, El Macero, CA, September 18 (2011c).
http://www.gfredlee.com/Landfills/PeoriaLF3.pdf
Lee, G. F., “Developing Protective Landfills,” Report of G. Fred Lee & Associates, El Macero, CA,
January 19 (2013). [16 kb]
http://www.gfredlee.com/Landfills/Sum_Developing_Protective_Landfills.pdf
Lee, G. F., and Jones-Lee, A., "Solid Waste Management: US EPA Lined-Landfill Approach
Not Reliable for Protecting Public Health and Environmental Quality," Prepared for the XI
International Congress on Solid Waste Disposal and Environmental Perspectives, Pereira,
Colombia, August 24-26, 2011, G. Fred Lee & Associates, El Macero, CA (2011c).
http://www.gfredlee.com/Landfills/Comblandfillsupdate.pdf
Lee, G. F. and Jones, R. A., “Is Hazardous Waste Disposal in Clay Vaults Safe?” J. American
Water Works Association 76:66-73 (1984).
Lee, G. F. and Jones, R.A., “Municipal Solid Waste Management: Long-Term Public Health and
Environmental Protection,” University of California, Davis, Landfills and Groundwater
Quality Short Course Materials, April (1991).
http://www.gfredlee.com/Landfills/MSWMANAGT.pdf
Lee, G. F. and Jones, R. A., “Municipal Solid Waste Management in Lined, ‘Dry Tomb’
Landfills: A Technologically Flawed Approach for Protection of Groundwater Quality,”
Report of G. Fred Lee & Associates, El Macero, CA, March (1992).
Available as LF008 from gfredlee@aol.com.
Lee, G. F. and Jones-Lee, A., “Municipal Landfill Post-Closure Care Funding: The 30-Year
91
Post-Closure Care Myth,” Report of G. Fred Lee & Associates, El Macero, CA, (1992).
http://www.gfredlee.com/Landfills/lfclos.htm
Lee, G. F., and Jones-Lee, A., “Groundwater Quality Monitoring at Lined Landfills:
Adequacy of Subtitle D Approaches,” Report of G. Fred Lee & Associates, El Macero, CA
(1993a). http://www.gfredlee.com/Groundwater/GW-MONITpaper93.pdf
Lee, G. F. and Jones-Lee, A., “Landfill Post-Closure Care: Can Owners Guarantee the Money
Will Be There?” Solid Waste and Power 7(4):35-39 (1993b).
http://www.gfredlee.com/Landfills/lffund.htm
Lee, G. F. and Jones-Lee, A., “Landfills and Groundwater Pollution Issues: ‘Dry Tomb’ vs F/L
Wet-Cell Landfills,” Proc. Sardinia ’93 IV International Landfill Symposium, Sardinia, Italy, pp.
1787-1796, October (1993c). Available as LF 036 from gfredlee@aol.com.
Lee, G. F. and Jones-Lee, A., “Landfilling of Solid & Hazardous Waste: Facing Long-Term
Liability,” In: Proc. of the 1994 Federal Environmental Restoration III & Waste Minimization II
Conference, Hazardous Materials Control Resources Institute, Rockville, MD, pp. 1610-1618,
April (1994a). Available as LF023 from gfredlee@aol.com.
Lee, G. F. and Jones-Lee, A., "Closed Landfill Cover Space Reuse: Park, Golf Course or a
Tomb?" Report of G. Fred Lee & Associates, El Macero, CA (1994b).
Available upon request as LF 025 from gfredlee@aol.com
Lee, G. F. and Jones-Lee, A., “Does Meeting Cleanup Standards Mean Protection of Public
Health and the Environment?” In: Superfund XV Conference Proc., Hazardous Materials Control
Resources Institute, Rockville, MD, pp. 53 1-540 (1994c).
http://www.gfredlee.com/HazChemSites/hmcrstd.htm
Lee, G. F. and Jones-Lee, A., “Addressing Justifiable NIMBY: A Prescription for Siting MSW
Landfills,” Environmental Management Review, Government Institutes Inc., Rockville, MD,
31:115-138, First Quarter (1994d). http://www.gfredlee.com/Landfills/funding.htm
Lee, G. F. and Jones-Lee, A., “Overview of Landfill Post Closure Issues,” Presented at American
Society of Civil Engineers Convention session devoted to “Landfill Closures - Environmental
Protection and Land Recovery,” San Diego, CA, October (1995a).
http://www.gfredlee.com/Landfills/asceco2a.htm
Lee, G. F. and Jones-Lee, A., “Practical Environmental Ethics: Is There an Obligation to Tell
the Whole Truth?” Published in condensed form “Environmental Ethics: The Whole Truth,”
Civil Engineering 65:6 (1995b). http://www.gfredlee.com/Landfills/ethics.htm
Lee, G. F. and Jones-Lee, A., “Landfill Leachate Management,” MSW Management 6:18-23
(1996).
Lee, G. F. and Jones-Lee, A., “Assessing the Potential of Minimum Subtitle D Lined Landfills to
Pollute: Alternative Landfilling Approaches,” Proc. of Air and Waste Management
Association 91
st
Annual Meeting, San Diego, CA, available on CD ROM as paper 98-
92
WA71.04(A46), 40pp, June (1998a). http://www.gfredlee.com/Landfills/alternative_lf.html
Lee, G. F. and Jones-Lee, A., “Deficiencies in Subtitle D Landfill Liner Failure and Groundwater
Pollution Monitoring, Presented at the NWQMC National Conference Monitoring: Critical
Foundations to Protect Our Waters, US Environmental Protection Agency, Washington,
D.C., July (1998b). http://www.gfredlee.com/Groundwater/nwqmcl.html
Lee, G. F. and Jones-Lee, A., “Detection of the Failure of Landfill Liner Systems,” Report of
G. Fred Lee & Associates, El Macero, CA, November (1999a).
http://www.gfredlee.com/Groundwater/lffail.htm
Lee, G. F. and Jones-Lee, A., “Unreliability of Predicting Landfill Gas Production Rates and
Duration for Closed Subtitle D MSW Landfills,” Report of G. Fred Lee & Associates, El
Macero, CA, September (1999b). http://www.gfredlee.com/Landfills/lf_gas_paper.pdf
Lee, G. F., and Jones-Lee, A., “Three Rs Managed Garbage Protects Groundwater Quality,”
Proc. AWMA 93rd annual conference, Salt Lake City, UT, paper 00-454 CD ROM, Air & Waste
Management Association, Pittsburgh, PA, June (2000).
http://www.gfredlee.com/Landfills/3rpap_sli.pdf
Lee, G. F. and Jones-Lee, A., “Occurrence of Public Health and Environmental Hazards and
Potential Remediation of Arsenic-Containing Soils, Sediments, Surface Water and Groundwater
at the Lava Cap Mine NPL Superfund Site in Nevada County, California,” In: Chappell, et al.,
Editors, Arsenic Exposure and Health Effects V, Elsevier B.V., Amsterdam, The Netherlands,
pp. 79-91 (2003).
http://www.gfredlee.com/HazChemSites/arsenic_07-2002.pdf
Lee, G. F. and Jones-Lee, A., “Overview of Subtitle D Landfill Design, Operation, Closure and
Postclosure Care Relative to Providing Public Health and Environmental Protection for as
Long as the Wastes in the Landfill will be a Threat,” Report of G. Fred Lee & Associates, El
Macero, CA (2004a). http://www.gfredlee.com/Landfills/LFoverviewMSW.pdf
Lee, G. F. and Jones-Lee, A., “Superfund Site Remediation by Landfilling - Overview of
Landfill Design, Operation, Closure and Postclosure Care Issues,” Remediation 14(3):65-91,
Summer (2004b). http://www.gfredlee.com/Landfills/LFoverviewRemediation.pdf
Lee, G. F. and Jones-Lee, A., “Evaluation of the Potential Water Quality Impacts of Dust
Suppressants,” Report prepared for Expert Panel on the Potential Environmental Impacts of Dust
Suppressants, organized by the University of Nevada, Las Vegas, Department of Civil
Engineering, January (2004c).
http://www.gfredlee.com/HazChemSites/dust-suppress-guidance.pdf
Lee, G. F. and Jones-Lee, A., Comments on Michael Caldwell’s Presentation, “Performance-
Based System for Post-Closure Care at MSW Landfills” to the CA IWMB Landfill Financial
Assurance Workshop, Sacramento, CA December 6, 2004,” Comments Submitted to CIWMB
by G. Fred Lee & Associates, El Macero, CA, December (2004d).
http://www.gfredlee.com/Landfills/CaldwellPerformBasedLF.pdf
93
Lee, G. F. and Jones-Lee, A., “Justification for Opposition by Residents of Mobile, Arizona,
to the Siting of an Additional Landfill in Mobile,” Comments submitted to H. Shanker, Attorney,
Phoenix, AZ, June (2004e).
http://www.gfredlee.com/Landfills/MobileAZ-com6-29-04.pdf
Lee, G. F., and Jones-Lee, A., “Disposal of Contaminated Sediments/Soils in MSW Landfills:
Need to Consider the True Cost,” Journal Remediation 15(3):95-101 (2005a).
http://www.gfredlee.com/Landfills/LF-DredgedSed.pdf
Lee, G. F., and Jones-Lee, A., “Unrecognized Environmental Pollutants,” In: Water
Encyclopedia: Surface and Agricultural Water, Wiley, Hoboken, NJ, pp 37 1-373 (2005b).
http://www.gfredlee.com/SurfaceWQ/WileyUnrecognizedPollutants.pdf
Lee, G. F., and Jones-Lee, A., “Municipal Solid Waste Landfills – Water Quality Issues,” IN: Water
Encyclopedia: Water Quality and Resource Development, Wiley, Hoboken, NJ pp 163-169
(2005c). http://www.gfredlee.com/Landfills/WileyLandfills.pdf
Lee, G. F. and Jones-Lee, A., “Progress toward Remediation of the Sydney Tar Ponds: A Major
Canadian PCB/PAH ‘Superfund’ Site,” Journal Remediation 17(1):111-119 (2006a).
http://www.gfredlee.com/Landfills/STP-Remediation-pap.pdf
Lee, G. F. and Jones-Lee, A., “Selection of an Independent Consultant to Review the Potential
Impacts of a Proposed Landfill,” Report of G. Fred Lee & Associates, El Macero, CA, December
(2006c). http://www.gfredlee.com/Landfills/SelectIndepConsult.pdf
Lee, G. F. and Jones-Lee, A., "Groundwater Quality Protection Issues," Report of G. Fred
Lee & Associates, El Macero, CA, Presented in part at CA/NV AWWA Fall Conference,
Sacramento, CA, October (2007a).
http://www.gfredlee.com/Groundwater/GWProtectionIssues.pdf
Lee, G. F. and Jones-Lee, A., “Comments on the CIWMB Staff Efforts to Gain Assured
Postclosure Funding for Landfills for as Long as the Wastes in the Landfill Are a Threat to
Public Health and the Environment,” Comments Submitted to California Integrated Waste
Management Board by G. Fred Lee & Associates, El Macero, CA, January (2007b).
http://www.gfredlee.com/Landfills/CIWMBPostCloseFund.pdf
Lee, G. F. and Jones-Lee, A., “Association Between Hazardous Chemical Sites and Illness,”
Report of G. Fred Lee & Associates, El Macero, CA, January (2007c).
http://www.gfredlee.com/Landfills/HazChemSites-Illness.pdf
Lee, G. F., and Jones-Lee, A., “Guidance on the Evaluation of the Potential Impacts of a
Proposed Landfill,” Report of G. Fred Lee & Associates, El Macero, CA January (2007d).
http://www.gfredlee.com/Landfills/CoventryLF.pdf
Lee, G. F., and Jones-Lee, A., "Comments on the Potential for the Turkey Run Landfill to
Pollute Groundwater and Surface Waters in Violation of GA EPD Solid Waste Management
Rules and Landfill Permit," Report of G. Fred Lee & Associates, El Macero, CA, June (2008).
http://www.gfredlee.com/Landfills/TurkeyRunLFCom.pdf
94
Lee, G. F., and Jones-Lee, A., “Comments on ‘Assessment of the Performance of Engineered
Waste Containment Barriers’ Prepared by National Research Council Committee to Assess the
Performance of Engineered Barriers, National Academies Press, Washington, DC (2007),”
Report of G. Fred Lee & Associates El Macero, CA, September (2009a).
http://www.gfredlee.com/Landfills/NRC_EngrBarriers.pdf
Lee, G., F., and Jones-Lee, A., “Comments on O’Brien Editorial, ‘SWANA,’ Summarizing
SWANA ARF Disposal Group’s Report on the Long-Term Potential Problems of Subtitle D
Landfills,” Report of G. Fred Lee & Associates El Macero, CA, September (2009b).
http://www.gfredlee.com/Landfills/SWANA_ARF_rpt_comments.pdf
Lee, G. F., and Jones-Lee, A., “Monitoring Pollutants in Stormwater Runoff from Superfund Sites
and Other Locations,” Report of G. Fred Lee & Associates, El Macero, CA, November 5 (2009c).
http://www.gfredlee.com/HazChemSites/MonitorRunoffSuperfund.pdf
Lee, G.F., and Jones-Lee, A., "TCLP Not Reliable for Evaluation of Potential Public Health and
Environmental Hazards of Chemicals in Wastes: Unreliability of Cement-Based
Solidification/Stabilization of Wastes," Report of G. Fred Lee & Associates, El Macero, CA,
September (2009d). http://www.gfredlee.com/Landfills/TCLP_Solidification.pdf
Lee, G. F., and Jones-Lee, A., “Electronic Wastes and MSW Landfill Pollution of Groundwater,”
Report of G. Fred Lee & Associates, El Macero, CA, September (2009e).
http://www.gfredlee.com/Landfills/ElectronicWasteCom.pdf
Lee, G. F., and Jones-Lee, A., “Comments on Environment Alberta’s ‘Consultation Draft’ of
Standards for Landfills in Alberta,” Report of G. Fred Lee & Associates, El Macero, CA,
Submitted to Environment Alberta, Edmonton, Alberta, Canada, September (2009f).
http://www.gfredlee.com/Landfills/EnvAlbertaDraftLF.pdf
Lee, G. F., and Jones-Lee, A., “Evaluation of the Potential for Area Disposal Company Proposed
Chemical Waste Unit Landfill to Pollute the County Water Resources with Hazardous
Chemicals,” Report to County Board, DeWitt Co., IL. Report of G. Fred Lee & Associates, El
Macero, CA, May 7 (2009g).
http://www.gfredlee.com/Landfills/Clinton_IL_CWU.pdf
Lee, G. F., and Jones-Lee, A., “Comments on ‘Draft Supplemental Environmental Impact
Statement (DSEIS) proposed Campo Regional Landfill Project on the Campo Indian
Reservation in San Diego County, California,’ Dated February 26, 2010,” Report
submitted to Dale Risling, Acting Regional Director, Pacific Regional Office, Bureau of
Indian Affairs, Sacramento, CA, by G. Fred Lee & Associates, El Macero, CA, April 29
(2010a). http://www.gfredlee.com/Landfills/CampoLandfillDSEIS.pdf
Lee, G. F., and Jones-Lee, A., "Issues in Monitoring Hazardous Chemicals in Stormwater
Runoff/Discharges from Superfund and Other Hazardous Chemical Sites," Journ. Remediation
20(2):115-127 Spring (2010b)
http://www.gfredlee.com/HazChemSites/MonitoringHazChemSW.pdf
95
Lee, G. F., and Jones-Lee, A., “Mercury Pollution of Putah Creek Fish at the City of Davis
South Fork Preserve Area,” Report to DSCSOC by G. Fred Lee & Associates, El Macero,
CA, February 9 (2010c).
http://www.gfredlee.com/DSCSOC/2010/Davis_Preserve_Hg.pdf
Lee, G. F., and Jones-Lee, A., “Comments on the O’Brien 2009 ARF SWANA Article,
‘The Solid Waste Managers’ Guide to the Bioreactor Landfill–A 2009 Update,’ MSW
Management 20(3):14,16 May (2010b),’” Report of G. Fred Lee & Associates El Macero,
CA, Submitted to MSW Management, May (2010d).
http://www.gfredlee.com/Landfills/SWANABioreactorCom.pdf
Lee, G. F., and Jones-Lee, A., "Report on the Adequacy of the Investigation/Remediation of the
Brisbane Baylands UPC Property Contamination Relative to Development of That Property,"
PowerPoint Slides for Presentation prepared for Brisbane Baylands Community Advisory
Group (BBCAG), Brisbane, CA, November 1 (2010e).
http://www.gfredlee.com/Landfills/BrisbaneBaylandsSlides.pdf
Lee, G. F., and Jones-Lee, A., "Report on the Adequacy of the Investigation/Remediation of the
Brisbane Baylands UPC Property Contamination Relative to Development of That Property,"
Prepared for Brisbane Baylands Community Advisory Group (BBCAG), Brisbane, CA, Report
of G. Fred Lee & Associates, El Macero, CA, October 19 (2010f).
http://www.gfredlee.com/Landfills/BrisbaneBaylands.pdf
Lee, G. F., and Jones-Lee, A., “Issues in Providing Long Term Public Health and Environmental
Protection from Redeveloped Brownfield Properties,” Report of G. Fred Lee & Associates, El
Macero, CA, Nov. 1 (2010g).
http://www.gfredlee.com/HazChemSites/Brownfield-Issues.pdf
Lee, G. F., and Jones-Lee, A., “PCBs as Contaminants in Construction and Demolition
(C&D) Wastes,” Report of G. Fred Lee & Associates, El Macero, CA, December 5
(2010h). http://www.gfredlee.com/Landfills/CD-LandfillsPCB.pdf
Lee, G. F., and Jones-Lee, A., “Comments on SWANA News, ‘The Long-Term
Management and Care of Closed Subtitle D Landfills,’ MSW Management, pp. 12-18 May
(2011a),” Report of G. Fred Lee & Associates, El Macero, CA, May 10 (2011a).
http://www.gfredlee.com/Landfills/SWANA30yrpostclosureCom.pdf
Lee, G. F., and Jones-Lee, A., “Comments on the Deficiencies in the Development of the
Gregory Canyon Landfill,” Submitted to J. Henderson, San Diego County Dept.
Environmental Health, San Diego, CA, by G. Fred Lee & Associates, El Macero, CA,
February 16 (2011b).
http://www.gfredlee.com/Landfills/GregoryCanyonLF-Comments.pdf
Lee, G. F., and Jones-Lee, A., “Review of Potential Public Health & Groundwater Quality
Impacts of the Proposed Jungo Landfill,” Report to Humboldt, NV County
Commissioners, Winnemucca, NV, G. Fred Lee & Associates, El Macero, CA, December
5 (2011c).
http://www.gfredlee.com/Landfills/JungoLandfillNevada.pdf
96
Lee, G. F., and Jones-Lee, A., “Review of Potential Impacts of Landfills & Associated
Postclosure Cost Issues,” Report of G. Fred Lee & Associates, El Macero, CA, April
(2012a). http://www.gfredlee.com/Landfills/Postclosure_Cost_Issues.pdf
Lee, G. F., and Jones-Lee, A., “Checklist of MSW Landfill Groundwater and
Environmental Protection Issues,” Report of G. Fred Lee & Associates, El Macero, CA,
April (2012b). http://www.gfredlee.com/Landfills/Checklist_LF_Issues.pdf
Lee, G. F., and Jones-Lee, A., “Comments on Characteristics of Proposed Thorhild Landfill
with Respect to Providing Reliable Protection of Public Health & Environmental Quality for
as Long as the Wastes Remain a Threat,” Comments Prepared by G. Fred Lee & Associates,
El Macero, CA, October 13 (2012c).
http://www.gfredlee.com/Landfills/ThorhildLFAppealDocuments.pdf
Lee, G. F., and Jones-Lee, A., “Response to Waste Management’s November 2, 2012 Motion
to Alberta Environmental Appeals Board to Disallow Portions of Dr. Lee’s Report and Possible
Evidence at Hearing,” Comments Prepared by G. Fred Lee & Associates, El Macero, CA,
November 18 (2012d).
http://www.gfredlee.com/Landfills/Thorhild_Response_Nov2_Motion.pdf
Lee, G. F., and Jones-Lee, A., “Comments on Waste Management of Canada ESRD’s Expert
Rebuttal Dated November 14, 2012,” Comments Prepared by G. Fred Lee & Associates, El
Macero, CA, December 24 (2012e).
http://www.gfredlee.com/Landfills/WM_Chaw_Response_Comments.pdf
Lee, G. F., and Jones-Lee, A., “Review of Potential Impacts of Landfills & Associated
Postclosure Cost Issues,” Report of G. Fred Lee & Associates, El Macero, CA, April (2012f).
http://www.gfredlee.com/Landfills/Postclosure_Cost_Issues.pdf
Lee, G. F., and Jones-Lee, A., “Summary of Issues & Findings–Province of Alberta Finance
and Administration Division Regulatory Approvals Centre’s Approval of Thorhild Class II
Municipal/Industrial Landfill,” Presentation to Alberta Environmental Appeals Board,
Edmonton, Alberta, Canada, on behalf of Concerned Citizens of Thorhild County Society,
Alberta, Canada, by G. Fred Lee & Associates, El Macero, CA, January 14 (2013).
http://www.gfredlee.com/Landfills/Thorhild_LF_1_13HearingPpt.pdf
Lee, G. F. and Jones-Lee, “Guidance on Evaluating and Managing PCB Pollution of
Waterbodies,” www.gfredlee.com (2015).
Lee, G. F.; Jones-Lee, A. and Martin, F., “Landfill NIMBY and Systems Engineering: A
Paradigm for Urban Planning,” In: Systems Engineering: A Competitive Edge in a Changing
World, Proc. National Council on Systems Engineering Fourth Annual International
Symposium, pp. 991-998, August (1994). PowerPoint slides from this presentation available
at http://www.gfredlee.com/Landfills/NIMBY-NCO2.pdf
Mansour, R.I., “GCL performance in semiarid climate conditions. In Proceedings of Sardinia
’01: The Eighth International Waste Management and Landfilling Symposium, vol. 3, October
97
1- 5, Cagliari, Italy, Environmental Sanitary Engineering Centre, University of Cagliari, Italy,
pp. 219-226. (2001)
Marshack, J., “The Designated Level Methodology for Waste Classification and Cleanup Level
Determination,” Staff Report of the California Regional Water Quality Control Board, Central
Valley Region, Rancho Cordova, CA, October 1986, Updated June (1989).
http://www.waterboards.ca.gov/centralvalley/plans_policies/guidance/dlm.pdf
McDilda, D., "CCA Treated Wood: The End of the Line," MSW Management, Web Article
Editorial [http://www.mswmanagement.com/web-articles/cca-treated-wood-3.aspx], August
2 (2010). http://www.gfredlee.com/Landfills/CCA-TreatedWood-Mcdilda.pdf
McDonald, T. A., “The Risk Posed by the PBDEs, A Class of Flame Retardants,” In: 6
th
Bienniel
State of the Estuary Conference, “The San Francisco Bay-Delta Estuary: Changes and
Challenges,” San Francisco Estuary Project, Oakland, CA (2003).
Montgomery, R. J. and Parsons, L. J., “The Omega Hills Final Cover Test Plot Study: Three-
Year Data Summary,” Presented at Annual Meeting of National Solid Waste Management
Association, Washington, D.C. (1989), included as Appendix B in “Critical Factors in Soils
Design for Covers,” Presentation by Dr. David E. Daniel at “Seminars – Design and
Construction of RCRA/CERCLA Final Covers,” Technology Transfer CERI 90-50, US
Environmental Protection Agency, Washington, D.C. (1990).
Mulder, J. H., and Haven, E. L., “Solid Waste Assessment Test (SWAT) Program,” Report to the
Integrated Waste Management Board 96-1CWP, by Division of Clean Water Programs, Water
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