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Assessing the Potential of Minimum Subtitle D Lined Landfills to Pollute:
Alternative Landfilling Approaches
G. Fred Lee, PhD, PE, DEE and Anne Jones-Lee, PhD
G. Fred Lee & Associates, 27298 E. El Macero Drive, El Macero, CA 95618
Ph: 530-753-9630; Fx: 530-753-9956; em: gfredlee@aol.com
March 1998
Abstract
The US EPA Subtitle D regulations specify as a minimum, MSW landfills be
lined with a single composite liner which is part of a leachate collection
and removal system. Upon reaching the landfill capacity, a low-permeability
cover is installed. A groundwater monitoring system is used to detect liner
failure during the 30-year mandated post-closure care period. The waste in a
minimum Subtitle D Adry tomb@ landfill will be a threat to pollute
groundwaters by leachate, effectively forever. The landfill liner and cover
have a finite period of time when they can be expected to function
effectively to keep moisture out of the landfill that generates leachate and
to collect leachate formed within the landfill. The groundwater monitoring
systems typically used with monitoring wells having zones of capture of about
one foot on each side, spaced hundreds of feet apart, have low probabilities
of detecting landfill liner failure that leads to groundwater pollution
before off-site pollution occurs. The 30 years of mandated post-closure care
is an infinitesimally small part of the time that the waste in a minimum
Subtitle D Adry tomb@ landfill will be a threat to generate leachate that can
pollute groundwater. Fundamentally, the minimum Subtitle D MSW landfill is a
technologically flawed approach that, at best, only postpones when
groundwater pollution occurs for those landfills sited at geologically
unsuitable sites, i.e. those without natural groundwater quality protection.
The US EPA Subtitle D regulations also fail to address the justifiable NIMBY
associated with active life releases (odors, dust, blowing paper, etc.) from
the landfill to the surrounding area. This paper discusses the deficiencies
in minimum Subtitle D landfilling of MSW and provides guidance on alternative
landfilling approaches that can protect public health, groundwater resources,
environment and the interests of those within the sphere of influence of the
landfill.
For the complete paper, see
http://home.pacbell.net/gfredlee/alternative_lf.html
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