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Home My WebLink About901355.tiff LAND DISPOSAL . 000 The Dinosaur Of Disposal Methods CONTRIBUTORS: STEPHEN U. LESTER BARBARA SULLIVAN PUBLISHED: APRIL 1986 COPIES AVAILABLE FROM THE CITIZENS CLEARINGHOUSE FOR HAZARDOUS WASTES. INC. FOR $8.98. MAKE CHECKS PAYABLE T0: CCHW POST OFFICE BOX 926 ARLINGTON. VIRGINIA 22216 CALL ( 703 ) 276-7070 DC 0564 ISNB-87-401671 S & ilicAL/ P*9c. TABLE OF CONTENTS I. Introduction 1 II. History 2 A. Current 4 III. The Indictment 6 A. Hazardous Waste Sites 11 B. Solid Waste Sites 13 IV. Myths 14 V. Hazardous Waste Landfills A. Design 18 B. The "Secure" Landfill 21 C. What Can Go Wrong's 23 D. What Can Be Done if a Failure Occurs' 27 E. What Defines Failure's 27 VI. Solid Waste Landfills A. Design 29 B. Do Municipal Landfills Really Pose A Threat's 33 C. What Can Go Wrong's 36 VII. Surface Impoundments A. Design 37 B. What Can Go Wrong's 38 VIII. Land Treatment A. Design 40 B. What Can Go Wrong's 43 IX. Regulations A. Hazardous Waste Landfills 45 1. Interim Status Groundwater Requirements 49 2. Closure and Post-Closure Requirements 51 3. Post-Closure Plan 51 4. Interim Status Financial Responsibility and Insurance Standards 52 5. Interim Status Standards For Landfills 52 6. Recent Changes in the Regulations 53 B. Solid Waste Landfills 55 C. Surface Impoundments 56 D. Land Treatment 58 X. Transport and Storage 59 XI. Alternatives 61 XII. Glossary 63 Appendix A - Participants List Appendix B - Resources SC564 Appendix C - Questions You May Want To Ask CDC') 11127,(C, I. INTRODUCTION Waste management technology is changing. Communities across the country are rejecting land disposal of chemical poisons and are demanding new approaches, not only for controlling newly produced toxic wastes, but also for cleaning up waste sites. In response to the need to better understand existing disposal options, CCHW began a series of five Roundtable Dialogue meetings designed to bring community people together with experts on different disposal methods to discuss the pros and cons of disposal methods. On June 13-14, 1985, CCHW held the third meeting in this series, on land disposal methods. The first two meetings addressed incineration and deep well injection. These Roundtables were made possible through the generous support of the North Shore Unitarian/Universalist Veatch Program and we're grateful for their support. CCHW launched this Roundtable series for two main reasons: • Though there is strong, clear and broad—based opposition to land disposal methods, there is a lack of information and thus a lack of consensus on the pros and cons, opportunities and pitfalls of different disposal alternatives. • While industry, government and environmentalists search for solutions, the general public and, more importantly, communities directly affected by hazardous waste problems, are often poorly informed and rarely included in these deliberations, even though they will be most profoundly affected by the outcome. These Roundtables reflect CCHW's philosophy that people most directly affected by problems have the greatest right to be part of the solution. CCHW's role is to provide both information and opportunities so that people can exercise that right. (l ,A)O4 Community leaders from 11 states, scientific and legal experts, government regulatory officials and environmental lobbyists met for two days to ernm;ne land disposal methods. The emphasis of the discussion (refected in this paper) was on the use of landfills, for both hazardous and municipal wastes, although surface impoundments and land treatment procedures were also examined. Deep well injection was not discussed since it was the subject of a separate Roundtable. Participants looked at the pros and cons of different disposal methods, discussed design considerations, applicable federal regulations and shared experiences, knowledge and resources about land disposal methods. II. HISTORY Land disposal of wastes began when Adam threw the apple away after taking the first bite. Since that time, wastes have been buried in landfills, piled on the surface, placed in surface impoundments and deep wells, spread over land, and dumped in streams, lakes and oceans. These activities have resulted serious contamination of the environment and dangerous threats to people's health. Landfills. A landfill is a depression in the ground where wastes - garbage and trash - are disposed of. If the trash and garbage are piled on top of each other, the site is called on "open dump." If the trash is covered to keep rodents, people and wind from dispersing the material, then the site is called a "sanitary or municipal landfill." If hazardous chemical wastes are disposed of, then the site is called an "industrial or chemical landfill." Landfills are one of the oldest waste disposal methods. Some of the earliest, formal landfills date from the late 1890's. They worked well when only biodegradable wastes were thrown away. Then the chemical revolution occured after World War II and chemical wastes like plastics, pesticides, organic solvents and petroleum products were generated. With disposal of these wastes, "leachate", a mixture of chemicals and rainwater, generated by the landfill became more toxic. Leachate mixes with groundwater, migrates 9CC564 -2- from the site and pollutes drinking water drawn from it. Landfills with chemical wastes also pose air pollution problems as volatile chemicals evaporate into the air. The discovery of contamination problems in the late 1960's brought about the first major changes in landfill design. New concepts were developed for site preparation and landfill liners. Some of these "lined landfills" also had a leachate collection system (pipes, holding tank and pump) . When leachate collects in the lowest part of the landfill ("leachate sump") , it's pumped to a waste water treatment plant so liquids can be separated from solids, further treated as necessary and discharged (after getting a permit) into a nearby waterway. Solids are usually returned to the landfill. If the liner leaks, leachate will escape and contaminate groundwater. It didn't take long for this to occur (some engineers still believe liners will contain chemical wastes) . So, in the mid-1970's, a new concept in landfill design emerged: "secure" or double—lined landfills. Here, two liners are separated from each other by 1-2 feet of sand or gravel. To boost popular appeal, they're also called "scientific" or more commonly "secure" landfills. Surface Impoundments. Surface impoundments are pits, ponds or lagoons of liquid wastes. Sometimes holes are dug and then filled with liquid wastes. Other times, natural depressions are used. Surface impoundments have been used since the late 1800's to store and dispose of liquid industrial wastes. In some cases impoundments were used because the wastes were considered too hazardous to discharge directly into waterways. More recently, it was simply cheaper or more convenient to use impoundments located on plant property. Sometimes, abandoned sand or gravel pits or rock quarries have been converted into impoundments. Land Treatment. Land treatment of wastes involves spreading wastes on the surface to diffuse and dilute waste components. SCOS 4 -3- CURRENT USE EPA estimated that in 1981 35% of all hazardous wastes were put in pits, ponds or lagoons, 57% in deep injection wells and 3% in landfills (See Figure 1, US EPA, 1984) . An estimated 100 billion gallons of liquid chemical wastes each year go into pits, ponds and lagoons, enough to fill an area 10 feet deep, 1 mile wide and 50 miles long. FIGURE 1. HOW ARE HAZARDOUS WASTvS DISPOSED Underground Injections 59% _ — Landfill 5% Surface Impoundment 35% — Other 1% (Source: USEPA, 1984) r'^ ? g1:CS VI -4- Hazardous Waste Landfills. Estimates vary on the number of landfills currently in use. EPA estimates there are only 407 operational hazardous waste landfills, based on an inventory of all storage, disposal and treatment facilities. Ninety—one (91) sites are fully permitted; the rest are "interim" status facilities (USEPA, 1985). Municipal Waste Landfills. EPA has also tallied 18,500 municipal or "sanitary" landfills (USEPA, 1984) while the Congressional Office of Technology Assessment (OTA) puts the number at around 60,000, including open and closed sites (OTA, 1985) . This difference likely reflects poor record keeping on small town dumps. Given that just about every community has some dump or landfill to put their wastes, OTA's estimate is probably closer to reality. Surface Impoundments. EPA estimates there are approximately 181,000 pits, ponds and lagoons on 80,000 sites (USEPA, 1983) in the following categories: Industrial 28,000 Municipal 37,000 Oil and Brine Wastes 65,000 Mining Wastes 25,000 Agricultural 19,000 Other 6,000 TOTAL 181,000 The paper, petroleum/coal, metals and chemical industries most commonly use impoundments. Land Treatment. Around 200 hazardous (NAS, 1983) and over 4000 "non—hazardous" land treatment waste systems (ASTSWMO, 1984) now exist in the U.S. Land treatment disposal occurs mostly in rural farming communities sometimes covering thousands of acres. 9C0561 1 -5_ III. THE INDICTMENT The failings of land disposal of hazardous wastes are well documented by disasters at Love Canal in Niagara Falls, NY, dioxin contamination in Times Beach, M0, Lowery Landfill in Denver, CO, Valley of the Drums in Brooks, KY, Stringfellow Acid Pits in Riverside, CA, and leukemic children in Woburn, MA, to name but a few. Most of these sites are landfills, some are surface impoundments and a few are deep wells. Table 1 shows a break out of the different land disposal methods found on the Superfund list (USEPA, 1985a) . The dismal performance of landfills has resulted in few government agencies at any level accepting landfills as a desireable option for hazardous waste disposal. Several states, in fact, have executive or legislative policies that restrict, ban or phase-out landfilling of hazardous wastes (CA, NY, FL, MS, NC and OH) . At the federal level, Congress passed legislation in November 1984 requiring EPA to phase out landfilling of hazardous wastes according to the following schedule: Date of Ban Wastes May 8, 1985 All liquid hazardous wastes November 8, 1985 All liquid non-hazardous wastes (in municipal landfills) November 8, 1986 Dioxins, solvents and other hazardous chemicals (see Table 2 for a complete list) July 8, 1987 California wastes (see Table 3) May 8, 1990 All remaining hazardous wastes. -6- 9CL56I _:B: - TYPES OF ACTIV17lES AT FINAL AND PROPOSED SUPERFUND SITES ORDERED BY TOTAL NATIONAL PRIORITY LIST (NPL) PREVIOUSLY ACTIVITY FINAL NPL PROPOSED* UPDATE 4 TOTAL NPL SURFACE IMPOUNDMENT 186 114 10 310 DRUMS 134 67 5 206 COMM/INDUST. LANDFILL 107 44 7 158 LANDFILL, NOS 120 27 3 150 OPEN DUMP 113 12 0 125 MUNICIPAL LANDFILL 82 30 8 120 TANK, ABOVE GROUND 67 29 4 100 PILES 55 40 3 98 OTHER MANUFACTURING 19 61 8 88 CHEMICAL MANUFACTURING 46 27 3 76 WELL FIELD 45 29 2 76 TRANSPORTER 50 21 0 71 TANK, BELOW GROUND 34 30 2 66 RECYCLING/RECOVERY 47 9 2 58 WOOD PRESERVING 28 17 2 47 WASTE OIL PROCESSING 32 6 1 39 INCINERATION 32 5 0 37 CHEMICAL/PHYSICAL TRT 33 4 0 37 MIDNIGHT DUMPING 32 2 0 34 MILITARY ORDINANCE 4 30 0 34 SOLVENT RECOVERY 25 6 0 31 SAND/GRAVEL PIT 15 11 2 28 FTYCTROPLATING 10 12 3 25 ORE PROCESSING/SMELTING 16 6 1 23 SPILL SITE 10 7 4 21 MINING SITE 13 6 1 20 * - UNCODABLE DATA 15 0 0 15 BATTERY RECYCLING 7 4 2 13 SURFACE WATII OUTFALL 3 6 2 11 OPEN BURNING 3 8 0 11 STORAGE, NOS 8 3 0 11 ROAD OILING Sill 7 2 0 9 WETLAND 3 4 1 8 FOUNDRY 6 0 1 7 LANDFARM 7 0 0 7 BIOLOGICAL TREATMENT 4 3 0 7 DRUM RECYCLING 4 3 0 7 SINK HOLE 3 1 1 5 LAUNDRY/DRY CLEANING 3 0 0 3 LABORATORY 2 0 0 2 UNDERGROUND FIRE 2 0 0 2 UNDERGROUND INJECTION ' 1 0 0 1 TANK WASHING 0 0 1 1 EXPLOSIVE DISPOSAL 0 1 0 1 TOTAL SITES: 541 271 38 850 * INCLUDES 25 PROPOSED UPDATE #3 SITES, 242 PROPOSED UPDATE #2 SITES,„ 4UP Ift PROPOSED i}PDATE #1 SITES (SOURCE: USEPA, 1985a). 5a` -7- / TABLE 2 WASTES BANNED FROM LANDFILLING California Wastes (By July 8, 1987) Liquid hazardous wastes with free cyanide > 1000 mg/liter (ppm) " Arsenic > 500 It It " " " Cadmium > 100 " " Chromium > 500 " It " Lead > 500 It It " Mercury > 20 Nickel > 134 " " Selenium > 100 It " Thallium > 130 " ,t It It pH <** 2.0 tt " PCB > 50 " Any hazardous waste with halogenated organics > 1000 " * Greater Than ** Less Than NOTE: All restrictions are subject to certain exemptions including review by the Administrator of EPA. TABLE 3 SOLVENTS BANNED FROM LANDFILLS F001* — Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1— trichloroethylene, methylene chloride, fluorocarbons; and sludges from the recovery of these solvents in degreasing operations. F002* — Tetrachloroethylene, methylene chloride, trichloroethylene, 1,1,1, trichorethane, chlorobenzene, 1,1,2—trichloro-1,2,2—trifluoroethane, orthodichlorobenzene, and trichlorofluoromethane; and the still bottoms from the recovery of these solvents. F003* — %ylene, acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, n—butyl alcohol, cyclohexanone, and methanol; and the still bottoms from the recover of these solvents. F004* — Cresols and cresylic acid, and nitrobenzene; and the still bottoms from the recovery of these solvents. F005* — Toluene, methyl ethyl ketone, carbon disulfide, isobutanol, and pyridine; and the still bottoms from the recovery of these solvents. 9C C 554 * Industry and EPA Hazardous Waste Number -8- Why this shift? Five reasons: (1) the growing number of horror stories that have come to public attention over the past 5 years, starting with Love Canal and on through the 850 dumps now on Superfund. (2) The growing research by such experts as Dr. Peter Montague, Princeton University, Drs. Kirk Brown and Dave Anderson, Texas A & M University and others showing failures of liners and landfills. Montague studied four state-of-the-art double-lined landfills and found all leaked within the first year of study (Montague, 1982) . Brown and Anderson found that some organic chemicals change the nature of clay and make it more "permeable," that is, less able to hold liquids and thus less useful as a liner (Anderson, 1982). This research led to EPA's decision not to require clay as a liner in landfills. Brown and Anderson also showed that synthetic liners will fail over time (Brown, 1986). (3) Similar research from different government agencies, including EPA. In 1983, OTA concluded that "landfills inhibit releases through containment but [they] eventually (and usually, gradually) leak and may contaminate groundwater (OTA, 1983)." When it proposed landfill regulations in 1981, EPA noted that "90% of the hazardous wastes annually generated in the U.S. can be disposed of safely without landfilling" (USEPA, 1981) . (4) A major study in 1983 by the National Academy of Sciences, the country's most prestigeous and conservative scientific organization, concluded: "Landfilling must be considered as the last alternative AFTER all waste treatment technologies including detoxification, volume reduction, resource recovery have been explored (emphasis added). . . In addition, the true costs of long—term secure landfilling, including monitoring and perpetual care insurance must be used in cost—effective comparisons. .. The short—term costs of this technology may be low, but the true costs to be incurred for perpetual care and monitoring for the period that, realistically, may exceed 500 years is signficantly greater and this cost should be used in comparison with other disposal options". (NAS, 1983) (5) Lastly is the recent track record of the "Cadillac of Landfills," the Waste Management site in Sumpter County near Emelle, Alabama. When first Or ifv-:51 —9— constructed in 1979, this site was touted as the perfect site, located in over 100 feet of "impermeable" clays and was guaranteed by Waste Management not to leak for at least 10,000 years. Given what scientists and engineers knew about the science of building and designing a landfill, these statements at first seemed reasonable. Unfortunately, they now appear unfounded, as an EPA staff memorandum indicates that Emelle is "in assessment" for groundwater contamination, meaning that the site is leaking (USEPA, 1985b). I£ the "Cadillac of Landfills" leaks, what hope is there for the Chevy and Fords? Other State—of—the—Art secure landfills that OTA reports to be leaking, . include the CECOS International Sites in Niagara Falls, NY and Williamsburg, OH, the BKK Site in West Covina, California, the Rollins Environmental Services Site in Baton Rouge, LA, the Wayne Landfill in Belleville, MI and the ESL Landfill in Joliet, IL (OTA, 1984) . When considering the 4 major landfill sites in the U.S. , only the SCA Services, Inc. landfill in Model City, NY is not known to be leaking. SCA refused to submit information requested under the Freedom of Inforamtion Act, stating the information was "confidential". Bill Sanjour at OTA (on temporary assignment from EPA) , who filed the FOI request, comments "I cannot think of any reason why a facility would make such a claim if it were not in assessment" (ie leaking) (OTA, 1984) . Despite the evidence, there are still some people, including very well—meaning people, who believe you can build a "secure" landfill, isolate waste from groundwater and reduce, if not eliminate, threats to groundwater in nearby communities. Landfills, municipal or hazardous, no matter how well engineered, are destined to fail. At best, engineering can only delay, but not stop, chemicals from leaking. It's not surprising, though, that some of the people who claim that "secure" landfills can be built and won't ever leak are, in fact, landfill operators. It's like an airplane builder whose planes are noted for crashing telling you, "Hey, I've got a new design, guaranteed to work." Would you fly in these planes? These factors plus strong citizen opposition are making land disposal and landfills, in particular, extinct. The following case histories illustrate the reasons why residents have consistently doubted and resisted -10- Si C'5:,4 land disposal methods. These examples come from the 850 Superfund sites, 50% of which are landfills and 36% of which are surface impoundments (see Table 1) . In addition, another 14% of Superfund sites are municipal landfills (US EPA, 1985a) . HAZARDOUS WASTE SITES • Stringfellow Acid Pits, Riverside CA: a licensed, off—site facility that operated from 1956-1972 consisting of evaporation ponds arranged like a series of steps. In 1969 and 1978, heavy rains filled the ponds, made waste spill over the barrier dam and spilled toxic wastes down the canyon and into town. Wastewater leaked from the ponds and under the berms around the ponds and concrete dam. The site has con— taminated groundwater and a toxic plume is moving toward the Chino Basin aquifer (Los Angeles' drinking water source) . Initial cleanup efforts completed in 1978 haven't stopped groundwater contamination. The site is now again being cleaned up at great expense to federal and state Superfunds. • Occidental Chemical Company's Lathrop, CA Site: from 1968 to 1979, thousands of gallons of pesticide waste was placed in unlined lagoons and percolated through extremely permeable soil, contaminating local water supplies. Contamination resulted from several factors: (1) the site was not in an environmentally secure area (2) no effort was made to line the site and (3) large amounts of toxic wastes were discharged. • Wilsonville, IL: a secure, state—of—the—art (at the time) landfill, permitted in 1976, leaked severely. Both U.S. and Illinois EPA prev- iously declared the site as one of the most secure in the nation. The site was closed by court order in 1981, when concentrations of halogenated organics as high as 369 were found in monitoring wells 9 feet from a trench where wastes were buried. • PJP Landfill, Jersey City, NJ: Covers nearly 80 acres bordering the Hackensack River. Much of the dump, now closed, is uncovered and fires 53C-356,12 -11- above and below ground had continuously burned for years. Volatile organics and other toxics have been detected in air, groundwater and run—off. The state has recently put out the fires and is negotiating current owners to define the nature and extent of the contamination. • Love Canal, Niagara Falls, NY: An abandoned canal, excavated in the 1890's for hydroelectric power, was used by Hooker Chemical to bury over 21,000 tons of toxic wastes. The site, covering 16 acres, was closed in 1952 and given to the school board which built a school on the site in 1953. A dense residential neighborhood was also built around the site. Odor and residue problems were first reported in the mid 60's and increased in the late 70's when heavy snow made the water table rise, bringing buried chemicals to the surface and pushing con— taminated groundwater into residents' basements. Between 1978 and 1980 N.Y. State and the Federal government spent $45 million on the site: $30 million to relocate residents and on health testing; $11 million for environmental studies and $4 million for a leachate collection and treatment system. • Industri—Plex, Woburn, MA: Between 1953 and 1981, Merrimac Chemical Co. and its successor, Monsanto Co. , made insecticides, explosives, acids, etc, on the site. In the late 1960's, much of the 250 acre site was acquired by the Mark Phillip Trust for industrial development. Excavation in the 1970's uncovered and mixed 130 years worth of indus— trial waste. Many pits, piles and lagoons continuously leak toxic metals. Area residents had complained about water contamination and unpleasant odors for at least 10 years. Woburn has a high cancer death rate (13%) and leukemia clusters in children were reported by the Centers for Disease Control. • Berlin & Farro, Swartz Creek, Flint, MI: Berlin and Farro Incineration, Inc.:, once a licensed disposal site for toxic wastes, was closed by health authorities in 1975. The firm repeatedly ignored orders to clean up the site and accepted wastes as late as 1979. State agencies spent nearly $900,000 on their own cleanup effots to empty most of the lagoons that once contained mysterious blue liquids and a thick, pink v C C33, �i�f.1 -12- slime. The site has an estimated 10,000 buried drums, 5 buried tanks containing 30,000 gallons of C-56 liquids (pesticide waste) and 4 lagoons with about 11,000 cubic yards of contaminated sludges. Traces of C-56, C-58, zinc, lead and cyanide were detected in ground water heading for nearby Swartz Creek, which flows into the Flint River and then into the Great Lakes. Ground penetrating radar shows illegally dumped barrels of hydrochloric acid may be at the bottom of the remaining lagoon. I£ these wastes mix with cyanide in the lagoon, a cloud of deadly hydrogen cyanide could form to endanger nearby resid— ents who would have just minutes to evacuate. • Lowry Landfill, Arapohoe County, CO: Covers 250 acres, 15 miles west of Denver. From 1967 to 1980, the landfill, owned and operated by the City and County, accepted both municipal and industrial waste, includ— ing an estimated 100 million gallons of liquid chemical waste like chlorinated solvents and oily wastes. These wastes were put in unlined trenches dug into the surface. Monitoring wells found volatile organic moved from the trenches into bedrock and shallow groundwater up to 1 mile from the site. SOLID WASTE SITES • Port Washington Landfill, Nassau County, NY: Also known as the Town • of North Hempstead L-4 Landfill, has been in operation since March, 1974. Before becoming a landfill, the site was a sand mine and is bor— dered by sand pits. In early 1981, Nassau County officials found methane gas migrating off—site and explosions occured in several nearby homes. Benzene, toluene, xylene and vinyl chloride were found in migrating gas. • Onalaska Municipal Landfill, Onalaska, WI: Within 500 feet of Black River, near the junction of the Mississippi, the landfill accepted residential, commercial, and industrial wastes. An estimated 2500 drums of solvent wastes were dumped there. The soil under this unlined site is highly permeable and groundwater appears to have risen into the waste thus carrying contaminating chemicals in groundwater from the site. • 19th Avenue Landfill, Phoenix, AZ: Abandoned sand and gravel pits on a 7—mile stretch of river were taken over by the city for a waste site. Municipal refuse and unknown amounts of industrial waste including heavy metals, solvents, and pesticides were dumped from 1954-1979. Parts of the landfill are within the 100—year floodplain of the Salt River. In early 1979, the river flooded, raised the water table and filled several pits. The high water also breached several dikes, allow— ing water to directly enter the site. Waste overflowed into the river. Local groundwater is badly contaminated and excess methane gas poses an explosion that threathens nearby residents. • Fulbright Landfill, Springfield, M0: Located on the floodplain of the Little Sac River near Springfield. From 1963-9, the city—owned site took household garbage and industrial wastes containing cyanides, acids, plating and paint sludges, solvents and pesticides. In 1967, a hauler died when he mistakenly dumped an acid drum into a pit with cyanide. • Laurel Park, Naugatuck, CT: The landfill covers 35 acres in sparsely populated Naugatuck Borough, New Haven County on top of Huntington Hill. Since the 1950's, the landfill has taken both industrial and municipal wastes. Only 8-12 acres of the site were permitted yet over 200 tons per day were dumped on the site. In the early 1960's, residents began to complain about odors, fires, spills and run—off. The maximum depth of the landfill is about 115 feet, yet bedrock is shallow and leachate is visible on slopes of the site. Leachate samples confirmed the presence of toxic organics and inorganics (metals). This site is Connecticut's top Superfund site and is still operating today. IV. MYTHS Roundtable participants discussed numerous arguments or "myths" often raised by land disposal supporters. These arguments and some responses are SOCK--•A 0 —14— given below. These myths apply equally to hazardous or municipal wastes; some counterarguments specifically addressed landfills, but the comment often applies equally to other land disposal methods. Myth: It's State—Of—The—Art Technology. Counterarguments: • This really means: "This is the best we can do now." It's not a good solution and there is no guarantee of safety. • "State-of-the-art" landfills have no track record, so what proof is there that they'll be any better? • That's what was said about the "double lined" landfill (See Section V. , Landfill Design and What Can Go Wrong) • Not good enough. • Is this the time to build more landfills? Isn't it better to use other safer alternatives first? Myth: The aquifer is already polluted, a little more won't hurt anything. Counterarguments: • As a society, we can't afford to "write of£" aquifers. • We want the aquifer cleaned up. • Let's not make it any worse; no reason to continue. • If we take that attitude on all contaminated aquifers, we're in deep trouble. kit 1t3 —15— • If people are drinking water from this aquifer, you've already got a sensitized population; don't make it worse. • We have a right to clean water for our children. • We have a moral responsibility to do something; if someone has cancer you don't just let the person die. You do something! Myth: Not Many People Will Be Affected. Counterarguments: • Maybe not directly, but rural aquifers are the drinking water source for many cities. • Animals, crops—food—for cities are raised on this water. • The lives of rural people are just as important as city dwellers. • Providing remedial, clean water to rural communities is expensive! • We didn't generate wastes, we don't want it (applies to waste brought in from another state or region) . • Environment should be protected, as well as people. Myth: So What Else Can We Do With These Wastes? What Are The Alternatives? Counterarguments: • Safe alternative .do exist (See Section %I, Alternatives) • We didn't generate the wastes, so we don't need to provide the alternatives. 9C C5611 5 11 -16- • We're smart enough to realize landfilling doesn't work. • Include tax on final products to cover costs of proper disposal, re— covery and recycling. If costs become too high, let free market re— flect this. It's o.k. if some products die, rather than people. Stop making "ridiculous" products that produce toxic wastes. Myth: If You Shut Down The Dump, We Have To Close And Take Our Jobs Elsewhere, Counterarguments: • Jobs aren't lost permanently, they change. • Landfilling isn't labor intensive. • Wherever company goes, workers are still needed; skilled workers may be transferred to new locations. • Plants can change practices, sometimes with large savings; industrial revenue bonds are available to help reduce costs. • Most threats are just bluffs. • Jobs aren't worth cost of sick children. Myth: You're Politically Motivated. Counterarguments: • Right, but so what? These decisions are mainly motivated by politics. • If government and industry handled waste responsibly, residents wouldn't have to get upset. -17- • Political participation, especially on decisions that affect people's lives, is a basic American right. • Decisions are made by politicians, not scientists or engineers. Myth: We're The Experts, Not You, We Know What We're Doing. Counterarguments: • We know how to read too, we have common sense. Who are the real ex— erts, anyway? Ex erts gain the expertise gradually. Few have an P P S P S Y• y real answers; most make mistakes. • People who live there know the land. • Experts disagree because science/engineering are so uncertain; so what do the experts really know? • We've proven we know our stuff: we're experts too — experts on our community! V. HAZARDOUS WASTE LANDFILLS DESIGN Hazardous waste landfills are supposed to minimize the production of liquids and control the movement of leachate. Landfills have 4 key parts: a bottom liner, a leachate collection system, a cover or cap and the natural -18- hydrogeolgic setting. The first three factors are engineered; the fourth is part of a selection process. Figure 2 shows a typical landfill. FIGURE 2. Hazardous Waste Landfill Pervious Laryw ar . Low Pooscoon an0 Loons COOSCawr llaabb Colocuon woman Wow b TennwN covw Lay« i Wawa Malawi / L.aduM tt Subyrade a UnderOrmo System Water Tattle • The Bottom Liner slows down leachate migration into sail and ground water by using material with low permeability (e.g. compacted clay, plastics like polyvinyl chloride or Dupont's Hypalon - a trade name.) . Plastic liners have permeability ranges of 10-11 to 10-14 cm/sec (that's "centimeters per second"). This is the measurement of how long it will take for water to pass through the liner. EPA requires a permeability of 10-7 for liners which usually range from 20-100 mils (thousandth of an inch) thick. Typical household plastic bags are 1.3 mils thick. Clay liners range in thickness from 12" to several feet with permeabilities of 10-7 to 10-9 cm/sec. Intact liners will allow leachate to pass through but at a low rate. —19— The Leachate Collection System is created by sloping the bottom of the landfill and placing pipes in the lowest point to collect waste and pump it out. The system is like a sump pump in the basement of a home. Collected leachate is usually tested for hazardous chemicals. Leachate levels (depths) in a landfill vary over time depending on infiltration, pumping and recharge rates. When more water enters, more leachate is generated. Increasing leachate causes more hydraulic head pressure on the liner. Pumping can reduce, but not eliminate this pressure. As a result, leachate may stand for even years in a landfill (as much as 10 feet has been reported at some landfills, OTA, 1983). Leachate has to be pumped out for decades after a landfill closes. EPA requires leachate be pumped until it can't be detected, but not longer than 30 years. The Cover, cap or "umbrella" goes over the top or surface after it's filled and no longer operating to reduce water entering the site. If the cap is broken or severed, water as rain, snow or runoff will enter the landfill. Generally, the cap consists of a series of layers of plastic, clay or soil sloped to the sides (See Figure 3). Wastes are covered with soil to provide an even base for the cover. Above the liner is a layer of sand or gravel to promote rain runoff. Then topsoil is added so vegetation can root to stabilize the cover. FIGURE 3. Landfill Cover or Cap i Compacted FM • :71-711 r....� ... • - . . •'•• ' ::•....::• • R cs- ock or Impervious Stratum• = SCC X54 -20- SITE CHARACTERISTICS include climate which influences how much leachate is generated, soil make—up which determines how easily leachate moves and hydrogeological setting. Important soil factors include: • Permeability of native soils; • Fractures, sand lenses (an area of sand sandwiched between soil of different makeup, such as clay, which provides a "pipeline" or pathway for water to move faster than the surrounding soil) or other pathways of migration; • Soil characteristics including depths, distribution and uniformity; • Seismic potential; • Fracturing of bedrock (cracks, spaces or separations in the bedrock that provide a "pipeline" or pathway for water to move faster than the surrounding rock) ; • Topography; • Evaporation vs. precipitation rates; and • Depth of water table. • Availability of cover. • Transportation. • Groundwater formations underneath. • Political acceptability. New York state has recently passed stringent siting criteria which prohibits a landfill from being built over an aquifer and in any area that has a well capable of pumping more than 10 gallons per minute (NYSDEC, 1985) . EPA has no criteria for siting hazardous waste landfills. However, for low—level radioactive wastes, EPA states that locations "should be chosen so as to avoid adverse environmental and human health impacts and wherever practicable to enhance isolation over time" (OTA, 1983). Many local and state efforts have evaluated siting criteria. Several are listed in the resource section. Relevant questions and criteria are listed in Appendix C. THE "SECURE" LANDFILL "Secure" is a term of art used by the hazardous waste industry and many government regulators. CCHW does not endorse this concept. We're presentiu LiC .:,0: -21- this explanation because it's commonly used and we all need to understand what they're talking about. The theory behind a "secure" landfill is to physically isolate wastes from the environment by preventing leachate from moving from the site (NAS, 1983). The "secure" landfill, first used in the mid 1970's, is basically a double—lined landfill. Two liners are placed in the ground and separated by 1-2 feet of porous soil usually sand or gravel. The lowest liner (closest to the ground) is called the secondary liner. The upper liner, closest to the waste is called the primary liner. Sand or gravel is generally placed between the wastes and this liner to prevent waste containers and waste—moving equipment from damaging the liners. The leachate collection system of the "secure" landfill may be between the two liners or may exist below each liner. A sump collects leachate generated from each layer. If leachate shows up in the sump (between the two liners) this is evidence the primary liner is leaking. The second liner is supposed to "catch" the leaking liquids and prevent groundwater contamination. Sometimes a "tracer" chemical is added to the wastes to provide a warning that leakage is occuring. Boron, fluoride or a dye that normally doesn't occur in the wastes can be added and monitored in the leak detection system. A typical "secure" landfill is shown on Figure 4. FIGURE 4. Secure Chemical Landfill Monitoring welt-. conlr_istmdergraun�xlater + •o'ohecfr tnf possible `` t R `, -t' w`� .�Z--' -ae•1� coniarrnnal _T C ` ... :02%-2 '�t....: a'T.--s br ., . . ��,Sollctwasteleyer. rte- 7••'''.5:-%77..-",- .=« v «"�•'.. ".. iiit.w,ttraln:^ . ..,.`..�-_mot=`'.� � .3 � LImlkOring;Mlll . T� .--. .r. 4.440-f. ,. 9u6atKfan . . ;' SfPtrdret6waMeWatNC �"�A ' mg ant drains T'.'' , ,; •-treatmentUnitthini }[rears-."1„---. F .ara.periorated and feed into ","" a mas loi-envinisnervalfe.i. M ' a drainpipe.whictuleilvers Y'^-^--- . - saledisp_os`al 4- ieeCht5e through dew` _.,,1,., --4i::„.----7'-'9,-.7a:-.*: '+ to ...In ,s LeAehattr re 4-Car s __ . - _ 7 .:1 • — ' t ;S".1"*.'. c• traytr �p " x, .4 _ �. '., i 'Ma1taN aoA� t - E CLywN prevents _ �-r 6't t--:.. �'Groundwater contaminants from leachklp +w S[. \.rd<'3"'t x -' - ,� iMo groundwater. r::. -22- WHAT CAN GO WRONG? In order for landfills to be effective, they must work perfectly for decades, if not centuries. Clearly, this has not happened. In fact, according to EPA's Bill Sanjour (OTA, 1984), virtually every hazardous landfill is known to be leaking. Leachate can escape from landfills in a lot of ways. The most common are shown on Figure 5 and described below: 1. Downward through soil, clay, sand, rock and liners into groundwater; 2. Sideways through the sides, or through or under dikes and dams; 3. Over the top if the cover fails and the "bathtub" fills; 4. Air emissions through soil. FIGURE 5. set r J �4 : 3 ..«.o<o... \\\...nuw..w.ccua.n '≥ Oftft:OATONw ..a. /„estar d u.c+w :.. .. Ma <ururw I . ► .. .� �� ."0 rprruw.r.O �'� 11pnVrrt cwr..wnoraa.o..ur• -23- 9 '05611 Wastes can escape through the BOTTOM LINER in the following ways: • Faulty installation causing damage during or after installation; • Liner deformation and creep on the sloping walls; • Differential settling caused by poor soil support; • Structural failure of the liner due to water pressure; • Liner degradation caused by chemical wastes or microbial action; • Liner swelling causing loss o£ strength and puncture resistance; • Chemical extraction of plasticizers ("glue") holding liners together. All liners will eventually fail. Low moisture content and poor clay compaction can increase permeability a 100 fold. For plastic liners, pinholes are produced in the manufacturing process, guaranteeing that the liner will fail (manufacturers actually report the number of pinholes per square meter in their specifications.) . When plastic liners are installed, small sheets are sealed together like a quilt. These seals are "weak" links and are often the first places to leak, since the panels can cover as much as 20,000 square feet and weigh 5 tons (OTA, 1983). Uneven soil or sharp rocks under the liner can tear plastic or cause stress in clay, eventually resulting in settling and cracking. Tractors and heavy equipment can also damage liners. Chemical reactions between leachate and the liner will also cause leakage. For example, acids can solubilize minerals in clays increasing permeability while some organic liquids will increase permeability of clays and dissolve components of PVC liners (Anderson, 1982). Dr. Peter Montague of Princeton University did a practical study of landfills and liners in 1981. Montague looked at 4 "state—of—the—art," "secure" landfills in NJ. In all 4, primary liners (one clay, two Hypalon and one PVC) failed and all four leaked (Montague, 1982). When he presented his results to Congress, Montague commented "the conclusion is inescapable that all landfill liners will ultimately fail," (Montague, 1982a) . SCC564 -24- Failure of the LEACHATE COIJ FCTION SYSTEM will also cause a landfill to leak. This can occur by: • Clogging of drainage layers or collection pipes; • Overlying waste or soil crushing collection pipes; • Pump failures. These failures are hard to detect and would require extensive testing which would be both expensive and time consuming with no guarantee of success. Lack of leachate flow, for example, could be misinterpreted as an end to leachate generation—in fact, the system may be blocked. TV cameras and specialized "snaking" tools can be used to find a blockage and clear it. Manholes connecting the pipes are needed to get at the collection system. Without manholes, there's no physical way to find out if the collection system is intact. In this case, a tracer chemical could be added to the wastes to see if it reaches the collection system. fah COVER or cap is perhaps the most important factor in success or failure of a landfill. Even if the bottom liner(s) and collection system remain secure, cap failure will make the landfill fill up like a bath tub and spill over the sides. Unfortunately, the cover is most likely to fail (See Figure 6) . Montague listed the following forces which can destroy the cap (Montague, 1982a) : • Damage due to faulty installation; • Cracking of the cap due to settlement; • Collapse o£ the cap into gaps caused by settling (subsidence) of wastes. Wastes, usually not compacted, slump and settle under the the weight of wastes above. Also, as organic matter decays, it forms gases. These leave the landfill full of void spaces to be filled by wastes sinking down from above; • Ponding of water in depressions; • Erosion caused by rain, hail, Snow, freeze/thaw cycles and wind; • Tree and plant roots that penetrate the cap; • Burrowing animals and insects digging through the cap; • Cracking of the cap due to drying out; • People building parks, schools, playgrounds, etc. ; Al -25- FIGURE 6. Potential Failure Mechanisms for Covers A) Cracking of cap due to settlement ..eelem ISM© � ri B) Collapse of cap Into open voids V illir C) Ponding of water In depressions "inkalliatCartc0, a D) Cracking of cap due to desiccation -.------ •:-;.41#*. E) Proper design (Source: OTA, 1983) `CCu'5r -26- These slow but relentless natural forces can be temporarily contained by maintenance and monitoring. But it's only a matter of time before nature destroys the cap. When this happens, rain enters the landfill and leachate begins to migrate outward. WHAT CAN BE DONE IF A FAILURE OCCURS? Historically, not much. Corrective actions at leaking landfills have generally dealt with the symptoms of failure, not the cause, because, unfortunately, very little can be done. For example, to repair a leaky liner, you have to first identify the source of the leak, excavate and remove the wastes and only then make the repair. All of this is technically difficult, not to mention very expensive, and therefore, seldom tried. Instead, the approach is usually to try some sort of containment system, such as a barrier or slurry wall (slurry walls have thier own weaknesses and are subject to failures; the best evidence is the slurry wall installed at the Pitman—Lipari Landfill which failed and leaked less than one year after it was installed —CDM, 1985) or a new leachate collection system placed to collect wastes leaking from the original system. Sometimes, groundwater pumping is used to capture and treat contaminated groundwater. You can repair a damaged cover, but the more complex and sophisticated the design, the more difficult and costly it is to fix. Cover repair may require peeling back each protective layer until you find the problem. Repairs include laying down new layers, reconstruction of cover drainage and gas collection systems, recompaction of soil layers and revegetation of surface soil. Most of these procedures must be done by hand, can't be done in bad weather and are very costly. WHAT DEFINES A FAILURE? The common sense definition is that failure is a breakdown of any of critical design feature that allows leachate to leave the site. EPA, on the other hand, uses groundwater monitoring data of 4 "parameters" to signal landfill leakage. If a "statistically significant" difference exists between Lei 0 _27_ well(s) upstream and wells downstream, then the site is considered to be leaking and requires corrective action. Problems with this approach: (1) EPA doesn't say what it's using as a baseline to which "new" observations will be compared. Unless this is defined, monitoring results have little meaning. (2) EPA doesn't say how much or how many of the four selection parameters must increase before they'll say there's leakage. One of 4? Two of 4? Three of 4, or must all 4 increase? This lack of clarity raises problems. Montague interviewed landfill operators and found that "even with many parameters increasing, owners and operators of landfills would not admit that their landfill liners had failed" (Montague, 1982) . By the time it gets into the groundwater it's too late. Though EPA hasn't addressed these inadequacies, they do recognize the risks posed by landfills: ". . 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." Such wastes "will remain potentially dangerous for many thousands of years." And "since disposing of hazardous wastes in or on the land inevitably results in the release of hazardous constituents to the environment at some time, any land disposal facility creates some risk" (USEPA, 1981) . While EPA admits the risk, they don't propose to do anything about it. No standards for "failure" exist, so failure is measured by how much damage has been done to the environment and people's health, not by the number of chemicals exceeding a standard. This is hardly environmental "protection" but is, instead an approach that says the problem will only be addressed after the harm's already been done. ,. —28— VI. SOLID WASTE LANDFILLS DESIGN Solid wastes are household wastes, trash and garbage that for years were put in "open dumps" and then burned or allowed to decompose ("biodegrade"). What didn't decay would gradually sink into the soil and more or less disappear. This was common practice until well into the 1960's. Since then, solid waste landfills have come into use. These landfills are also called municipal or "sanitary" landfills. However, they're anything but "sanitary," attracting birds, mosquitos, flies and rodents (all of which are carriers of disease) and are subject to fires. These problems can be reduced—not eliminated—by covering the wastes. Municipal landfills are designed so waste is spread in layers, compacted to the smallest practical volume and covered with soil by the end of each day. There are three basic municipal landfill designs: The Area Type: wastes are spread on the ground, compacted and covered with earth from another source. This method is often used with ground depressions or earthen structures, like quarries, strip mines, ravines or valleys (See Figure 7) . FIGURE 7. Area Style Solid Waste Landfill _ r 1 _ - IU IW5WI�ir�ntilkdi1':i�r.Fil.i gra -� art - -,� • - \'\"-fir``." �� %\ i •• >: (Source: USEPA, 1972) -29- The Ramp Type: a variation of the area method. Wastes are spread and compacted on a slope (See Figure 8). Cover material is taken from the surrounding area so much more wastes can be placed in the excavated area. The Trench Type: wastes are spread and compacted in an excavated trench. Cover materials are taken from readily available excavated soil. Residual "spoils" can be stockpiled for later use (See Figure 9). This method isn't useful in areas with water tables within 6 feet of the surface; best suited to flat or gently rolling land. These methods are often combined, depending on site characteristics and, to some extent, the wastes to be disposed of. Important factors in traditional municipal landfill design: (1) Volume Requirements — By comparing site capacity with the rate of waste dumping, you can estimate the useful life of the landfill. (2) Site Characteristics — Characteristics and type of topsoil and subsoils, depth to bedrock, distance to groundwater, surface terrain (i.e. rocks, hills, drainage areas, vegetation and surrounding land use) . (3) Surface Water Controls — To divert surface water from entering the landfill. Gullies, trenches, or pipes could be used to divert drainage. Surface water entering the landfill will increase leachate direction. (4) Groundwater Protection — To prevent leachate from contaminating groundwater. You need information on depth, rate, direction and uses of groundwater, and discharge areas to assess impact on grundwater quality. At no time should the water table enter the areas of waste disposal in a landfill. Clay or plastic liners are sometimes used to "protect" groundwater (See Section V. What Can Go Wrong?). Monitoring wells are needed to assess the impact on groundwater quality. C� e S -30- FIGURE S. Ramp Style Solid Waste Landfill x-1- tWt'{ t•.{.r -..+..-0,0,-.6a---r-4---0,,y.,,,,^•rip`,.may. rf�— �* _ e- •\ �_ L c I - I _ - , l _ _ — - ._�_.,� 4 S�Y� _. ! - DAILY EARTH COVER ISIN{ - t ‘V�.\��_. ^' X IK/ 4L` -TS S. T -,P)i; P1 i 1r 1r 1 StT !ate\ s id r y 31'f'I I�r 3. �•'{ r. ate. EXCAVATION FOR ORIGINAL � � �•:.. EARTH COVER GROUND „ :{ COMPACTED _ GG SOLID WASTE +`i - .I.? f--. 4d 1t '-,, ,-'- _.__.-j..... In the progressive slope or ramp method of sanitary Iandf Wing, solid waste is spread and com pacted on a slope. Cover material is obtained directly in front of the working face and compacted on the waste. (Source: USEPA, 1972) FIGURE 9. Trench Style Solid Waste Landfill ti,... -- � _ �� _---..._ �- ." �- _ � �' .... .� ,.-- , IMP N.••••• ..... ` `\y �,'\.A'• `/Ll / LLB //1/Nit 1717177,7-1--____, �/ '1 ,7 1.1� •It,,`to- _..u� �� ` •�. N, ,N %, � \ - � (Source: USEPA, 1972) ' `- 1%4 �%N. •-- .1/2 •3/4 nr,,(1, - -31- (5) Gas Movement Control to contain and release gases — carbon dioxide and methane — generated by decomposition of wastes. Vent pipes and gravel filled trenches are commonly used to vent these gases (See Figure 10). Unreleased gas buildup can cause explosions. FIGURE 10. Gravels or Gravel—Filled Trenches for Controlling Gas Movement r�Sbe .furl w.w mrwir , +�0 � � „d . /Os i ,\ Cdl • iinM two'materiel (Source: USEPA, 1972) (6) Closure and Future Land Use to ensure proper closing, monitoring and compatibility of site with surrounding land use. The closed landfill can pose a danger if proper precautions are not taken. Factors to be addressed include: • Settlement of wastes; • Disturbance of cover/cap; • Release of landfill gases; • Capacity to support weight (such as the foundations of buildings); • Production of acids from decomposition of wastes which can corrode utility lines, leachate drains, or building foundations. 900 564 -32- In the past, old municipal landfills have often been turned into parks, playgrounds, nature preserves, golf courses or even ski hills. These practices are inappropriate, given the history of these sites and the risks they pose. Consider also, the point raised earlier that human activity on landfill caps can cause them to break down. Siting criteria for solid waste landfills should not be any different from criteria for hazardous waste landfills. The general sense that solid waste landfills are not as dangerous as hazardous waste landfills is a myth that has no basis in reality (See Next Section) . The same toxic chemicals that are disposed of in a hazardous waste landfill are disposed of in municipal landfills. The only differences are that the generator doesn't produce very much of these wastes and subsequently the amounts are less. Several important siting and design factors are described below. A more extensive listing of questions to ask are included in Appendix C: • Transportation: access roads; location of entrances; traffic patterns; flow and volume; anticipated arrival time; condition of existing roads and facilities for private citizens. • Site operation and maintenance: operating hours; use of equipment; management systems; control of rodents, flies, mosquitos, birds and other vectors; and control of litter. DO MUNICIPAL LANDFILLS REALLY POSE A THREAT? Why the big deal about municipal landfills? After all, they only take household garbage and trash, right? These wastes are not the same toxics that end up in chemical landfills, right? WRONG. In addition to household wastes (which include some toxics) , municipal landfills accept the very same wastes that end up in a chemical landfill. The only difference is who generates the wastes. EPA allows "small generators" to dump the same toxics found at sites like Love Canal, Woburn, MA and Stringfellow, CA in the town dump. OTA estimates that 26 million metric tons of hazardous wastes (of an estimated 250 million metric tons) were put in municipal landfills (OTA, Sec,- 4 -33- 1985). As a result, municipal landfills may pose a greater risk to public health and groundwater than chemical landfills. In fact, if you look at the current Superfund list, over 207 of the sites are municipal landfills (OTA, 1985). 897 of these sites have contaminated groundwater, more than half of which are sources of drinking water (OTA, 1985). Reasons for these problems: (1) large quantities of hazardous waste are dumped in these landfills; (2) small generators use these landfills all the time; and (3) there are no safeguards or warning devices to prevent or detect leakage. (1) Large quantities of hazardous waste end up in municipal landfills b cause many hazardous materials are not regulated and can be disposed of in nv landfill. For example: • Mining wastes, including radioactive wastes, toxic metals and acids. • Wastes from energy production - toxic metals, organic solvents. • Agricultural wastes - pesticides and fertilizers. • Waste oils - toxic organics and metals. • Waste burned as fuels - unburned toxic organics. • Wastes from pollution control devices such as scrubbers on incinerators—toxic organics and inorganics. • Small generators of hazardous waste - industries producing less than 2,200 lbs (See discussion below) of hazardous waste each month; • Fly and bottom ash from garbage incinerators and from burning fossil fuels - toxic metals. • Cement kiln dust - alkalinity, toxic metals. • Domestic sewage discharged into publicly owned treatment works - contents uncertain, but likely includes toxic metals, organics and other wastes from small generators. • NPDES permitted industrial discharges - toxic organics, heavy metals. • Infectious wastes and materials, from, for example, hospitals. • Wastes exempt from delisting petitions - could be anything. • Toxicity test exemptions - organics. • Recycled wastes - improper handling or application of wastes. (list adapted from OTA, 1983) !.L� t,l SAS P-^S v f7 �3 " -34- (2) Small quantity generators likely contribute the greatest quantities of hazardous wastes to municipal landfills. Small quantity generators are those who produce either: • Less than 1 kilogram (2.2 lbs) a month of acutely hazardous waste; • No more than 100 kg (220 lbs)/month of residue or contaminated soils, water or other debris resulting from cleanup or any spill of any acutely hazardous waste; • No more than 1000 kg (2200 lbs)/month of any other hazardous wastes. Congress recently lowered this criterion to 220 lbs/month, but EPA hasn't yet released the regulations scheduled to take effect in July, 1986. These generators have the benefit of total exemption from RCRA disposal, notification, record keeping, reporting and manifest tracking. Some small generators compound this problem by mixing and diluting hazardous wastes with non—hazardous to create a mixture that qualifies for the exemption. As a result, most small generators end up disposing of their wastes in the most convenient means possible — usually in the nearest town dump. Then there's the hazardous materials derived from household garbage such as plastic bags, solvents, draino and other cleaners, aerosol cans, and pesticide wastes. Read the label on the next cleaner you buy and think about how every household in the country does the same thing and you'll begin to understand the contributions of household wastes. (3) Few, if any but the newest municipal landfills, have protective measures to prevent leachate generation or migration. Liners, collection systems, covers and monitoring systems are not typical o£ solid waste landfill design. In its classic 1972 design manual EPA mentions but doesn't actively encourage use of liners to prevent groundwater migration (USEPA, 1972). This manual is the industry's "bible" for the design and construction of solid waste landfills. fi c s a,,r S —35— ': t: ' Even the updated version of the manual does not encourage use of liners. EPA states "Liners should be used when soil permeabilities or soil depths are not adequate to protect groundwater or when required by State regulations. It is economically preferable to use in situ (in place) soils whenever possible" (USEPA, 1981a). By bringing in cost considerations, EPA seems to be telling landfill operators that liners are expensive and where possible use native soils. As a result, few if all municipal landfills in operation today have liners of any kind. WHAT CAN GO WRONG? Groundwater Contamination. Caused by leachate generated when water mixes with wastes. This leachate moves with the local groundwater carrying wastes from the site. Leachate can contaminate nearby drinking water wells, local groundwater, streams, creeks, lakes, rivers and surrounding soil. Gas Build Up and Migration. Methane gas generated by bacterial decay, takes the path of least resistance through permeable portions of the landfill (See Figure 11). Methane gas can hurt vegetation by denying oxygen to the root systems and can cause explosions. In 1984, methane from the Lorton Landfill leaked into the next—door District of Columbia prison, exploded and killed one inmate and maimed a second (Washington Post, 1985). Methane concentrations between 5-159, are explosive. FIGURE 11. Pathways of Gas Migration EXTENSIVE LATERAL MIGRATION CLAY OR SYNTHETIC CAP )LOW PERMEABILITY) CLAY SOIL, FROZEN OR SATURATED SOIL, OR PAVEMENT )LOW PERMEABILITY) \l Il 0'•:r/• /• �•• REFUSE TC Y .'e e. : f % e T " SAND AND GRAVEL SOIL (HIGH PERMEABILITY) -36- Volatile toxic chemicals can be carried with methane gas and escape. This happened at the Monument Street landfill in Baltimore, MD, where vinyl chloride, benzene, toluene and 1,1-dichloroethane were found in vent gasses. A carbon—activated filter was placed on the vent pipe to prevent release of these chemicals into the community. (Princeton University, 1983). Birds, mosquitos, flies and rodents carrying disease from the landfill. Garbage wastes attract insects and animal scavengers that carry infectious diseases. Most of these pests can be controlled by daily covering wastes with soil. Standing or ponded water, a prime source of mosquito breeding should be eliminated. Litter blowing around can be a nuisance. These can be somewhat controlled by use of fences to capture blowing litter. Acrid odors and fires caused by leaving wastes open to the air. Dust. Surface water contamination caused by overflowing leachate, runoff during rain, snow or seepage through berms, dikes or side walls. The same problems as hazardous waste landfills (See Section V.) . VII. SURFACE IMPOUNDMENTS DESIGN Surface Impoundments (SI) are ground depressions used to store, treat or dispose of hazardous wastes with names like: pits, ponds, lagoons, treatment basins, holding, settling, evaporation and aeration ponds. SI's can be natural or man—made, diked or excavated areas formed by local soils (See Figure 12) . Sometimes abandoned sand and gravel pits or rock quarries were converted into impoundments. Most impoundments are smaller than 1 acre, but some are as large as 100 acres in size. 907 are -37- smaller than 5 acres, except for mining waste SIs where 339, are greater than 5 acres (USEPA, 1983). Most range from 2-3 feet in depth to as much as 30 feet deep (USEPA, 1978). FIGURE 12. Surface Impoundment New impoundments are built in three ways: (1) totally excavated, (2) filled, or (3) combined. Excavated impoundments are those which are dug from the surface downward. Filled impoundments are built from the ground up. Most SIs are combined using both excavated and combined methods (See Figure 12). Some SIs are specifically designed to seep into groundwater, unlined and sited on permeable soils. Others serve as holding tanks for curing, dilution or treatment (pH adjustment, water cooling, precipitation/coagulation, biological oxidation). Some SIs contain liners of clay, concrete, asphalt, metal, local soils or plastic. Most don't. EPA surveyed SIs and found that over 70% of industrial sites weren't lined (USEPA, 1977). WHAT CAN GO WRONG? The greatest threats result from seepage into groundwater, evaporation, berm or sidewall collapse and spillage over sides. EPA has records on over 400 cases of SI groundwater contamination. Of these, 79% are seepage through the bottom (USEPA, 1977). 87% of the SIs are located over aquifers used for drinking water (OTA, 1983). Residents in Vickery, OH living next to huge waste lagoons have complained of odors and air pollution for years; a toxic cloud was released from that site when incompatible wastes were mixed together. .In Tombstone, AZ, 90,000 gallons of cyanide wastes escaped from a lagoon when a berm collapsed. OCC:584 —38— Ways surface impoundments can fail include: 1. Poor siting/local conditions. 2. Improper design. 3. Poor construction. 4. Bad weather. 5. Earthquakes. 6. Poor maintenance. 7. Liner rupture from poor liner preparation or sink hole formation. Seepage into soil and groundwater causes more loss of liquids than by evaporation (OTA, 1983) . How much leakage occurs depends on thickness of the liner, if any liner exists, the distance to groundwater, the mobility of the wastes, and the type of soil under the impoundment. The amount of time waste is stored can also affect leaching. Bottom sludges, for instance, can actually can slow down bottom losses. Some stored liquids are volatile and evaporate at normal temperature and pressure, as has occured at Vickery, OH and Middleport, NY. There's little data on the severity of this problem. Few air tests exist that show what comes from SI's; most data comes from mathematical model estimates. These models were adapted from models evaluating ocean or lake evaporation. Although OTA feels these models "must be viewed with caution", they still predict significant emission losses (OTA, 1983) . • For example, emissions from a 1/4 acre impoundment (depth 3.5 meters, air temperature 25°C and wind speed of 1/10 mph) holding liquids with 100 ppm — benzene and 100 ppm chloroform are estimated to be 45 lbs/hr of benzene and 30 lbs/hr chloroform (OTA, 1983) . This means that in each hour 45 lbs of liquid benzene and 30 lbs of chloroform will evaporate into the air. Emissions will decrease as concentration decreases and increase if more wastes are added. Factors that influence evaporation include initial concentration, vapor pressure, solubility, air temperature, humidity, wind velocity and the size of the impoundment. The direction of wind will primarily determine who if anyone is affected. —39— "C a 3` e _ SI's are proven problems. Nine of the top 20 Superfund sites have a pit, pond or lagoon. 36% of 850 Superfund sites are SI's, the most common disposal method found on the Superfund list. Among the more notorious are Stringfellow Acid Pits, Riverside, CA; Berlin—Farro, F1int,MI; Woburn, MA; Vertac Corp, Jacksonville, AR. VIII. LAND TREATMENT DESIGN This method involves spreading waste on land to make wastes "degrade", transform or become immobilized. There are now about 200 hazardous waste land treatment sites (NAS, 1983) in the U.S. and over 4000 sites for non—hazardous wastes (ASTSWMO, 1984). Many land treatment systems cover thousands of acres in a single area or county. Farm lands are often used because land is available and, presumably, fewer people would be affected. Other terms for land treatment are: land application, land cultivation, land irrigation, land or soil farming, land spreading, land spraying, and soil incorporation. Slurries, sludges, untreated wastes, residues and solid wastes are typically the kinds of wastes disposed of by this method. However, nearly every type of waste has been considered at one time, including low—level nuclear wastes, PCBs, inorganic and organic chemicals. It is highly inappropriate to dispose of organic chemicals (solids or liquids) by land treatment. Doing this would eventually contaminate local groundwater because many of these chemicals are mobile in water. Waste is generally mixed or applied directly to topsoil (0-1 ft). The theory is that chemical and biological reactions occur that break down part of the waste. Absorption and fixation immobilize other portions and the rest is carried away from the site either by groundwater, surface water or rain. Land treatment essentially works by spreading the wastes over large areas and Se5Frffi -40- letting natural elements reduce contaminant levels primarily by dilution.(See Figure 13). FIGURE 13. Land Treatment Application SLUDGE TRANSPORT AND APPLICATION Q EQUIPMENT U J T C ' _ AERATED SLUDGE MOLDING BASIN • • •' SURE ACE WATER MONITORING BUFFER ZONE SLUDGE APPLICATION, E BUFFER LONE OVERLAND AND/OR EGETATION 1 SUBSOIL INJECTION COVER • it SUBSURFACE DISPOSAL SITE _ WATER MONITORING DRAINAGE DEVICES This disposal method assumes that soil and weather will stabilize wastes through biological, chemical or physical means, coupled with control of soil pH (usually between 6.0 and 8.0) and "best management" practices. However, reactions between soil and wastes are very complex and more research is needed. Further, there aren't any long—term studies that evaluate the impact of land treatment sites on public health and the environment. In the absence of adequate studies, the suitability of each land farming site has to be judged on its individual merits. Wastes are applied to the land by spraying, irrigation, furrow or ridge irrigation, spreading, center pivots or soil injection. Important safeguards: groundwater monitoring, land preparation, buffer zones, secure storage areas, security, closure and post—closure requirements, careful crop selection and, most importantly, monitoring of application procedures. The wrong techniques or poor management can completely undermine the system. Unfortunately, .thjre are no required standards for any of these procedures. EPA and some states have issued guidance documents, but for the most part, the operator is left to decide how, when or if to use these safeguards and how to manage the site. As a result, few sites have groundwater monitoring and even fewer are inspected to ensure that proper application procedures are being used. Even when problems or poor management practices are identified (often by irate community people) , there is little enforcement power to force the company to change operating habits. There are two key design concepts for land treatment systems: (1) how much and what type of waste is going to be applied and (2) what's the best way to do it. In the first step, only wastes that can transform or become immobilized in a particular soil should be candidates for land farming. The following are general categories that should NOT be land farmed: • persistent wastes such as PCBs or pesticides; • soluble inorganics such as boron, arsenic, selenium; • ignitable wastes; • volatile wastes; • highly reactive wastes; • nuclear wastes; • incompatible wastes; • wastes that contain unknown chemicals or materials of unknown quantities; • wastes which when mixed together reduce degradation, transformation of other soil reactions. For the second step, you have to assess the ability of the site to absorb the wastes by determining how much waste constituents can be applied per unit of land without damaging the environment. While research studies provide some help in this evaluation, experience and "best judgements" are usually used. As already mentioned, experience and best judgement don't always result in use of proper application procedures. Several examples of what can go wrong are described below. 9CC56/1 -42- WHAT CAN GO WRONG? Little information is available on health or environmental risks from land application of sludges. Why? Because there haven't been any major sludge—related disasters to direct and focus bureaucratic and scientific attention on land treatment. One local environmental organzation has, however, given the subject a great deal of study and they've flagged a number of problem areas. "Inappropriate and sloppy" is how Fauquier Organized Residents Guarding The Environment (FORGE) describe actual practices. FORGE has been extremely dissatisfied with the kinds of wastes applied, how, how much and where it's applied and has documented numerous violations of federal and state guidelines and application requirements, noting that enforcement is a major problem. Specific problems and concerns: • groundwater contamination; • surface water contamination; • air pollution; • odor and aesthetic problems; • dust problems; • runoff and erosion during rainfall; • up—take and accumulation of wastes in crops; • survival of pathogens; • hydraulic overloading of soil; • damage to vegetation; • ultimate use of land; • danger to wildlife and domestic pets; • midnight dumping/nuisances; • transport accidents involving trucks delivering wastes; • increased truck traffic and tracking of wastes on roadways (by both normal traffic and waste hauling trucks); • poor/inadequate application procedures; • lack of groundwater monitoring; • run—off of sludges/wastes onto roadways and other "clean" areas; • damage to agricultural businesses; • over application. 9 C'sJ34 —43— Waste constituents can leach through soil and pollute groundwater threatening drinking water in nearby wells and water used by farms to grow crops and feed animals. Consequently, neither soluble organics nor inorganics should be land treated. EPA says the following site characteristics can reduce potential groundwater contamination: 1. topsoil should be at least 5 feet above seasonal high water table; 2. facility should not be sited over usable aquifer; 3. boundaries no less than 500 feet from drinking water supply; 4. there should be no wells or geological conditions such as sand lenses or fractures that permit rapid downward movement; 5. soils should be fine grained to enhance soil reactions. (USEPA, 1984a) Surface water can be contaminated by waste run-off caused by rain. To minimize this, off-site surface water should be diverted away from/around the site and contaminated run-o£f should be collected and treated as hazardous waste. Direct chemical evaporation, dispersion of contaminated dust and odors and air pollution are other major problems. Odors can be caused by applying new waste on top of old or from poor biological activity in the soil, as well as standing water left on site. This invites anaerobic (no oxygen) conditions in soil that can produce bad odors. Raw waste should be mixed with soil promptly after application to reduce odors and tilling may be needed to maintain aerobic (oxygen rich) soil conditions. Applications should cease during periods of extended rainfall or freezing conditions. Pathogens are a concern because bacteria, parasites and viruses can survive in soil treated with wastes and affect groundwater, surface water, air, crops, livestock, drinking water and people. see s -44- I%. REGULATIONS HAZARDOUS WASTES LANDFILLS The Resource Conservation and Recovery Act (RCRA) of 1976, implemented by EPA, is the main law regulating land disposal. EPA took 6 years to issue regulations (see preamble to 47 FR 33, 276-78, July 26, 1982 for the history USEPA, 1982) which went into effect on January 26, 1983. These rules require all land disposal operators to: • Apply for a permit from EPA. • Meet interim status standards until permit is approved or denied; • Meet the permit conditions after issuance. This permitting process has two parts, A and B. In Part A, EPA asks for general information on the site; Part B has the detail on facility design, operating and maintenance procedures, closure plans, financial responsibility assurances and regulatory compliance. Facilities qualifying for "interim status" may operate without a permit while their application is reviewed and are treated as though a permit has been issued. A Part A application is little more than a formality notifying EPA that the facility exists, but it is needed for an "interim status" permit. No site inspections nor follow—up on the application occur. Part B is more substantial. To qualify for interim status, a facility must (1) have existed on November 19, 1980; (2) notify EPA of its activities; (3) submit a Part A application. Interim status facilities must comply with interim status rules like prevention of hazards, manifest tracking system, record—keeping, reporting, groundwater monitoring, closure and post closure care, use and management of containers, financial responsibility, waste analysis, site security e e( i A —45— inspections, personnel training, design and operation of disposal facilities. According to EPA, these requirements are incorporated into the final permit. All existing or proposed facilities must meet "performance standards" that: • Set design and operating practices to protect health and environment; • Provide the technical basis for permitting facilities; • Set minimum standards for authorizing state hazardous waste programs. Performance standards call for an "acceptable" level of effectiveness without specific technical guidelines or standards, making permit writers use site specific data to make sure health and the environment are protected. Relying on the permit writer has been highly controversial and open to criticism. Too much is left to a single person to decide. Is the person qualified? Does s/he have the experience and training to understand all the technical characteristics of a site? Is s/he above corruption or political influence? What results is an uneven interpretation and enforcement of the standards depending on the individual permit writer. A summary of the performance standards that apply to land disposal facilities are included on Table 4. Most facilities operate under interim status. GAO reviewed EPA's permiting process and found that through July 1983, only 24 of 8000 facilities received final permits and EPA didn't expect to complete the process until well into the 1990's (GAO, 1983) . Currently, only 91 facilities have been permitted. The deadline for operating facilities to submit their final permit application (or closure plan) was November 8, 1985. EPA reported that only 492 out of 1600 interim status facilities submitted information before the deadline (USEPA, 1985c) . This means that approximately 1108 facilities must close down or already have. How EPA will handle this situation is unclear at this time. Lists of who has been certified and who hasn't can be obtained from the USEPA RCRA Superfund Hotline (See USEPA, 1985d on Resource List) . Interim Status regulations are less stringent than final performance standards and are mostly "housekeeping" or cosmetic requirements (See Table 5) . Only groundwater monitoring, closure and post closure are detailed.Seu. 331 -46- Table 4. Technical Performance Standards for Landfills and Surface Impoundments Design and Operating Conditions Landfills(subpart NI Surface bispea ndanaare(Subpart K) All landfills Incept existing portions)must nave a liner to prevent migration of wastes to soils, wound,or sup All surface Impoundments(except existing portions) face waters through closure.Alaten si must prevent must have•liner that prevents migration of any wastes waste passing into liner during active life of unit,resist out of the impoundment to adjacent soil,or surface or failure and degradation,and be compatible with wastes- wound water at any time during the active Ilia of the Uner must cover all earth likely to be in contact with facility(Including closure). wastes or laaehate. Unto base must support and resist Exemption from liner requirement for alternative design pressure gradients to prevent failure. RA will set liner and operating practices and wagon characteristics design and operating specifications to.achieve perform- mat prevent migration of any hazardous constituent once standards In permit. Into ground or surface water at any future time. All landfills(except existing portions)must have a Impoundment must be designed, built,and operated to leaenre convenor'and removal system above the liner prevent overtopping from overfilling, run-on, malfunc- deslgned and operated to prevent liquids accumulation tlon,or human error. of more than 1 ft above the liner and t0 function with- Dikes and containments must be designed, built, and out failure, clogging,or degradation through scheduled maintained to prevent massive failure without relying on closure. RA will set design and operating specifications the assumption that the liner will function without for Inchon)collection system in permit. leakage during the active life of the unit. Exemptions from liner-esel ate collection system require- Special contingency plan provisions for Immediate shut manta can be prated by RA If alternative design and down, spill containment,emptying of unit, and operating practices and locations prevent migration of emergency repairs. any hazardous constituent to ground or surface waters The RA will specify all design and operating require- at any time in the future.All landfills must Install run- tents necessary to meet these standards In the permit. on controls and runoff management systems sufficient to control flow Into or out of the unit from a 24-hr 2 -yr storm and control wind dispersal of particulates. Disposal of bulk liquids In landfills Is limited to facilities with liners and ledenate collection and removal systems. Design and operating conditions necessary to achieve performance standards will be specified in the permit by RA. • Inspection and Monitoring Inspect liner, Ieschate colleetion system and cover,dur- ing and alter construction or Installation for defects, inspect liner and cover during and after installation for damage,or nonunifamltles that may affect performance. defects. damage,or nonundorrntitles that may affect inspect weekly for improper operation,deterioration,mar- performance. function of ninon or waft, and wind dispersal con- At least weekly and atter storms, Inspect for evidence of troll,and for liquids in laiutoetectich system or leach- deterioration, malfunction, improper operation of over- ate in the leaches collection system end proper func- topping controls, drops In level of contents, liquids in tloming of systems.All"tegulated"units must Implement the leak4etectlon system, severe erosion,or deteriore- ground weer monitoring program as specified In permit. tlon in dikes or other containments. Exemption from detection monitoring program for Implement appropriate ground water monitoring program facilities the Install double liners with INkoetectlon specified in permit unless an exemption applies(see system between the linens. If any liquid Is detected be- landfills). twain liners,facility must repair the liner or lose the exemption. Exemption from ground water monitoring may be granted If RA finds that there le no potential for migration of liquid from a regulated unit to the uppermoat aquifer during the active life and closure and post-closure care periods. Closure/Post Closure • Final cover should minimize liquid migration through RemoVe all wastes and residues, decontaminate num- closed unit, require minimal maintenance, promote merit at storage Impoundments;send wastes to TSDF. drainage, resist erosion or abrasion of cover,acorn- At disooW impoundments:eliminate free liquids andnor modee settling,subsidence while assuring cover atop- sohdlty wastes and residues to stabilize waste to rlty. Cover permeability should be less than or equal to support final cover. the liner or natural subsoils. Final cover should minimize liquid migration through Facility must comply with permit specifications on eh> unit, require minimal upkeep, promote drainage, resist sure and post-closure care for maintenance of final erosion and abrasion of cover, and accommodate set- cover,monitoring,and lea-detection systems. t.eachate tling and subsistence while maintaining cover imegnty. collection system must be operated until leachate is no Cover pemiaablllty should be test than or equal to liner longer detected.Ground water monitonng and response or neural subsoils. pogrom requirements must be observed. Observe closure and post-closure-wire, maintenance, in- spection, and monitoring of cover, run-on, runoff con- NOTE M—RplOmr Administrator. trots, ground water monitoring system.and leak- SO URCE 40 CFA Part 1M. • sdetection system. If leak-detection system indicates pon presence of liquid, notify RA for permit modification for (Reprinted faun Chit 1983) Sappropriat Fe rn ground water monitori Ground water monitoring and response program recline- manta must be observed. _(,7_ Goneral repuirements for all interim status facilities —Use of alternative ground water monitoring program • Notify EPA of hazardous waste activities. similar to ground water assessment program allowed If • Obtain EPA identification number. monitoring of indicator parameters would show • Submit Part A permit application. • statistically significant changes in water quality. • File annual or other periodic reports required by EPA. • Handling Ignitable, reactive,and incompatible wastes— • Comply with manifest system: waste analysis and special safety precautions such as —Sign for receipt of waste shipment and retum manifest waste segregation,smoking restrictions,and limits on mix- copies to transporter and generator, Ing these special wastes are required. —Inspect shipment and report to EPA any significant • Bite security. discrepancies In amount, type of waste; —Maintain site security to prevent unknowing entry,and —Report unmanlfested waste (except shipments from to minimize unauthorized entry into facility through exempted small generators)' and 24-hour surveillance,barriers,fencing,posted warnings; —Maintain manifest copy at facility for 3 years. and • Nopfy EPA before receiving waste shipments from outside —Control entry to active portion of facility. the United States. • Personnel training: • Notify new owner in writing of duty to comply with RCRA —Assure that facility personnel are trained in waste regulations. management,operating,and emergency procedures;and • Maintain facility operating record over life of facility —Maintain personnel training records until closure. covering: • Emergency preparedness and prevention and contingency —Type,quantities,and location of each waste at facility; plan: —Method of treatment, storage, and disposal; —Provide Internal alarm and emergency communications —Waste monitoring, testing, inspection results, and system,fire,spill control,and decontamination equip- analytical data(maintain monitoring data for disposal ment, and device for summoning local emergency facilities through post-closure period); assistance; —Accidents requiring action under contingency plan;and —Test and maintain systems and equipment for emergen- -Closure coat estimate(and post-closure costs estimate cy readlnesa; for disposal facilities). —Develop written contingency plan for accidents and • Waste analysis: emergencies; —Prepare and follow written waste analysis plan sPecity• —Designate emergency coordinator, and Ing detailed chemical and physical analyses to be con- —Provide written report to Regional Administrator within ducted,sampling methods,and special analyses for lg. 15 days of events requiring implementation of conbngen- ratable,reactive or incompatible wastes,and for Inspec- cy plan. Ong shipments for compliance with manitest; • Closure: —Teat a lepresentative sample of wastes before treatment, —Develop written closure plan by May 19,1981,including: storage,or disposal;retest if change in waste generating methods of closing(or partially closing) facility at any pldceaaes or If ottslte wastes do not match manifest time during life of facility and at end of operating life, description; and estimate of largest inventory of waste in storage or treat- -Maintain record of waste analyses results. ment during life of facility,how facility and equipment • Inspections and monitoring: will be decontaminated; estimated date of closure; —Prepare and follow written ;operator's Inspection estimated closure costs;and schedule for final closure; schedule describing types of problems to be detected, —Notify EPA 180 days before closure begins; and frequency of Inspection; —Submit closure plan within 15 days of loss of Interim —Inspect for spills at least daily; follow specific status or receipt of order to stop receiving waste; technology Inspection and monitoring requirements —Follow closure plan; under technical standards; and —Complete all treatment,storage disposal activities within —Maintain record of inspection reeults for 3 years. 90 days after receiving last waste shipment; and • Ground water monitoring(landfills,surface Impoundments, —Complete closure within 180 days of beginning of and land treatment facilities only): closure period (unless date is extended by RA). —By Nov.19,1981,develop and Implement ground water • Obtain engineer's and operator's certification that closure monitoring program for assessing the attests of the Is completed according to plan and all equipment and facility on the uppermost aquifer underlying the twill- facilities have been decontaminated or disposed of ty. Program must include: accordingly. (1)written ground water monitoring plan, Including • Post-closure(disposal facilities only): sampling and analysis specifications and methods; —Develop written post-closure plan by May 19,1981,speci- (II)installed system of ground water monitoring Wells tying monitoring and planned maintenance activities to (at least one upgradient well and 3 downgradlent be carried on during 30-year post-closure period and wells);and identifying responsible person; oil)outline of ground water quality assessment program —Follow ground water monitoring plan and reporting to be implemented If contamination is detected. requirements; • Conduct sampling and testing of ground water, —File survey plat showing location,type and quantity of —First year quarterly samples of all monitoring wells to waste in disposal facility after closure,and amend title establish background levels of specified parameters: records showing use of land for waste disposal and (I)Maximum contaminant levels in National Interim restrictions on future use. Primary Drinking Water Standards (21); • Financial responaibility. (II)Water quality indicator parameters: chloride, iron, —Maintain on file at facility.(I)written estimate of closure manganese, phenols, sodium, and sulfate; and costs, adjusted at least annually for inflation, and (ii) (III)Ground water contamination indicator parameters: 'demonstration of mechanism facility will use to pH,specific conductance,total organic carbon,and guarantee coverage of closure costs. total organic halogen. - • Uability Insurance: —Subsequent years: Test for each well quarterly for 8 —Maintain liability insurance or self-Insurance for at least background water quality indicator parameters; semi- St million dollar per occurrence for sudden accidental annually for 4 contamination indicator parameters. injuries to persons or property from facility operations • Continue monitoring program for life of facility and dur- up to annual aggregate of S2 million(exclusive of legal Inc 30-year post-closure period for disposal facilities. costs); • Report ground water monitoring results(for landfills,Sur- —Owners of surface impoundments, landfills, and land face impoundments, and land treatment facilities): treatment facilities must provide insurance or self- -Waivers of ground water monitoring program available: insurance of at least 33 million per occurrence for non- (I)by demonstrating low potential for migration of waste sudden accidental occurences up to an annual aggregate constituents trom facility via uppermost aquifer to water- of SB million(exclusive of legal costs).(Variations may supply wells:(Written determination Is made by facility , be approved by RA for State insurance requirements or operator and certified by qualified geologist or for State assumption of liabilltcli 9`Cr 1 • geoteghnical engineer.) and (II) for surface impound- ..:9''N-;.'E.)C.R“i ments neutralizing corrosive waste If demonstrate no potential for migration from Impoundment. , _ Interim Status facilities are largely self—monitored—it's up to the operator to make sure standards are followed. EPA or the state can conduct periodic. inspections, allowing these agencies to issue administrative orders, imminent hazard actions or enforcement measures that supersede the interim status rules if the facility threatens human health or the environment. INTERIM STATUS GROUNDWATER REQUIREMENTS. As of November 19, 1981, all land disposal facilities must have permanent ground water monitoring programs to assess the effects of the facility on the uppermost aquifer under the facility, containing these three parts: • written monitoring plan (including sampling and analysis) ; • installed system of wells; • written outline of a groundwater quality assessment program to be implemented if contamination is found. There must be at least one upgradient well and two down gradient wells (more wells and in different locations, if needed) to immediately detect any "statistically significant waste migration." Initial background levels for all monitoring wells must be established by sampling at least quarterly in the first year. The operator must test each well quarterly during the first year for 31 specified "parameters," including maximum contaminant levels set in the National Interim Primary Drinking Water Standards under the Safe Drinking Water Act (See Table 6) , groundwater quality indicator parameters (chloride, iron, manganese, phenols, sodium sulfate) and 4 groundwater contamination indicator parameters. (Specific conductance, pH, Total Organic Carbon, Total Organic Halogen). Results must be reported to EPA. After the first year, the operator must test quarterly for 6 background water quality parameters and semiannually for 4 parameters that indicate leakage (See Section V. , What Defines Failure?) . Groundwater monitoring requirements have been carefully evaluated and critiqued in a report prepared by OTA (OTA, 1984a) with these findings: • Corrective action isn't required if contamination is found (unlike the standards for permitted facilities) ; only continued monitoring is required; 9C(id -49- TABLE 6 NATIONAL INTERIM PRIMARY DRINKING WATER REGULATIONS Arsenic 0.05 mg/1 Barium 1.0 mg/1 Cadmium 0.010 mg/1 Chromium 0.05 mg/1 Lead 0.05 mg/1 Mercury 0.002 mg/1 Nitrate (as N) 10 mg/1 Selenium 0.01 mg/1 Silver 0.05 mg/1 Fluoride 1.4 - 2/4 mg/1 (ambient temp) Endrin 0.0002 mg/1 Lindane 0.004 mg/1 Methoxychlor 0.1 mg/1 Toxaphene 0.005 mg/1 2,4 - D 0.1 mg/1 2,4,5 - TP (Silvex) 0.01 mg/1 Coliform bacteria < 1/100 ml Radium - 226 + radium -228 5 pCi/1 Gross alpha particle activity 15 pCi/1 Beta particle and photon radioactivity 4 mrem (annual dose equivalent) Turbidity 1 Tu (up to 5 Tu) Trihalomethanes (the sum of the concen- 0.10 mg/1 trations of bromodichloromethane, dibromochloromethane, bromoform and chloroform) NATIONAL SECONDARY DRINKING WATER REGULATIONS Chloride 250 mg/1 Color 15 color units Copper 1 mg/1 Corrosivity Non—corrosive Foaming Agents 0.5 mg/1 Iron 0.3 mg/1 Manganese 0.05 mg/1 Odor 3 threshold odor number pH 6.5 — 8.5 Sulfate 250 mg/1 TDS 500 mg/1 Zinc 5 mg/1 mg/1 : milligrams per liter (ppm) pCi/1: picocuries per liter, a measure of radioactivity mrem : millirem, a measure of absorbed dose Tu : Turbidity Units e.;),. p< —50— • All or part of the requirements can be waived under certain conditions. If, based on a review of certain site conditions, it can be demonstrated that "there is a low potential for migration", the groundwater requirements can be waived. The waiver is made by the facility operator who does not have to report to EPA or the State. However, files must be maintained on-site and available for inspection. CLOSURE AND POST-CLOSURE REQUIREMENTS. Interim status (IS) facilities that close before a permit is issued must comply with IS closure and post—closure requirements. These standards are similar to the permanent program standards, except they don't require more extensive corrective action and groundwater monitoring requirements. Closure is a period after which hazardous waste is no longer accepted. The closure period generally lasts 6 months. Post—closure is the 30—year period after closure when operators of disposal facilities must perform monitoring and maintenance activities. Interim status closure regulations are supposed to ensure that facilities are closed properly to (1) minimize need for further maintenance, and (2) control, minimize, or eliminate post-closure escapes of hazardous wastes or constituents into the environment. There are specific requirements for different technologies as well as general requirements. General requirements include a written closure plan and steps necessary to completely or partially close the facility at any point during its intended operation and at the end of its operating life. When an operator decides to shut down, the plan must be submitted to the EPA Regional Administrator 180 days before closure begins. Comments and hearings may be required. I£ a facility loses interim status or is ordered to stop receiving waste, it must submit a closure plan to EPA in 15 days. POST—CLOSURE PLAN. By May 19, 1981, operators must have a written post—closure plan to identify activities to be carried out for 30 years after closure, at minimum, providing for groundwater monitoring and reporting, planned maintenance on the final cover, containment system and monitoring —51— equipment, plus the identity of the persons responsible for the facility after closure. INTERIM STATUS FINANCIAL RESPONSIBILITY AND INSURANCE STANDARDS. All facilities except those operated by federal or state government must make assurances that money is available to pay for closure and post-closure care and to compensate people for damage caused by "sudden" events (accidents) or "non-sudden" events (e.g. groundwater leaks) . Each facility must have on file a written estimate of closure costs (to be adjusted annually to reflect inflation) showing how it plans to cover its costs through mechanisms like: • a trust fund, • a surety bond guaranteeing payment into a trust fund, • an irrevocable letter of credit, • a financial assets test, or • an insurance policy. INTERIM STATUS STANDARDS FOR LANDFILLS. General facility standards apply to interim status facilities, plus some additional technical standards for groundwater monitoring, financial responsibility, closure and post—closure care. These standards aim to control the usual problems of landfills: fire, explosion, toxic fumes and ground and surface water contamination. Operators must divert rainwater and collect runoff from the active portion of the landfill. Wind dispersion must be controlled, too, if necessary. Ignitable and reactive wastes must be treated or mixed before landfilling so they don't catch fire or explode. Liquid disposal in landfills is limited to prevent leachate; May, 1980 rules ban most liquid waste landfilling, including wastes that contain liquids. Bulk and noncontainerized liquids were accepted for landfills with chemically and physically resistent liners (and leachate collection and removal systems) . Landfilling is allowed for liquids in very small containers (e.g. , capsules) and containers (e.g. , batteries) designed for storage. -52- RECENT CHANGES IN THE REGULATIONS In November 1984, Congress amended RCRA. Highlights: • No landfilling of uncontainerized liquid wastes even with absorbent material added, effective May, 1985; • No land disposal of certain hazardous wastes (See Table 2) within 32 months unless EPA rules that land disposal of these wastes is protective of health; • No solvents and dioxin contaminated wastes within 2 years, unless EPA rules there's no threat to health or the environment (See Table 3) • New, replacement or expanded landfills or impoundments must be double lined with groundwater monitoring and leachate collection. The double liner rule can be met by an EPA—approved alternative design; • Each landfill or surface impoundment Part B application submitted 9 months after enactment (they all must be submitted within 12 months) must have information on potential public exposure to hazardous waste releases. If the application has already been submitted, the company has 9 months to submit an exposure assessment; • Surface Impoundments can't receive hazardous wastes after 48 months unless double lined or unless the primary liner has not failed, and it's more than 1/4 mile from any underground drinking water source and is in compliance with groundwater monitoring rules; • Existing consent orders (prior to 10-1-84) involving impoundments can be modified to reflect changes in these amendments; • Surface impoundment operators must demonstrate no groundwater migration in the future for an exemption from retrofitting requirements; gent-, —53— • Waste prohibited from land disposal and placed in double lined surface impoundment for storage must be cleaned out once a year. • Disposal bans can be waived if pretreatment reduces waste concentrations below trigger levels (See Tables 2 and 3) ; • Banned wastes cannot be stored except to facilitate proper treatment, reuse or disposal; • Air emission standards must be developed within 30 months; • Permits for land disposal sites must be issued or denied within 48 months (November, 1988) ; • Interim status, once terminated, cannot be reinstated; • Owners/operators of land disposal sites must apply for a RCRA Part B permit and certify compliance with groundwater and financial responsibility requirements within 12 months (November, 1985, See Section IX, Hazardous Waste Landfills) ; • In 24 months (November, 1986) , EPA must submit a schedule to Congress (ranked by hazard and volume) for determining restrictions on all remaining hazardous wastes listed by EPA. One—third of the list must be completed in 45 months, 2/3 in 55 months and the rest in 66 months. Determinations for newly listed wastes must be made 6 months after listing. If EPA fails to meet the schedule, the first 2/3 of the list may continue to go into landfills or surface impoundments so long as the operator certifies that no alternative is available. Late action on the last 1/3 results in immediate ban from all forms of land disposal (even those that have low hazard/volume) . (USEPA, 1985e) These new rules are great on paper, but useless unless enforced. EPA is overwhelmed, understaffed and underfinanced. Further, enforcement against corporate polluters is not one of this Administration's priorities. However, —54— SCOr^ P11 it's important to know what your new rights are under these rules (USEPA, 1985e) and how these rules tie in with state requirements (See EDF, 1985) . SOLID WASTE LANDFILLS Solid waste landfills are regulated primarily by State and local requirements. Federal requirements are spelled out in detail in the Criteria for the Classification of Solid Waste Disposal Facilities (USEPA, 1979) and address the following areas: 1. Floodplains 2. Endangered Species 3. Surface Water 4. Groundwater 5. Application on land used for the production of food chain crops. 6. Disease 7. Air 8. Safety In addition, a National Pollution Discharge Elimination Source (NPDES) permit is required for location of a landfill in waters of the U.S, and for any specific "source" discharges, such as landfills (landfill operators can get a permit to discharge collected leachate if they can show that the concentration of the leachate is below discharge limits) . Also, an Army Corps of Engineers permit is required for the construction of any levee, dike or other type of containment structure to be placed at a landill located in US waters (USEPA, 1979). State and local regulations and permits vary widely and often more than one permit is required, such as landfill permits, zoning permits, fugitive dust permit, special use, or sediment control permits. Sometimes both State and local permits may be required. Most State requirements follow the guidance laid out in the federal regulations. The major problem with these regulations is that landfill operators do not have to follow the regulations because they are simply guidelines that establish minimum criteria or performance standards that facilities Allistret -55- if they are to be classified "as posing no reasonable probability of adverse effects on health or the environment" (USEPA, 1979). These criteria are useful in establishing who may or may not be in compliance with the criteria, but they are useless in terms of doing something about it. If a landfill does not meet the criteria, EPA has no authority to force the operator to close down, change operations or anything else that will prevent or stop leakage from the landfill. The regulations give EPA no enforcement power whatsoever. Consequently, only those states that specifically give the power to regulating agencies can do something about poorly managed or leaking sites. SURFACE IMPOUNDMENTS Surface impoundments are regulated according to whether the liquid wastes are hazardous or nonhazardous. Hazardous waste impoundments are subject to the requirements of RCRA Subtitle C (USEPA, 1982) while non hazardous waste impoundments are regulated under RCRA Subtitle D (USEPA, 1979) . In addition local and state reulations are applicable but in most states, no special regulations apply. Design and operating standards for hazardous waste impoundments generally require new ponds to have an "impermeable" plastic liner and that all impoundments must be capped upon closure. Owners of existing impoundments are not required to install liners. New and existing impoundments must be monitored in the upper most aquifer both up gradient and down using a minimum of three monitoring wells. A number a specific inadequacies have been identified in the federal regulations: 1) Owners of existing impoundments are not required to install any type of liners; 2) Owners can get a waiver for liner requirements if they can demonstrate that contamination will "not adversely effect current or et'CC .56 -56- future use of the groundwater". Owners do not have to show that their impoundment will not leak; 3) There are no restrictions on the use of impoundments over aquifers that are currently used for drinking water; 4) Groundwater monitoring is used exclusively to detect seepage and to prevent contamination yet over 602 of RCRA facilities are in violation of groundwater monitoring reqirements (See OTA, 1984a) ; 5) There are no restrictions on the kind of wastes that can be placed in impoundments despite studies that have shown that certain wastes can increase the permeability of liners (See Anderson, 1982) ; and 6) There are no standards or monitoring requirements for air emissions. (CBE, 1983) INTERIM STATUS REGULATIONS. There are some requirements for impoundments operating under interim status. Existing impoundments are required to minimize or control major problems from groundwater leakage, volatile waste air emissions, overtopping and spillage from overfilling, precipitation, run—on, or wind. Standards require surface impoundments to have at least 2 ft of freeboard (the distance from the surface o£ the impoundment to the top of dike) to protect against overtopping. Impoundments with earthen dikes must have protective covering (e.g. grass, rocks, plastic sheeting) to limit erosion and maintain structural integrity. Additional waste analyses are required before the impoundment can be used for new waste or new treatment processes. Ignitable or reactive wastes must be pretreated before dumping to prevent fire and explosion. No incompatible wastes. The freeboard level must be inspected daily to detect and prevent overtopping; weekly inspections for the structure and equipment. Surface impoundments must follow groundwater monitoring rules for interim status facilities. At closure, all wastes, contaminated soils and residues must be removed and sent to an approved treatment or storage facility. If the SI is a disposal facility, it 200sJ��2 q .J —57— must follow final closure procedures similar to those for landfills, meet financial responsibility requirements, and provide post—closure care. LAND TREATMENT Land treatment regulations also differ according to the nature of the wastes. Hazardous waste land treatment is regulated under RCRA subtitle C, 40 CFR Part 264. Design and operating specifications are spelled out in RCRA Guidance Document on Land Treatment (USEPA, 1984a) . Regulations that apply to nonhazardous wastes are the same as those that apply to solid waste landfills (See USEPA, 1979) . Regulations that apply to hazardous waste land treatment were established in 1984 to "ensure that treatment of hazardous constituents by degradation, transportation or immobilization is maximized within the treatment zone" (USEPA, 1984a) . Note that there is no requirement that criteria be followed nor any enforcement mechanism; instead, the following are "guidelines": 1. land treatment sites should be located, designed and constructed so the treatment zone contains soils having one or more of the follow— ing USDA Classifications: loam, silt loam, sandy clay loam, sandy loam, silty clay loam, clay loam; 2. Treatment zone should not contain karst formations (an area of soluble rock which is prone to forming sinkholes or pathways where water movement is faster than the surrounding soil) or irregular features such as fissures, faults, or bedrock outcrops; 3. Waste application rates should be carefully determined by waste prop— erties and treatment zone characteristics. Selected application rate must not exceed the treatment zone's capacity to degrade, transform and immobilize wastes; 4. pH of the treatment zone should always be between 6.0 and 8.0; n rao o_ '23'1 —58— 5. Moisture, fertilization and tilling which affect microbial and chem— ical reactions should be carefully evaluated and enhanced; 6. All design and operating requirements specified in RCRA Guidance Document for land treatment, including collecting and treating run-off, wind dispersal control, aerosol dispersion, or unsaturated zone monitoring, closure and post—closure care, run—on and run—off movement should be followed. See the resource list for how you can get a copy of EPA's Draft RCRA Guidance Document, Land Treatment (USEPA, 1984a) . It contains much more detail. X. TRANSPORT AND STORAGE No matter how you dispose of hazardous waste, there are important transportation and storage issues. Pits, ponds, lagoons, waste piles, stacking barrels, waste transport and transfers from vehicles and storage containers to the site pose threats to people and the environment. Major concerns include: • Transport Accidents. They happen and it seems like it's more often than ever before. The first victims are usually the drivers and others on the roadway. Then come people neighboring the accident site, emergency personnel like police, firefighters, ambulance drivers, medics, cleanup crews; etc. In Somerville, MA, a train derailed, sending 300 people to the hospital and driving 17,000 from their homes. This accident was worsened when firefighters innocently sprayed water on the spill, not knowing that the chemicals would react and release a toxic cloud. The same thing would have happened if it had been raining. • On—site Accidents. Containers can spill, break open or explode when unloaded or transferred. Connections between transfer lines and tanks can rupture. When they do, air, soil and groundwater contamination e r —59— E ah. An explosion could begin a chain reaction With other wastes at the site as it did at the Rollins site in southern New Jersey. Damage and injury could be widespread. • Pits, Ponds and La¢oons. Mixing incompatible wastes can cause explo- sions as it did in Shelby Township, MI or tonic clouds as at Vickery, OH. In Shelby, two workers emptied a waste tank into a lagoon causing a reaction that killed both men and iniured emergency crews that res- ponded. SI liners (if there is one) is another source of trouble, as all liners w-ll eventually leak. Another problem is evaporation. • Placement of Wastes. Combustible, reactive and explosive wastes should be carefully separated so that small, on-site fires don't turn into major disasters, as happened in Elizabeth, NJ„ where thousands were affected by fire, explosion and exposure to fumes at the Chemi- cal Control Corp. conflagration. Further, storing reactive chemicals - in faulty containers can release deadly fumes, Bhopal being the most horrifying example. • LeakinQ Containers, if left undetected or ignored, could damage water supplies, air, health and the environment. A battery salvage and recycling company in Florida ignored its leaking holding ponds and contaminated the nearby creek and threathened drinking water. A state official reported that there was so much acid in the soil that it burned the soles off your shoes. • The operator's financial stability. Ask if the company has the money or coverage to pay for cleanup, health costs and compensation if there is an on or off-site accident. The Somerville accident cost local taxpayers $500,000. - What's the operator's plan for dealing with accidents? - Are emergency personnel (firefighters, hospitals, etc.) prepared. If not, who will train them and who will bear the costs? - Will taxpayers be stuck with costs for cleanup, medical care, devalued property and site maintenance if the company leaves or goes_ bankrupt? 90055 -60-- — Is there an emergency response plan to cover most emergency situations? Does the emergency plan include evacuation procedures? %I. ALTERNATIVES Even in the face of evidence that landfills fail, there are always those who argue, "well, we've got to put it somewhere," especially municipal waste. Not necessarily true. Alternatives do exist for hazardous wastes. California's Office of Appropriate Technology and OTA both report that over 80% of land—disposal wastes could be managed by other methods. Both conclude that the continued availability of cheap (but dangerous) land disposal methods (e.g, landfills, deep wells) holds back progress toward the wider use of alternatives. When the incentive to dump changes, so will industry's disposal practices (See resource list, OAT, 1981 and OTA, 1983) . Alternatives include: — Recycling on—site to reuse valuable wastes constituents. — Waste reduction at the source using primarily process changes. — Separation, segregation, concentration eases reduction and recycling. — Waste treatment including chemical, biological and physical means and neutralization to eliminate hazardous components. — Innovative destruction methods (e.g plasma arc, Hubar, Modar systems) — Waste Exchange: one generator trades waste to another as a resource. — Stabilization and fixation processes. — Energy production or recovery. — Product and process substitution that use less toxic intermediates. — Ban production of hazardous wastes that can't be properly disposed of. — Chemical/physical treatment. — Above ground storage and retrieval when permanent treatment methods are available and/or cost effective. — Microbial degradation. Municipal waste can be recycled too, but it takes commitment and the will to adopt comprehensive waste management programs. There are success stories: in Berlin Township, NJ, 25% of its waste is recycled; 35% in SC C5(34 —61— Woodbury, NJ and 75% in Berkeley, CA. The NJ State Advisory Committee on Recycling estimates the state can recycle 55% of municipal garbage through curb—side collection. Based on just these few examples, recycling benefits are obvious. Recycling can reduce disposal costs, save precious resources, save energy and offer new supplies of materials (e.g. aluminum, glass, paper) . Specific alternatives include: • Recycling and reuse of materials • Methane Production • Source/mechanical separation • composting/land farming (see section on land farming) • starved air combustion (wet oxidation) • pyrolysis • in—process changes that result in less waste generation • source reduction • premanufacturing testing • changes in consumer buying patterns Eti 0564 —62— XII. GLOSSARY ANAEROBIC — Able to live or grow in the absence of oxygen; generally bacteria. AQUIFER — Underground geological formations (rocks) that hold or contain water. BACRFILL — Material, usually dirt, used to refill a ditch or other excavation. BALER — A machine used to compress or bind together municipal solid waste. CFT.T — An area of a landfill where wastes are placed. CLOSURE — The period after which hazardous wastes are no longer accepted at a site, the site is closed and the cover or other closing operations are in progress. Usually lasts about 6 months. COVER MATERIAL — Soil used to cover wastes in a landfill. FLOOD PLAIN — Lowlands and relatively flat areas adjoining waterways. FRACTURED BEDROCK — A crack, space or separation in the bedrock that provides a "pipeline" or pathway for groundwater to move faster than in the surrounding rock. FREEBOARD — The distance from the surface of an impoundment to the top of the dike. INTERIM STATUS — A permit condition applying to all waste facilities which filed an application and were in operation as of November 19, 1980. Interim Status continues until a final permit is issued by EPA (See Section IX. of text). C Sri —63— • RARST FORMATIONS — Formations os soluble rock, such as limestone, which is prone to forming sinkholes and other pathways or regions where groundwater movement is faster than in the surrounding soil. LEACHATE — A mixture of chemicals and water formed by rain, snow, surface water, groundwater or other sources of water entering or formed in a landfill, surface impoundment or other land disposal method. LIFT - A compacted layer of wastes in a municipal landfill; also the top layer of cover material. LYSIMETER - A device used to collect a sample of leachate moving through unsaturated soil below a landfill or land treatment site. Lysimeters measure the amount or rate of leachate movement in a landfill. OPEN DUMP - A landfill site where wastes are simply left uncovered on top of dirt. All sites which do not comply with EPA solid waste criteria (See Section IX.) are considered open dumps. PERFORMANCE STANDARDS — Non—specific standards which require only that minimum criteria be achieved. How they are achieved is unspecified and left to the site operator. POINT SOURCE — Any specific discharge of contaminated water (leachate) including pipes, ditches, tunnels, conduits, wells, seeps, etc. POST CLOSURE — The 30 year period following the closing of a waste facility. Monitoring and maintenance is required during this period. SAND LENSE — An area of sand sandwiched between soil of different makeup, such as clay, that provides a "pipeline" or pathway for groundwater to move faster than the surrounding soil. SANITARY LANDFILL - A site where household garbage is buried in land usually by spreading the waste in then layers, compacting and covering with soil at the end of each day. Also referred to as municipal landfills and town dumps. SC 0554 -64- SECURE LANDFILL — Sites where chemical wastes are disposed of that are supposed to allow no waste or leachate to come into contact with water and thus an attempt to isolate the wastes. All secure landfills have • been shown to leak (See Sections III. and V.) and thus are not in fact secure. Also referred to as chemical, engineered, or scientific landfills. SHREDDER — A machine used to reduce the volume of municipal wastes, by pulverizing, milling, grinding or other size—reduction processes. The resulting product is relatively homogeneous and has certain advantages for land filling. SUBSIDENCE — Settling of wastes in a landfill caused by degradation of wastes which create air spaces or voids which collapse under the weight of material above them. TOPOGRAPHY — The elevations and slopes of the surface of an area. TRANSFER STATION — A site where municipal wastes are stored and concentrated, then taken to a processing facility or landfill. VECTOR — A carrier of disease, usually a rodent, bird or mosquito. WASTE PILE — Wastes stored or dumped in piles, whether covered or closed. C E55 7 —65— APPENDIX A - PARTICIPANTS SC 0564 PARTICIPANTS FOR LANDFILL ROUNDTABLE Kirk Brown* Norman Carl Texas A & M University 2774 Craig Road Dept. of Soil and Crop Sciences Springfield, OH 45502 College Station, T% 77843-2474 (513) 325-0341 Hugh Coombs Verna & Victor Courtemanche R.E.S.C.U.E. 8189 South Marrish Road Rd #1, Box 31A Swartz Creek, MI 48473 Hallstead, PA 18822 (313) 635-9497 (717) 879-2895 John Daines Susan Egan 410 Aberdeen Road EDF Lewiston, NY 14092 1525 18th Street, N.W. (716) 754-7004 Washington, DC 20036 (202) 387-3500 Alison Fiocchi Willie Fontenot* D.U.M.P. Department of Justice Indiana Cabin Road Land and Natural Resource Division Sweetwater, NJ 08037 7434 Perkins Road (609) 567-1015 Baton Rouge, LA 70808 (504) 922-0187 Esther Forbes Sandra Hardy FORGE Citizens For A Clean Environment Rt. #2, Box 229 Rt. #1, Box 1585 Summerduck, VA 22742 Willow Springs Road (703) 439-3541 Sulphur, LA 70663 (318) 527-7053 Kathy Hadley Jim Hilbert Clark River Coalition 125 Erie Avenue 607 Oregon Street Rockaway, NJ 07866 Deerlodge, MT 59722 (201) 625-9147 (406) 846-1125 Laura Kaffenbarger Charles Lee Citizen For Wise Action Toward UCC — Commission For Racial Justice Environmental Resources 105 Madison Avenue 6470 Terra Haute Road New York, NY 10016 Urbana, OH 43078 (212) 683-5656 (513) 969-8549 S0055.4 David Lennett Jennifer Mathews EDF Citizens for a Clean Environment 1525 18th Street, N.W. Rt. 1, Box 1609 Washington, DC 20036 Sulfur, LA 70663 (202) 387-3500 (318) 527-5315 Peter Montague* Pat Nichols 3A Magie — Faculty Road 5212 Curry Ford Road, #203 P.O. Box 3541 Orlando, FL 32806 Princeton, NJ 08540 (305) 281-4955 (609) 683-0341 Marge Peary Mary Russo 220 Old Brookville Road Maryland Waste Coalition Barnegat, NJ 08005 845 North Shore Drive (609) 698-1182 Glen Burnie, MD 21061 (301) 255-7021 or 7026 Bill Sanjour Boo Setti USEPA Remington, VA 22734 401 M Street, S.W. , (WH-563) (703) 439-3662 Washington, DC 20460 (202) 382-4502 Rita Shiflet Ken Silver A.C.T.I.O.N. Clean Water Action Project c/o Circleville Medical Association 733 15th Street, N.W. 111 Island Road Washington, DC 20005 Circleville, OH 43113 (202) 638-1196 (614) 474-2444 Cora Tucker* Marvin Wanatek Rural Advancement Fund Environmental Action National Sharecroppers Fund 1525 New Hampshire Avenue, N.W. Box 356 WATS Project Halifax, VA 24558 Washington, DC 20036 (804) 476-7757 (202) 745-4870 Stephanie Wauters Yvonne Woodman Ocean City Citizens For Clean Water Concerned Citizens Against Contam- 942 Tunesbrook Drive inated Water Toms River, NJ 08753 9084 Hipps Road (201) 929-9272 Jacksonville, FL 32238 (904) 722-8369 Fran Zwenig Environmental Safety 1519 New Hampshire Avenue, N.W, D Washington, DC 20036r'E, , (202) 328-7903 * Did Not Attend APPENDIX B - WRITTEN RESOURCES 900%4 LAND DISPOSAL RESOURCES I. References Used in Text * (Anderson, 1982) Does Landfill Leachate Make Clay Liners More Permeable? David Anderson, Civil Engineering — ASCE, pp 66-69, September, 1982. Available from K.W. Brown Associates, 64 Graham Road, College Station, TX 77840. * (ASTSWMO) National Solid Waste Survey, Association of State and Territorial Solid Waste Management Officials (ASTSWMO) , October, 1984. Available From ASTSWMO, 444 North Capitol Street, N.W. , Washington DC 22201, (202) 624-5828. * (Brown, 1986) Personal communication with KW Brown, Texas A & M University, Department of Soil and Crop Sciences, College Station, TX, 7843-2474. * (CBE, 1983) Hazardous Waste Surface Impoundments — The Nation's Most Serious and Neglected Threat to Groundwater, A Summary of Major Studies and Evaluations, Citizens For A Better Environment (CBE) , Natural Resources Defense Council, Sacramento Toxics Alliance, Sacramento Tapwater Action Committee and Coalition on Environmental and Occupational Health Hazards, September 15, 1983, 49 pages. Available from Toxics Assessment Group, 2530 J Street Suite 200, Sacramento, CA 95816. * (CDM, 1985) On—Site Feasibility Study for Lipari Landfill, EPA Contract No 68-01-6939, Prepared For EPA Region II By Camp Dresser and McKee, Inc, Clement Associates, Inc, Woodward—Clyde Consultants, August 1985, Available from EPA Region II, Federal Plaza, New York NY 10278. * (EDF, 1985) State Regulation of Hazardous Waste, D. Lennette and L. Greer, Ecology Law Quarterly, Vol (2 No (2) , 183-269, 1985. Available from Environmental Defense Fund, 1526 18th Street, N.W. , Washington, DC 20036 (202) 387-3500. * (GAO, 1983) Interim Report On Inspection, Enforcement and Permitting Activities At Hazardous Waste Facilities, US General Accounting Office, Report # GAO/RCED-83-241, September 21, 1983. Available From GAO, Document Handling and Information Services Facility, P.O. Box 6015 Gaitherburg, MD 20760, (202) 275-6241. * (GAO, 1981) Hazardous Waste Facilities With Interim Status May be Endangering Public Health and the Environment. Report by the Comptroller General' of the United States, US General Accounting Office, Report No. CED-81-158, September 28, 1981. Available from GAO, Document Handling and Information Services Facilities, PO Box 6015, Gaithersburg, MD 20877 (202) 275-6241. * (Montague, 1982) Hazardous Waste Landfills: Some Lessons From New Jersey. Dr. Peter Montague. Civil Engineering. — ASCE, pp 53-56, September, 1982. Available from CCHW at .15/page. B_1 S 0O64 * (Montague, 1982a) Dr. Peter Montague, Princeton University, Testimony before the House Subcommittee on Commerce, Transportation and Tourism of the Committee on Energy and Commerce, Serial No. 97-169, March 31, 1982, 11 pages. Available from CCHW at .15/page. * (NAS, 1983) Management of Hazardous Industrial Wastes: Research and Development Needs, By the National Materials Advisory Board, National Research Council of the National Academy of Sciences, March, 1983. Available from NMAB, 2101 Constitution Avenue, N.W. , Washington, DC 20418 (202) 334-3505. * (NYSDEC, 1985) Upstate Groundwater Management Report, New York Bureau of Water Resources, New York State Department of Environmental Conservation, February, 1985. Available from NYSDEC, BWR, 50 Wolf Road, Room 328, Albany, NY 12233 (518) 457-3495. * (OAT, 1981) Alternatives to the Land Disposal of Hazardous Wastes. An Assessment for California. Prepared by the Toxic Waste Assessment Group, Governor's Office of Appropriate Technology, State of California, 1981. Available from Publications and Information, OAT, 1600 Ninth Street, Sacramento, CA 95814 (916) 323-8133. * (OTA, 1985) Superfund Strategy, US Congress, Office of Technology Assessment, 1985, Available From OTA, US Congress, Washington, DC 20510 (202) 226-2115. * (OTA, 1984) Where have all the Superfund Wastes Gone, Memorandum From W. Sanjour To Joel Hirschhorn, Office of Technology Assessment, May 17, 1984, 7 pages. Available from CCHW at .15/page. * (OTA, 1984a) Are RCRA Groundwater Protection Standards Adequate to Prevent New Uncontrolled Sites? OTA Staff Memorandum, April 1984, 72 pages. Available from OTA Industry, Technology and Employment Program, US Congress, Washington, DC 20510. * (OTA, 1983) Technologies and Management Strategies for Hazardous Waste Control, Congress of the United States, Office of Technology Assessment, 1983. Available From OTA, US Congress, Washington, DC 20510, (202) 226-2115. * (Princeton University, 1983) Review and Evaluation of Monument Street (Baltimore) Landfill, Water Resources Program, Princeton University, Departments of Civil Engineering and Geological and Geophysical Sciences, April, 1983, 114 pages. Available from the Office of Environmental Program, Maryland Department of Health and Mental Hygiene, 201 West Preston Street,Baltimore, MD 21201. * (USEPA, 1985) Summary Report on RCRA Activities, US Environmental Protection Agency (USEPA), Office of Solid Waste and Emergency Response, July, 1985, 18 pages. Available from EPA, 401 M Street, S.W. , Washington, DC 20460 (202) 382-4753. * (USEPA, 1985a) Types of Activities at Final and Proposed Superfund Sites, US EPA, December 17, 1985, 1 page. Available from CCHW at clime ,-r. 4Z .15/page. gy '3 B-2 * (USEPA, 1985b) Sanjour, W. US EPA Office of Solid Waste and Emergency Response, Memorandum to Scott Schwarz, Deputy District Attorney, Fifteenth Judicial Circuit of Alabama, January 10, 1985, 15 pages. Available from CCHW at .15/page. * (USEPA, 1985c) US EPA Press Release on Compliance With Financial Responsibility Requirements, December 6, 1985. Available from US EPA Office of Public Affairs 401 M St. SW, Washington, DC 20460. * (USEPA, 1985d) Certifications Received To Retain Interim Status . Pursuant to Section 3005 (e)(2) of RCRA Summary Results, US EPA Office of Solid Waste, December 6, 1985, 125 pages. Available from RCRA Superfund Hotline (WH-563) US EPA Office of Solid Waste, 401 M Street,SW, Washington, DC 20460, (800) 424-9346. * (USEPA, 1985e) Summmary 1984 Amendments to Resource Conservation and Recovery Act, USEPA, Office of Solid Waste, January 31, 1985, 17 pages. Available from USEPA, OSW (WH-562), 401 M Street, SW, Washington, DC 20460. * (USEPA, 1984) National Survey of Hazardous Waste Generators and Treatment, Storage and Disposal Facilities Regulated Under RCRA in 1981. Prepared For The US EPA Office of Solid Waste by Westat, Inc. , April 1984. Available from US EPA, Office of Solid Waste, 401 M Street, S.W. , Washington, DC 20460. * (USEPA, I984a) Groundwater Protection Strategy, USEPA, Office of Groundwater Protection, August, 1984. Available from USEPA. Office of Groundwater Protection (WH 550G) , 401 M Street, SW. , Washington, DC 20460 (202) 382-7077. * (USEPA, 1984b) RCRA Guidance Document Land Treatment Draft. USEPA, 1984, 67 pages. Available from CCHW at .15/page. * (USEPA, 1983) Surface Impoundment Assessment National Report, USEPA Office of Drinking WAter (EPA 570/9-84-002) , December, 1983, 204 pages. Available from USEPA, Office of Drinking Water, 401 M Street,S.W. , Washington, DC 20460. * (USEPA, 1982) Hazardous Waste Management Systems, Permitting Requirements for Land Disposal Facilities, US EPA, Federal Register, Part II, July 26, 1982. Available from EPA, 401 M Street, S.W. , Washington, DC 20460. * (USEPA, 1981) Hazardous Waste Management System, Standards Applicable to Owners and Operators of Treatment, Storage and Disposal Facilities and Permit Program, US EPA. Federal Register, Part II, February 5, 1981. Available from EPA, 401 M Street, S.W. , Washington, DC 20460. * (USEPA, 1981a) Solid Waste Landfill Design and Operation Practices, Draft, Prepared by SCS Engineers under contract 68-01-3915 for USEPA, April 1981, 208 pages. Available from USEPA, Office Of Solid Waste, 401 M Street, S.W. , Washington, DC 20460. SC0561 B-3 * (USEPA, 1979) Criteria For Classification of Solid Waste Disposal Facilities and Practices; Fund, Interim Final and Proposed Regulations, USEPA Federal Register, Vol. 44, No. 179, Thursday, September 13, 1979, pp. 53438-468. * (USEPA, 1978) Surface Impoundments and Their Effects On Groundwater Quality in the United States — A Preliminary Survey, USEPA, Office of Drinking Water (EPA 570/9-78-004), June, 1978, 276 pages. Available from EPA Office of Drinking Water Groundwater Protection Branch, 401 M Street, S.W. , Washington, DC 20460. * (USEPA, 1977) Waste Disposal Practices and Their Effects On Groundwater — The Report To Congress, USEPA, Office of Water Supply, pp. 108-143, January 1977. Available from CCHW at .15/page; full report available from USEPA Office Of Solid Waste Management Programs, 401 M Street, S.W. , Washington, DC 20460. * (USEPA, 1972) Sanitary Landfill: Design and Operation, Dick Brunner and Daniel Keller, USEPA (SW-287), 1972. Available from USEPA, Office of Solid Waste, 401 M St. , SW, Washington, DC 20460. * (Washington Post, 1985) "Inmates Moved After Lorton Blasts May Be Returned At End of Month," Washington Post, January 4, 1985. II. Resource Materials on Hazardous Waste Landfills • Organic Leachate Effects on the Permeability of Clay Liners. D.C. Anderson, R.W. Brown, and J.D. Green, Appeared in the Proceedings of the National Conference on Management of Uncontrolled Hazardous Waste Sites. October 28-30, 1981. Available from CCHw at .15/page. • Landfills of the Future, K.W. , Brown Soil and Crop Science Dept. , Texas A & M University, December 15, 1982. Available from R.W. Brown & Associates, Inc. , College Station, Texas 77843. • State Action to Reduce Land Disposal o£ Toxic Wastes, a Discussion Paper. Prepared by the Interagency Task Force for Reduction of Land Disposal of Toxic Wastes, State of California Department of Health Services, 10 pages, January, 1982. Available from CCHW at .15/page. • Land Disposal Restrictions, Statement of Reasons for Proposed Regulations, prepared in response to Governor Brown's Executive Order B-8881, State of California, 22 pages, October 13, 1981. Available from CCHW at .15/page. • Hazardous Waste Disposal Methods: Major Problems With Their Use. Report by the Comptroller General.of the United States, US General Accounting Office (GAO) , Report No. CED-81-21, November 19, 1980. Available from GAO, Document Handling and Information Services Facilities, PO Box 6015, Gaitherburg, MD 20877 (202) 275-6241. • Clay-Soils Permeability and Hazardous Waste Storage. William Green ' F. Fred Lee, and R. Anne Jones. Journal Water Pollution Control A Y 2 Federation 53: 1347-1354 (1981). B-4 • Clay Liners in Common Use For Hazardous Waste Disposal Landfills — How Long Will They Last/Can They Be Improved? Lehigh University Research Team, October 24, 1984, 4 Pages. Available from Office of Public Information, William Arnold, Director, 436 Brodhead Avenue, Bethlehem, Pennsylvania 18015, (215) 861-3170. • Four Secure Landfills in New Jersey--A Study of the State of the Art in Shallow Burial Waste Disposal Technology, Draft, Dr. Peter Montague, Department of Chemical Engineering and Center for Energy Env. Studies Sch, of Eng./Applied Sci. , Princeton University, 90 pages, 1981. Available from Peter Montague 3A Magie—Faculty Rd. PO Box 3541, Princeton, NJ 08540. • Hazardous Waste Landfills — Can Clay Liners Prevent Migration of Toxic Leachate? Allen Morrison. Civil Engineering — ASCE pp 60-63, July 1981. Available from CCHW at .15/page. • William Sanjour, USEPA, Testimony before the House Subcommittee on Natural Resourses, Agricultural Research and Environment of the Committee on Science and Technology, November 30, 1982, 25 pages . Available from CCHW at .15/page. • Nowhere To Go, The Universal Failure of Class I Hazardous Waste Dump Sites In California, Prepared By Toxics Assessment Group For Environmental Defense Fund, June 1985, 90 pages. Available from EDF, 2606 Dwight Way, Berkeley, CA 94704, (415) 548-8906. • A Methodology to Inventory, Classify, and Prioritize Uncontrolled Waste Disposal Sites, Project Summary, Nelson, AB, Hartshorn, LA and Young, RA, USEPA Environmental Monitoring Systems Laboratory, Report # EPA-600/54-83-050, 4 pages, December, 1983. Summary available from CCHW at .15/page; full report available from USEPA, EMSL, Los Vegas 89114. • Draft RCRA Guidance Document Landfill Design, Liner Systems and Final Cover. US EPA Issued 7/82, (33 Pages, Plus Appendices) . Available from USEPA Office of Solid Waste, 401 M Street, SW, Washington, DC 20460. • Listing of Hazardous Waste Landfills - On-Site/Off-Site - in the United States as of May 19, 1982, Interim Status, "Part A" Facilities, USEPA, 12 Pages. Available from CCHW at .15/page. • Land Disposal of Hazardous Waste, Proceedings of the Eighth Annual Research Symposium (EPA-600/9-81-002) 37 papers, 549 pages, March 1982. Available from USEPA Office of Research and Development/Publications, Center for Environmental Research Information, Cincinnati, OH 45268. • Hazardous Waste Management, Interim and Proposed Regulations, US EPA, Federal Register, Part II, February 25, 1982. Available from EPA, 401 M Street, S.W. , Washington, DC 20460. • Land Disposal: Hazardous Wastes, Proceedings of the Seventh Annual Research Symposium (EPA-600/9-81-002a) 35 papers, 399 pages, March, 1981. Available from USEPA Office of Research and Development/ Publications, Center for Environmental Research Information, Cincinnati, OH 45268. B-5 • Land Disposal of Solid Wastes, Section VII of the Report to Congress Waste Disposal Practices and Their Effects on Groundwater, USEPA, pp. 144-185, 1977. Section VII available from CCHW at .15/page; full report available from USEPA, Office of Water Supply, 401 M St. SW, Washington, DC 20460. III. Resource Materials on Solid Waste Landfills • "What Lurks Within Your Town Dump? Is It As Innocent As It Appears?" Everyone's Backyard, Vol. 2, No. 1, Winter, 1983. Available from CCHW, PO Box 926, Arlington, VA 22216. • "Time to Stop Burying Solid Waste.": Natural Resources Register Vol. 5 (6). , June 1985, 6 Pages. Available from the Department of Natural Resources, Community Assistance Division, Resource Recording Section, P.O. Box 30028, Lansing, MI 48909, (517) 373-0540. • Some Municipal Waste Landfills Rival Industrial Ones in Toxicity, Research Report, Robert L. Haney, Science Writer, The Texas Agricultural Experiment Station, Neville P. Clarke, Director, The Texas A & M University, October 23, 1985, 1 Page. Available from Science Writer, Department of Agricultural Communications, Texas A & M University, College Station, TX 77843 or CCHW at .15/page. • Solid Waste Data, A Compilation of Statistics on Solid Waste Manage— ment Within the United States, Prepared By JRB Associates For USEPA Under Contract NO 68-01-6000, August, 1981, 72 pages. Available from USEPA, Office Of Solid Waste, 401 M Street, S.W. , Washington, DC 20460. • "Toxic Time Bombs" in Agenda for Citizen Involvement, NYPIRG, Vol IV No. No. 2, March/April 1983, 15 Pages. Available from NYPIRG, 9 Murray Street, New York, NY 10007, (212) 349-6460. • Assessment of Liner Materials for Municipal Solid Waste Landfills. A technical paper from Land Disposal: Municipal Solid Waste, Proceedings of the Seventh Annual Research Symposium, USEPA (EPA-600/9-81-002a) 26 pages, March, 1981. Paper available from CCHW at .15/page; full report available from USEPA, MERL, Office of Research and Development, Cincinnati, OH 45268. • Draft Environmental Impact Statement on the Proposed Guidelines For The Landfill Disposal of Solid Waste, USEPA, Office of Solid Waste, March 1979. Report No. SW-769. Available from the USEPA, Office of Solid Waste, 401 M Street, S.W. , Washington, DC 20460. • Decision Makers Guide in Solid Waste Management, USEPA Office of Solid Waste (SW-500) 158 Pages, 1976. Available From USEPA Office Of Solid Waste, 401 M Street, S.W. , Washington, DC 20460. • "Landfill Closure and Long-term Care" Waste Age, October 1981, 7 Pages. Available from CCHW at .15/page. • "Sanitary Landfill Site Design" Waste Age, Landfill Course, August 1981. Available from CCHW at .15/page. 499(253 B-6 • "Landfill Site Selection" Waste Age, June 1981, 9 Pages, Available from CCHW at .15/page. • "Gas and Leachate Movement" Waste Age, Landfill Course, May, 1981, Available from CCHW at .15/page. • "Land Disposal of Solid Waste" Waste Age, Landfill Course, April 1981, 7 Pages. Available from CCHW at .15/page. IV. Resource Materials on Surface Impoundments • Is Our Water Safe To Drink? Assembly Office of Research State of California, April, 1983, 135 pages. Available from Assembly Publications Office, Box 90, State Capitol, Sacramento, CA 95815. • Lining of Waste Impoundment and Disposal Facilities, USEPA Office Of Water and Waste Management (SW-870) September 1980, 204 pages. Available from USEPA Municipal Environmental Research Laboratory (MERL) Office of Research and Development, Cincinnati, OH 45268. • Landfill and Surface Impoundment Performance Evaluation, USEPA Office Of Water and Waste Management, (SW-869) September 1980, 63 pages. Available from USEPA, MERL, Solid and Hazardous Waste Research Division, Cincinnati, OH 45268. V. Resource Materials on Land Treatment • Hazardous Waste Land Treatment, Brown, R.W. , G.B. Evans and B.D. Frenthrup, (eds.) 1983, 692 pages. Available from Butterworth Publishers, 10 Tower Office Park, Woburn, MA 01801 • Land Farming — Design Criteria, Chapter in The Handbook Of Hazardous Waste Management, Metry, A, ed, pp-396-400, Technomics Publishing Co. Westport, CT, 1980. Available from CCHW at .15/page. • Use and Disposal of Municipal Wastewater Sludge. Environmental Regulations and Technology, Guidance Document, USEPA, Intra Agency Sludge Task Force, (EPA 625/10-84-003), September, 1984, 76 pages. Available from USEPA Center For Environmental Research Information, Office of Research Program Management Office of Research and Development, Cincinnati, OH 45268. • Annotated Literature References On Land Treatment of Hazardous Waste, Galegar, W.W. and Tillman, B.J. Project Summary, USEPA (Robert S. Kerr, Environmental Laboratory (EPA-600/52-84-098) , June, 1984, 2 pages. Summary available from CCHW at .15/page; full report available from M.L. Wood, Robert S. Kerr Environmental Research Lab, USEPA, P.O. Box 1198, Ada, OK 74820. • Process Design Manual For Land Treatment of Municipal Wastewater. USEPA, US Army Corps o£ Engineers, US Dept. Interior, US Dept. Agriculture, EPA Report # (625/1-81-013) , USEPA Center For Env. Response Information, Cincinnati, OH, October 1981. B-7 cl e.C f..tS/Ot • A Guide to Regulations and Guidance for the Utilization and Disposal of Municipal Sludge, USEPA, Office of Water Program Operations (WH-547), (EPA-430/9-80-115; MCD-72) September, 1980, 48 pages. Available from General Services Administrations (BBRC) Centralized Mailing Lists Services, Building 41, Denver Federal Center, Denver, CO 80225. • Cost of Land Treatment Systems (MCD-10) USEPA, Office of Water Program Operations (WH-547) , EPA Report # (430/9-75-003), September, 1979. Available from USEPA 401 M Street, S.W. , Washington, DC 20460. • Municipal Sludge Management: Environmental Factors. Construction Grants Program Requirements (EPA 430/9-77-004 MCD-28) . USEPA, Office of Water Program Operations, October 1977, 30 pages. Available from USEPA, Office of Water Program Operations, 401 M Street, S.W. , Washington, DC 20460. • Long—term Land Treatment — Are There Health or Environmental Risks, Reed, S. Thomas R and Rowal, N. , USEPA, (Undated) 37 pages. Available from CCHW at .15/page. ADDITIONAL READINGS Hazardous Waste Landfills • "Barrier—Leachate Compatibility", David Anderson, Hazardous Materials Control Research Institute, November 8, 1984, 86 pages. Available from R.W. Brown & Associates, Inc. , College Station, Texas 77843. • Prohibition on Landfilling of Halogenated Solvents, J.Anderson, Illinois Pollution Control Board, August, 1984, 41 pages. Available from IPCB, Illinois EPA, Chicago, Illinois 60601. • Potential Clogging of Landfill Drainage Systems, Bass JM, Ehrenfield JR, and Valentine JN, EPA Project Summary Report # EPA 600/52-83-109, February, 1984. Summary available from CCHW at .15/page; full report available from EPA, Municipal Environmental Research Laboratory, Cincinnati, OH 45268. • Fact Sheet on Hazardous Waste Landfills, Citizens Against Chemical Toxins in Underground Storage (CACTUS), Anson County, NC, September, 1982, 9 pages. Available from CACTUS, Bonnie Morgan, P.O. Box 1062, Wadesboro, NC 28170. • Liners of Natural Porous Materials to Minimize Pollutant Migration, Wallace H. Fuller, EPA Project Summary Report # EPA-600/52-81-122, July 1981, 5 pages. Summary available from CCHW at .15/page; full report available from Municipal Environmental Research Laboratory, Cincinnati, OH 45268. • Environmental Impact Evaluation of Hazardous Waste Disposal in Land: Joseph L. Pavoni et. ed, Water Resources Bulletin, Volume 8, No. 6, December 1972, 17 pages. Available from CCHW at .15/page. V,e arr < B-8 • Performance Difficulties of "Secure" Landfills For Chemical Waste and Available Mitigation Measures, Peter N. Skinner. Appeared in The Hazardous Waste Dilemma: Issues and Solutions, 1980 Conference of Environmental Engineering Division of the American Society of Civil Engineers, New York, 1981. • Treatment of Reactive Wastes at Hazardous Waste Landfills, EPA Project Summary, Report # EPA-600/52-83-118, January 1984, 4 pages. Available from USEPA, Municipal Environmental Research Laboratory, Cincinnati, OH 45268. • Landfill Disposal of Hazardous Waste: A Review of Literature and Known Approaches, USEPA, September 1975, Timothy Fields, Jr. and Alfred W. Lindsay, 36 pages. Available from Solid Waste Information, USEPA, Cincinnati, Ohio 45268. Solid Waste Landfills • Municipal Solid Waste Disposal . . . How Cities Site Landfills. National League of Cities. United States Conference of Mayors. Prepared in Part By the Office of Solid Waste Management Programs, USEPA, Under Grant No. T906607010, 1977, 71 pages. Available from CCHW at .15/page. • Comparisan of Leachate Characteristics from Selected Municipal Solid Waste Test Cells, EPA Project Summary, Richard J. Wigh, Municipal Environmental Research Laboratory Report Number EPA-600/52-84-124, September 1984, 4 pages. Summary available from CCHW at .15/page. • Production and Management of Leachate From Municipal Landfills: Summary and Assessment, EPA Project Summary, Lu, Eichenberger, Stearns, Melnyk, Municipal Environmental Research Laboratory, Report # EPA-600/ 52-84-092, September 1984. Summary available from CCHW at .15/page. • Field Verification of Liners From Sanitary Landfill, EPA Project Summary, Report # EPA-600/52-83-046, August 1983, 5 pages. Available from Municipal Environmental Research Laboratory, Cincinnati, Ohio 45268. • Land Disposal: Municipal Solid Waste. Proceedings of the Seventh Annual Research Symposium. USEPA Report No. 600/9-81-002a, March 1981. Available from USEPA, Office of Research and Development/ Publications, Municipal Research Laboratory, MRL, Cincinnati, OH 45268. • Leachate Production and Management From Municipal Landfills: Summary and Assessment, A Technical Report From Land Disposal: Municipal Solid Waste, Proceedings of the Seventh Annual Research Symposium, USEPA, 1481, 18 pages. Full report available from MRL, Cincinnati Ohio 45268, or report alone from CCHW at .15/page. • Leachate Production by Landfilled Processed Municipal Wastes. A Technical Report from Land Disposal: Municipal Solid Waste, Proceedings of the Seventh Annual Research Symposium, USEPA, 1981, 20 pages. Full report available from MRL, Cincinnati, OH 45268, or report alone from CCHW at .15/page. CR•��'R'"Fw B-9 • Technology, Prevalence and Economics of Landfill Disposal of Solid Waste, USEPA Report # SW-754, December 1980. Available from USEPA Office of Water Waste Manag. 401 M Street, S.W. , Washington, DC 20460. • Environmental Impact Statement. Criteria For Classification of Solid Waste Disposal Facilities and Practices, USEPA, Office of Solid Waste, Report No. SW-821, December 1979. Available from USEPA Office of Solid Waste, 401 M St. SW, Washington, DC 20460. • Municipal Solid Waste, USEPA, Report No. SW-843, reprint from The Tenth Annual Report of the Council on Environmental Quality, December, 1979, 59 pages. Available from USEPA, Office of Solid Waste, 401 M St. SW Washington, DC 20460. • Guide to Landfill Equipment, Waste /Lee, August 1981, Pages 100-107, Available from CCHW at .15/page. Land Treatment • The Potential For Using Municipal Wastewater and Sludge in Land Reclamation and Biomass Production as an Innovative and Alternative Technology: An Overview, Bastian, RR, Montague, A, Numbers, T. , pp 13-54, Pennsylvania Mine Reclamation (Undated Rerint) . Available from R. Bastian, USEPA, Office of Water Program, 401 M Street, S.W. , Washington, DC 20460. • Land Treatment Field Studies, Berkowitz, J. Bysshe, S.E. , Goodwin, BE, Harris, JC, Land, DB Leonardos, G. and Johnson, S. Project Summmary USEPA, Municipal Environmental Research Laboratory (EPA-600/52-83-057) 4 pages, September, 1983. Summary available from CCHW at .15/page; full report (Six Volumes) available from Robert Landreth, MERL, USEPA, Cincinnati, OH 45208. • A Survey of Existing Hazardous Waste Land Treatment Facilities in The United States, R. W. Brown and Associates, Inc. 1981. Submitted to the USEPA Under Contract No. 68-03-2943. • Land as a Waste Management Alternative, Loehr, R. C. (ed.) 1976. Ann Arbor Science Publications, Inc. , Ann Arbor, Michigan, 811 p. • Design of Land Treatment Systems For Industrial Wastes—Theory and Practice, Overcash, M.R, and D. Pal. , 1979. Ann Arbor Science Publications, Inc. , Ann Arbor, Michigan, p. 481-592. • Land Treatment and Disposal of Municipal and Industrial Wastewater, Sanks, R. L. and T. Asano (eds.), 1979, Ann Arbor Science Publications, Inc. , Ann Arbor, Michigan, 300 p. • Sludge Disposal by Landspreading Techniques, Torrey, S. , 1979, Noyes Data Corp. , New Jersey, 372 p. ; C e5 .. B-10 APPENDIX C - QUESTIONS YOU MAY WANT TO ASK EThp /Y PR-qe- The following are questions and concerns you should raise around any land disposal site, either proposed or existing. This overview is not necessarily complete, but highlights many concerns for the proper siting and operation of a land disposal site.* ISSUES AND QUESTIONS THAT MAY BE PERTINENT I. Economic considerations A. Is this facility needed I. How was need established a. Local and regional survey b. On—site or off—site needs c. Is it beneficial to good regional hazardous waste management d. Is there a generic survey of hazardous waste needs for the area — compatibility with this plan e. Is the technology proposed an improvement over that presently available f. Will this facility replace on outmoded/worse polluting one g. What geographical area will it serve B. Profit expectations 1. High or low risk 2. Longevity of facility a. Expansion anticipated b. In what time frame 3. Who owns the facility 4. Are owners financially backed by others 5. Who are the competitors C. Facility operators 1. Prior experience/operating record 2. Will company that owns also operate facility 3. Who will seek the permits 4. How can operators' expertise be evaluated if new to this field D. Economic effects on community 1. Possible effects on property values 2. Who will receive any increase in tax base 3. How much tax revenue may be generated 4. Will public costs rise a. Police protection b. Fire protection c. Road maintenance d. Emergency response equipment and facilities 4.3-5S1 * Taken From Keystone Center Discussion Paper C-1 E. Potential for compensation to community 1. Donated equipment community may need due to facility's locating nearby 2. Fees to general revenue fund 3. Property value guarantees 4. Parks, etc. F. Closure and post closure 1. When is closure anticipated 2. Who is responsible for the site after closure 3. What assurances will there be that site will be closed in accordance with the plan 4. Financial assurances to establish ability to handle problems after closure 5. Who certifies that site is properly closed 6. How are people protected from unwittingly buying land after closure a. Recorded in deed b. What future uses are possible II. Function of facility A. Storage B. Wastes to be handled 1. What wastes will be handled a. In what quantities b. Physical and chemical characteristics (1) Degree of hazard anticipated (2) What makes the waste hazardous 2. What wastes will not be handled — why 3. Sources of waste a. On—site generation b. Off—site generation (1) Local (2) Regional (3) Statewise (4) Out—of—state (5) Out—of—country c. Consumer products from which such waste results 4. Will nonmanifested wastes be accepted 5. Where will waste go if not handled at this site C. Does this facility fit into an integrated hazardous waste management system (reduction, recovery, recycling, sale/exchange, storage, treatment, disposal) 1. On—site 2. Regional D. Is this facility part of a master plan to provide hazardous waste management 1. Whose plan 2. How does it fit into plan 3. Geographical area served by plan SCCSael C-2 E. Plans for future expansion 1. Additional facilities 2. Additional types of facilities 3. Time frame anticipated III. Technology to be used — general questions A. Why was this technology chosen 1. Are others available 2. Can wastes to be handled be recycled, sold, exchanged or treated to avoid disposing of as hazardous waste 3. Engineering design and operating techniques to compensate for any site deficiencies B. Quality assurance/control 1. In identifying wastes a. Role of generator b. Role of facility 2. Plans for lab work 3. How are out-of-spec wastes handled 4. What happens to rejected wastes C. Reliability of technology 1. Paste experiences with it 2. Any serious environmental impacts 3. How was it tested to assure long-term safety and effective- ness D. Sequence of technolgy used from arrival of wastes to end process at facility (flow chart) 1. Analysis of waste 2. Unloading 3. Storage 4. Treatment 5. Disposal 6. Any residuals requiring further handling 7. Monitoring 8. Closure 9. Post closure IV. Technologies to be used-specific questions A. Land Disposal 1. Types a. Surface impoundment b. Land application/treatment c. Landfill (burial) d. Other - specify 2. Technical processes preceding land disposal a. Treatment, .stabilization b. Segregation of noncompatible wastes c. Handling of containerized waste 3. Technology to protect environment 4. Closure plans a. Interim partial closure of each cell ''",r`^ b. Final closure of full facility 5. Post closure plans a. Periodic monitoring and maintenance C-3 b. Post closure period c. Financing and cost assurance d. Responsibilities of facility operator, land owner, local and state units of government B. Deep Well Injection 1. Well Construction a. Depth b. Casings c. Monitoring equipment d. Local faults e. Previous wells in area 2. Pretreatment a. Sediment removal b. Waste compatibility 3. Processes to assure environmental protection 4. Closure Technology 5. Closure Technology 6. Technology available if remedial action is needed. C. Recycling/Recovery 1. How will it be accomplished 2. Plans for energy conversion 3. Will supplemental fuel be needed — what type 4. Reliability of waste characteristics 5. Long—term demand D. Storage 1. How is waste stored 2. Length of time in storage 3. Where does the waste go next E. Incineration 1. How complete will destruction be 2. Will supplemental fuel be needed — What type 3. Air quality protection 4. Anticipated air quality monitoring 5. What monitoring will be done 6. What are procedures in case of an upset F. Treatment 1. What type of treatment will be used 2. What type of wastes will be treated 3. How completely will waste be rendered nonhazardous 4. What will happen to the treated waste V. Site Characteristics A. How are site characteristics determined 1. What is done in a geotechnical investigation 2. Other assessment techniques B. Characteristics to be considered 1. Site geology 2. Hydrology 3. Topography 4. Soil properties FAQ* bs Ltd Ly C-4 5. Aquifer location a. Relationship to water table b. Wells presently in area c. Flow rate and direction of groundwater flow d. Groundwater quality e. Does aquifer connect with others f. Aquifer recharge area 6. Climatic conditions a. Normal b. Potential for natural disasters 7. Is site in or near environmentally sensitive areas a. Wetlands b. Shoreline c. Flood prone area d. Aquifer recharge zone e. Endangered species critical habitat f. Hurricane storm surge area g. Prime agricultural area h. Other 8. Susbsidence problems 9. Proximity to residences/schools/etc. 10. Evacuation routes in area 11. Current character of surrounding area 12. Zoning of site and areas nearby 13. What plans currently exist for site and area 14. What transportation routes will be used C. Why was this site chosen 1. Were others considered 2. Still under consideration 3. Why were others rejected VI. Environmental Quality A. Surface drainage 1. Is the site in a flood plain a. Which one? By whose standards? (1) How current are maps used to make determination b. What is the elevation of the land c. Dikes planned (1) Internal (2) Perimeter d. Diking required or desired (1) Height (2) How protected from erosion (3) Design storm used (4) Acess to site over or through kikds 2. Stormwater management a. How will it be controlled b. Treatment/discharges c. Effect on receiving body of water d. Will residuals remain (sludge management plans) e. Design storm used 3. Hurricane vulnerability a. Is site in an area subject to storm surge b. Design storm specifications C-5 c. Damage from wave action possible d. For what levels of wind speed is facility designed B. Groundwater protection 1. Groundwater resources a. Are aquifers used for drinking water (1) Now or possibly in future (2) Location of known wells b. Other uses of groundwater now or in future c. Proximity to surface water 2. Soil a. Physical characteristics, including permeability b. Chemical characteristics, including compatibility with wastes to be handled 3. Leachate Collection a. How will leachate be collected b. How will leachate be treated c. For how long will leachate be collected? Treated? 4. Liners a. What is required? Desired? b. What areas of the facility will be lined c. Integrity of liner (1) Type: clay or synthetic (2) Thickness (3) How constructed (4) Compatibility with wastes to be handled — how tested d. Remedial action possible 5. Caps a. Same questions as liners b. Erosion control c. Prevention of water standing on site, correction of settlement d. Revegetation planned, post closure maintenance 6. Deep well injection has additional concerns a. Relationship of aquifers to injection zone b. Compatibility of waste with area geology c. Remedial action possible d. Limitations of future land use for mining, etc. C. Air emissions 1. What protection is afforded from which contaminants 2. Potential for unregulated emissions 3. Odor control plans 4. Who will be affected by emissions a. Direction of prevailing winds b. Frequency of "bad air" conditions 5. Control of vapors at various stages of process VII. Transportation • A. Mode of transporation now and in future 1. Truck • 2. Rail 3. Barge 4. Other possiblities n C5 B. Containment of waste during transport ( � 'E ., F C-6 1. Type of container a. Bulk b. Drums c. Other 2. Protection against leakage a. Compatibility of wastes with packaging b. Reliability record of container 3. Labeling of containers C. Who is reponsible for transport 1. Company responsible — what is their record 2. Training of drivers a. Safe driving skills b. Emergency response 3. Manifest system 4. Labeling of trucks D. Timing of arrivals 1. Days 2. Hours E. Routing 1. Routes to be used 2. Any restrictions existing a. Who imposed them b. Who enforces them c. Can penalties be assessed on offenders 3. Effects on area traffic 4. Effects on area road conditions F. Spill response 1. Whose responsibility 2. Clean up techniques 3. Who pays for clean up VIII. Operations A. What actions will be taken when there are operating problems 1. Back—up systems planned 2. Start—ups and shutdowns a. Effects on permitted emissions b. Frequency/longevity anticipated B. Emergency response 1. What is included in the contingency plan 2. How will fire protection be provided a. On—site equipment b. Mutual aid agreements c. Alarm systems C. Site security 1. Controlled entry 2. Fencing SP � r 3. Warning signs t.# 4. Surveillance systems C-7 RELATED READINGS Alternatives To Land Disposal: Available from CCHW, P.O. Box 926, Arlington, Virginia 22216 for $2.75. Environmental Testing: Where To Look, What To Look For, How To Do It And What Does It Mean: Available from CCHW, P.O. Box 926, Arlington, Virginia 22216 for $7.95. Incineration: The Burning Issue of the Eighties: Available from CCHW, P.O. Box 926, Arlington, Virginia 22216 for $8.98. Deepwell Injection: An Explosive Issue: Available from CCHW, P.O. Box 926, Arlington, Virginia 22216 for $8.98. Reprints: Science Features From Everyone's Backyard: Available from CCHW, P.O. Box 926, Arlington, Virginia 22216 for $4.50. Reduction of Hazardous Wastes: The Only Serious Management Option: Available from CCHW, P.O. Box 926, Arlington, Virginia 22216 for $8.98. Innovative Technologies For Disposal of Hazardous Wastes: Available from CCHW, P.O. Box 926, Arlington, Virginia 22216 for $8.98. 13 15 17 19 21 23 25 27 29 1 33 35 37 39 41 43 45 47 RD 138 L"...\••••••-•er RD 136 ' RD 134 RD 132 II' RD 130 RD 128 RO 126 / CARR ROCKPORT � J P RD 124 RD 122 RD 120 .. c RD 118 RD 116 RD 114 I RD 112 L RD 110 ■ RD 108 _ RD 106ii RD 104 (Jl 11r RD 102 , 11 ' 1 I I 1 RD 100 XNUNNQ��;, RD 98 RD 96 RD 94 RD 92 CIt PIERCE RD 90 RD 88 • . • pU I / • rG�U/�7 RD 86 • ND 13 IS 17 `4,*\ • 23 • 19 21 RD 84 • • 84 • • 1 43 45 47 sfrE A01T RD 82 , X • • • • • • to • • as t • RD 80 • - •• _ • ., • RD 80 • •�+ • • II • • 25 • r RD 78 • RD 78 39 27 29 ss Hello