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Flawed Technology of Subtitle D Landfilling of Municipal Solid Waste
G. Fred Lee, PhD, PE, DEE and Anne Jones-Lee, PhD
G. Fred Lee & Associates
27298 E. El Macero Drive, El Macero, CA 95618
www.gfredlee.com
Updated March 2006
This report presents a review of the information available pertinent to public health and environmental quality protection issues for proposed Subtitle D landfills. Based on this review it is concluded that this type of landfill will at most locations cause groundwater pollution by landfill leachate and be adverse to the health, welfare and interests of nearby residents and property owners.
As discussed, there is normally significant justification for those near a proposed Subtitle D landfill to oppose the development of the 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 do 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 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 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.
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. 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.
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