=======================Electronic Edition========================
RACHEL’S HAZARDOUS WASTE NEWS #231
—May 1, 1991—
News and resources for environmental justice.
——
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org
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EPA PROPOSES A PERFECT SOLUTION FOR
NEW MUNICIPAL SOLID WASTE LANDFILLS.
Eighty-two percent of all U.S. municipal solid waste–or roughly
134 million tons annually–ends up in the nation’s 7575 landfills
(see RHWN #176). The vast majority of these landfills have no
liners, no leachate collection systems, and no groundwater
monitoring systems. In humid regions, all landfills produce
leachate, caused inevitably by the interaction of garbage,
rainfall and gravity; gravity pulls the rain slowly downward
through the garbage until the rain drips out the bottom
contaminated. In 1977, an EPA (U.S. Environmental Protection
Agency) contractor estimated that 90 billion gallons per year of
leachate was entering U.S. groundwater from municipal
landfills.[1] Since the leachate that drips from beneath a solid
waste landfill has essentially the same carcinogenicity
(cancer-causing ability) as the leachate that drips from
industrial and hazardous waste landfills like Love Canal (see
RHWN #90), and since a careful analysis of landfills shows that
86% of those studied have contaminated groundwater (see RHWN #71), it
seems safe to say that the nation’s 7575 solid waste
landfills, taken together, constitute a major source of serious
environmental contamination. Furthermore, because household
products each year are made from more and more strange chemical
mixtures, each year landfill leachate becomes a little more
toxic, a little more dangerous, so the problem is getting worse.
Soon the federal EPA will officially recognize the hazardous
nature of municipal landfills. In the next couple of months EPA
will publish new regulations governing the siting, design and
operation of municipal landfills, including monofills for
incinerator ash. The agency proposed the new regulations back on
August 30, 1988 (FEDERAL REGISTER Vol. 53, No. 166, pgs.
33314-33422) and will soon publish a final version; the 1988
proposal offers some insight into what the new regulations will
include.
Unfortunately, the new regulations seem likely to increase
environmental contamination by landfills. However, from the
viewpoint of present-day regulatory officials and politicians,
the new regulations offer a perfect solution to a difficult and
worsening problem. How is this possible?
To naive readers, the new regulations will give the appearance of
solving the leachate-leakage problem from landfills and will thus
encourage increased landfilling of dangerous municipal wastes.
However, since contamination from landfills cannot be prevented
by regulations that only deal with the design and operation of
landfills (ignoring what goes into them) EPA’s new regulations
will merely delay the appearance of problems from today’s
landfills and will thus pass the costs of contamination from
today’s landfills on to the next generation. EPA’s “state of the
art” regulations essentially guarantee that our grandchildren
will live in a world substantially more degraded than our own.
Somewhat surprisingly, the Agency acknowledges most of these
facts in its August 30, 1988 FEDERAL REGISTER notice.
Here are some details:
First EPA acknowledges that the problems of municipal solid waste
landfills and the problems of hazardous waste landfills are
identical, when viewed from the perspective of environmental
damage: “…the concerns relating to failure of containment
structures are the same for any landfill regardless of waste
type.” (pg. 33334)
The “containment structure” is what a modern landfill is all
about. EPA’s 1988 proposal would require new MSW [municipal solid
waste] landfills to be designed with a bottom liner of plastic
(thus forming a plastic bathtub in the ground), a leachate
collection system (a set of pipes in the bottom of the bathtub),
and, when the landfill is full of garbage, a “cap” over the
top–an umbrella made of plastic to keep out the rain (to prevent
the formation of leachate).
Thus the garbage will be completely enclosed in a plastic baggie
in the ground. This would seem to solve the problem of landfill
leachate. What could possibly go wrong?
The EPA answered this very question in the same FEDERAL REGISTER
notice in which it proposed the new regulations:
The baggie will delay the introduction of leachate into the
environment but will not prevent it because eventually the
containment system (the baggie) will deteriorate for a variety of
reasons. Says EPA: “First, even the best liner and leachate
collection systems will ultimately fail due to natural
deterioration, and recent improvements in MSWLF [municipal solid
waste landfill] containment technologies suggest that releases
[of leachate] may be delayed by decades at some landfills.” (pg.
33345) EPA goes on to say that human error may also contribute to
leachate “releases due to design or operating errors (e.g.,
tearing of liners or disposing of wastes that are incompatible
with the liner) and routine deterioration of liner.” (pg. 33344)
The duration of the hazard is long: “Experience has shown that
leachate generation in landfills continues long after closure,”
says EPA. (pg. 33344)
The EPA notice makes it clear that every part of a landfill will
eventually degrade and break down. For example, the cover: “Cover
maintenance also includes periodic cap replacement, which is
necessary to remediate the effects of routine deterioration.”
(pg. 33344) And the groundwater monitoring wells will
deteriorate: “Because ground-water monitoring wells are subject
to routine deterioration, postclosure activities should also
include the periodic replacement of these wells as needed.” (pg.
33344)
Therefore, it is the Agency’s position that “Even when properly
carried out, however, closure cannot guarantee against long-term
environmental problems at landfills.” (pg. 33344) In fact, the
Agency explicitly acknowledges that “Particularly for landfills
designed with advanced containment systems (e.g., liners,
leachate collection systems, or synthetic final caps) groundwater
contamination may be delayed by many years.” (pg. 33344)
Thus the EPA’s proposed new landfill regulations will do two
things: they will make landfills very expensive to build and
operate, and they will delay but not prevent the appearance of
contamination from landfills. Why would EPA–which understands
the dangers of landfills as well as anyone–propose regulations
that will make landfills expensive and will delay, but not
prevent, the appearance of contamination?
Making landfills expensive to build will drive small waste
haulers out of business. Even most county governments and
municipalities will have difficulty coming up with the tens of
millions of dollars needed to build a plastic-lined landfill with
leachate collection and a final cover made of plastic. Some
states (such as Pennsylvania) have passed such laws and the
effect is already visible: only the biggest waste haulers can
remain in the landfill business, and small governments are now
turning to the giant haulers for solid waste services. Only a
handful of wealthy companies, like Waste Management, Inc., and
Browning-Ferris Industries (BFI), can afford to meet the new
regulations. They in turn make substantial campaign contributions.
Secondly, by delaying the appearance of environmental problems,
the current crop of regulators and politicians will be able to
claim that they have “solved” the garbage crisis, yet they will
have avoided any really difficult choices. By the time the bulk
of the problems appear, President Bush will be dead, Bill Reilly
will have followed the path of Bill Ruckelshaus (former head of
EPA, now head of BFI, the nation’s No. 2 waste hauler) and all
today’s local politicians will have been put out to pasture. (Our
children will pay, but they have no vote.)
From the viewpoint of contemporary regulators and politicians, it
is the perfect political solution to a difficult problem. (Next
week: real solutions.)
–Peter Montague, Ph.D.
===============
[1] David W. Miller, editor. WASTE DISPOSAL EFFECTS ON GROUND
WATER (Berkeley, Ca: Premier Press, 1980), pg. 509. This is a
reprint of EPA’s 1977 REPORT TO CONGRESS, WASTE DISPOSAL
PRACTICES AND THEIR EFFECTS ON GROUND WATER. The reprint is now
officially out of print, but is still available for $18 from
Geraghty & Miller, 125 East Bethpage Rd., Plainview, Ny 11803;
phone (516) 249-7600..”
The only real alternative is to address the source of the problem
through pollution prevention–to require that manufacturers keep
dangerous (persistent, bioaccumulative, or toxic) chemicals out
of their consumer products.
This real solution will require intervention in (or at least
public influence upon) the manufacturing process itself; it may
require outlawing certain dangerous chemicals (for example,
perhaps lead, perhaps cadmium, perhaps some chlorinated compounds
such as PVC or perhaps some solvents).
It will take leaders of vision and courage to make these
difficult choices. Such questions may provide the ultimate test
of the American political system. Judging by its 1988 proposals,
the present administration seems unlikely to measure up.
Descriptor terms: MSW; landfilling; epa; leachate; groundwater
contamination; cancers; health effects; regulations; liners;
pollution prevention