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To: Activists concerned about landfills Fr: Greenpeace Research Division Da: 2 May 1989 If landfills are an issue in your area, you should find the following information of interest: "Disposal of "nonhazardous" solid waste is regulated under Subtitle D of the Resource Conservation and Recovery Act (RCRA). These Subtitle D wastes include many different types of waste streams, such as municipal solid waste, industrial waste, and oil and gas waste." "More than 11 Billion Tons of Subtitle D Waste Are Produced Annually in the United States. Of this total more than 95 percent are industrial nonhazardous waste, oil and gas waste, mining waste, and municipal solid waste. Each type of waste presents unique management problems and risks." "There are 226,732 Subtitle D units in the United States. Eighty-four percent of this total are surface impoundments, 8 percent are land application units, 6 percent are landfills, and 2 percent are industrial waste piles. Of the nearly 13,000 landfill units identified, 6,584 are municipal solid waste landfill units." "Shortages of Municipal Solid Waste Landfill Capacity are Occurring in Some Areas of the Nation. The shortages are due to several factors: (1) 83 percent of the municipal solid waste generated in 1986 was landfilled; (2) 45 percent of all municipal solid waste landfills will close by 1991; (3) some States have not conducted long-term planning; and (4) siting of new disposal facilities is difficult." "Municipal solid waste landfills have degraded and may continue to degrade the environment." "... the data indicate that releases to the ground water from municipal solid waste landfills present potential risks to human health." "Acute human health impacts associated with methane releases have been documented." "... the limited available data on industrial Subtitle D facilities indicate that there is cause for concern and a need for further study. Current findings include: (1) the use of design controls at industrial facilities is very limited; (2) the number of industrial facilities is large and the amount of industrial nonhazardous waste generated annually dwarfs the amount of municipal solid waste; ..." "Waste tires, infections waste, and municipal waste combustion ash are examples of special Subtitle D wastes. The special management concerns posed by these waste streams arise from the unique characteristics of these wastes. Current data are not sufficient to estimate reliably the risks posed by these wastes." "Federal and some State solid waste regulations lack the following essential requirements: location criteria, appropriate design criteria, ground-water monitoring, corrective action, closure and post-closure care, and financial responsibility." 1 "... HSWA [1984 Hazardous and Solid Waste Amendments to RCRA] requires EPA to revise the current criteria for facilities that may receive household hazardous waste or small-quantity generator hazardous waste." "... the Subtitle D waste stream is very diverse. Such different waste types as waste tires, infectious waste, industrial nonhazardous waste, and municipal solid wastes are all regulated under Subtitle D of RCRA. .. the industrial nonhazardous waste category includes waste from the pulp and paper industry, the organic chemical industry, the textile manufacturing industry and a variety of other industries." "Each Subtitle D waste type presents unique problems and risks." "Table 1. Subtitle D Waste Categories and Quantities Estimated Annual Generation Rate Waste Category (million tons) Industrial Nonhazardous Waste 7,600 (a,b) Oil and Gas Waste (c) -drilling waste 129 - 871 (d,e) -produced waters 1,966 - 2,738 (e,f) Mining Waste (c) > 1,400 (g) Municipal Solid Waste 158 (b) -household hazardous waste 0.002 - 0.56 (b) Municipal Waste Combustion Ash 3.2 - 8.1 (h) Utility Waste (c) - ash 69 (i) -flue gas desulfurization waste 16 (i) Construction and Demolition Waste 31.5 (j) Municipal Sludge - wastewater treatment 6.9 (b) - water treatment 3.5 (b) Very-Small-Quantity Generator Hazardous Waste (<100 kg/mo) 0.2 (e) Waste Tires 240 million tires (g) Infectious Waste 2.1 (e,l) Agricultural Waste Unknown Approximate >11,387 a: Not including industrial waste that is recycled or disposed of off site. b: These estimates are derived from 1986 data. c: Waste category is the subject of a separate report to Congress d: Converted to tons from barrels: 42 gals = 1 barrel, ~17 lbs/gal e: These estimates are derived from 1985 data. f: Converted to tons from barrels: 42 gals = 1 barrel, ~8 lbs/gal g: These estimates are derived from 1983 data. h: This estimate is derived from 1988 data. i: These estimates are derived from 1984 data. j: This estimate is derived from 1970 data. k: Small quantity generators (100-1,000 kg/mo) have been regulated under RCRA, Subtitle C, since October 1986. Before then, approximately 830,000 tons of small-quantity generator hazardous wastes were disposed of in Subtitle D facilities every year. 2 l: Includes only infectious hospital waste. "This study estimates that there are 226,732 Subtitle D units located at approximately 128,000 establishments. (An establishment may have more than one unit.) Of these units, 84 percent are surface impoundments, 8 percent are land application units, 6 percent are landfills, and 2 percent are industrial waste piles ... More than half the units are oil and gas surface impoundments. Municipal solid waste landfills account for nearly half of the landfills and more than two-thirds of the land application units are municipal sewage sludge units." "Most of the Subtitle D facilities are privately owned. This is because of the overwhelming number of privately owned oil and gas, industrial, and mining waste facilities. In addition, approximately 17 percent of municipal solid waste landfills are privately owned. However, municipal solid waste landfills are predominantly publicly owned. Nearly 78 percent of municipal solid waste landfills are owned by local governments, approximately 4 percent by the Federal government, and 1 percent by State government." "Table 2. Estimated Number of Active Subtitle D Units Unit Type Waste Category Landfills Surface Land Waste Impoundments Application Piles Total Municipal solid waste 6,584(a) b b b 6,584 Industrial waste 2,757(c) 15,253 (c) 4,308(c) 5,335 (c) 27,654 Municipal Sewage Sludge d 1,938 11,937 b 13,875 Oil and Gas Waste (e) b 125,074 726 b 125,800 Agricultural Waste d 17,159 b b 17,159 Mining Waste (e) d 19,183 b d 19,813 Municipal Runoff b 488 b b 488 Construction and Demolition Debris 2,591 b b d 2,591 Miscellaneous Waste 1,030 11,118 621 d 12,769 Appropriate Total Number of Units 12,962 190,843 17,592 5,335 226,732 a: The results of a previous census of the States indicated 9,300 municipal solid waste landfills. However, the table entry is considered more accurate. It is based on a 1986 Survey. b: Unknown, none or few thought to exist. c: These estimates differ from previously published results from a census of the States. Table entries are considered to be more accurate. They are based on a 1986 Industrial Survey. d. Unknown, some may exist. e. Waste category is the subject of a separate report to Congress. "Approximately 83 percent of the municipal solid waste generated in 1986 was disposed of in landfills, while only 11 percent was recycled, and only 6 percent was combusted." "Nearly three-fourths (74 percent) of all municipal solid waste landfills are expected to close within 15 years, with 45 percent expected to close in 5 years .... These shortages are becoming critical in densely populated areas of the country, particularly in 3 the Northeast." "Municipal solid waste landfills and the waste they receive have been characterized reasonably well, and some impacts associated with municipal solid waste landfills have been identified. However, leachate and gas data for these facilities are limited." "Comparatively less is known about industrial wastes and facilities. Specific industrial waste streams have not been well characterized and little is known about the hazards they may pose." "... the data indicate that some municipal solid waste landfills present potential risks to human health. Human health impacts from exposure to contaminant releases to ground water from municipal solid waste landfills are difficult to isolate due to the complex interaction of factors that affect human health." "With regard to air emissions from municipal solid waste landfills, acute impacts associated with methane releases have been documented. The Agency is currently determining the extent of human health risks that may result from emission of volatile organic compounds, which have been estimated to be in the range of 200,000 megagrams per year." "The number of industrial facilities is very large, as is the amount of waste they handle. Because current data are limited, it is not possible to draw conclusions regarding the risks posed by these facilities. Existing data however, do suggest that these facilities need to be further investigated to determine the need for additional regulatory action." "Data on post-1980 facilities [solid waste landfills] are very limited. (These newer sites represent only 30 percent of the municipal solid waste landfills in existence today)." "... on a national basis, EPA found little difference in the location, design, and operation of newer municipal solid waste landfills versus older landfills." "Some large-quantity [hazardous waste] generators may also be illegally disposing of their hazardous wastes in municipal solid waste landfills." "... environmental impacts and threats to human health have been documented at 163 municipal solid waste landfills." "Ground-water and surface water quality were adversely affected at 146 and 73 municipal solid waste landfills, respectively. While the impacts identified range in severity, 33 sites have contaminated drinking water resources, and three other sites pose a threat to water supply systems. For example, one active municipal solid waste landfill has contaminated a square mile of a sole-source aquifer and has closed a major community well field. ... Elevated levels of organics, including pesticides, and metal contaminants have been found in ground water and/or surface water at many sites." "Impacts on fish or other aquatic life have been documented at 13 sites. ... this small number of cases does not likely reflect the actual number of occurrences." Superfund Statistics "To be listed on the NPL [Superfund National Priorities List], a site must present or be capable of presenting significant environmental and/or human health impacts. Of the 850 sites listed or proposed for listing on the NPL in May 1986, 184 sites (22 percent) were identified as municipal solid waste landfills." "Halogenated organics, aromatics, and metals were found at most 4 of these sites. Releases of hazardous materials to ground water were documented at nearly 75 percent of the sites. Forty-three percent had releases to surface water, and 16 percent had significant air emission problems." Methane Damage "Methane is produced in municipal solid waste landfills through anaerobic decomposition of organic waste, and is explosive at sufficiently high concentrations (the lower explosive limit). ... where methane is not controlled, it can cause fires and explosions." Ground-Water Risk Assessment "To characterize typical leachate from a municipal solid waste landfill, the AGency chose eight constituents from more than 200 chemical constituents found in municipal solid waste leachate. ... The eight constituents and the effect of concern for each are as follows: - Vinyl Chloride human health risk (cancer) - Arsenic human health risk (cancer) - Iron resource damage (taste and odor) - 1,1,2,2,-Tetrachloroethane human health risk (cancer) - Methylene chloride human health risk (cancer) - Antimony human health risk (systemic poisoning) - Carbon Tetrachloride human health risk (cancer) - Phenol resource damage (taste and odor)" The analysis estimates human health risk for the maximum exposed individual and the total population using ground water as a drinking water source within one mile of the facility. ... Current data indicate that 54 percent of existing municipal solid waste landfills have no downgradient drinking water wells within one mile." "For the subgroup of landfills located within one mile of a drinking water well (46 percent of all landfills), nearly 40 percent have risk exceeding 10(-6), with 14 percent posing risk in the 10(- 5) to 10(-4) range." "The overall risk distribution changes significantly if it is assumed that all drinking water wells are located at the facility boundary (assumed to be 10 meters from the landfill unit). This scenario, although certainly very conservative, helps to identify the number of landfills that may contaminate the ground water beneath the facility above health-based limits. Making this assumption, over 67 percent of the landfills would hypothetically pose risks exceeding 10(-6), with approximately 35 percent posing risks in the 10(-5) to 10(-4) range." "In present-value terms, the Agency estimates that resource damage from municipal solid waste landfills ranges from $0 to more than $4 million per site. The model predicts that nearly a third of the landfills would have resource damage exceeding $200,000, and about 13 percent have resource damage in excess of $1 million." "The model estimates that the resulting total plume area from 6,000 new facilities placed in existing landfill locations would be roughly 1,114 square miles (an area slightly smaller than the state of Rhode Island) over the 300-year modeling period." "Municipal solid waste landfills receive a variety of wastes ... While the overall waste stream is considered to be less hazardous than that received at RCRA Subtitle C (hazardous waste) facilities, 5 it nevertheless is a source of concern. By far, the majority of waste disposed of at municipal solid waste landfills is household waste (72 percent of the total waste stream). Household waste is primarily made up of nonhazardous materials such as paper. Some nonhazardous material, however may contain hazardous constituents, such as, lead in newsprint. In addition, within a landfill, some of these nonhazardous materials may degrade biologically and/or chemically and form more toxic constituents. ... Also, about 0.35 to 0.40 percent of the overall household waste stream includes hazardous components. Constituents of concern in household hazardous waste include solvents, pesticides, other organics, acids, bases, medicines, and inks ... "Table 4: Wastes Disposed of in a Typical Municipal Solid Waste Landfill Waste Types Waste Composition Percentage (a) (mean value) Household Waste 72 Commercial Waste 17 Construction/Demolition Waste 6 Industrial Process Waste 2.73 Other Waste 1.18 Sewage Sludge 0.50 Other Incinerator Ash 0.22 Asbestos-Containing Waste 0.16 Municipal Incinerator Ash 0.08 VSQG Hazardous Waste 0.08 Infectious Waste 0.05 (a) Percentages are rounded and do not add to 100 percent. "The other 28 percent of wastes received at municipal solid waste landfills includes very-small-quantity generator (VSQG) hazardous waste, commercial waste, industrial process waste, infectious waste, municipal incinerator ash, and asbestos-containing wastes. Some of these waste streams may contain potentially hazardous constituents. Congress, in the 1984 amendments to RCRA, was particularly concerned with VSQG waste. This waste stream accounts for a small part of the overall waste stream received at municipal solid waste landfills; however, some relatively hazardous or toxic materials are present in the VSQG waste stream ... Used lead acid batteries are the largest single source of VSQG waste. "Categories of Very-Small-Quantity Generator Wastes Arsenic waste Photographic wastes Cyanide wastes Solutions of sludges Dry cleaning filtration containing silver residues Solvent still bottoms Empty pesticide containers Spent plating wastes Heavy metal dust Spent solvents Heavy metal solutions Strong acids or alkalies Heavy metal waste materials Used lead-acid batteries Ignitable paint wastes Waste formaldehyde Ignitable wastes Waste inks containing flammable Ink sludges containing solvents or heavy metals chromium or lead Waste pesticides Mercury wastes Wastes containing ammonia Other reactive wastes Wastewater containing Paint wastes containing wood preservatives 6 heavy metals Wastewater sludges containing Pesticide solutions heavy metals" "Of the 70 sites [municipal solid waste landfills] for which EPA has data, 53 of them were analyzed for some organic constituents, and 62 for some inorganic constituents. ... A total of approximately 82 leachate constituents were found -- 63 organics and 19 inorganics. ... the median concentration values of the leachate constituent data were compared to EPA drinking water and/or human health criteria concentrations. ... The median concentrations of all the carcinogens (nine constituents) were above the health-based criteria for these compounds. In a number of cases, the median concentrations of all the carcinogens (nine constituents) were above the health-based criteria for these compounds. In a number of cases, the median concentrations would take more than a 1000-fold dilution in order to meet the health criteria." "... leachate quality tends to change over time as the landfill moves through the stabilization process. However, where leachate data are available for both pre- and post-1980 landfills, no trend is apparent. Median concentrations for leachate from post-1980 landfills are higher than those for pre-1980 landfills for approximately 50 percent of the constituents." "Landfill gas adds to the potential for impacts from municipal solid waste landfills ... Methane, which is explosive, accounts for about 50 percent by volume of the total gas stream. ... trace constituents (up to 2 percent) of volatile organic compounds (VOCs) and toxic constituents also may be present. Toxic constituents commonly found in municipal solid waste landfill gas include vinyl chloride, benzene, trichloroethylene, and methylene chloride." MSW Disposal on Indian Lands "At present there are 314 Federally recognized Indian Tribes and 198 Alaskan Native villages in the United States covering an area of approximately 87,000 square miles ... The total population of this land is approximately one million. The Indian Health Service (IHS) has identified 576 municipal solid waste disposal sites on Indian lands." "Several EPA-sponsored surveys indicate that Indian Tribes perceive municipal solid waste disposal as current and future environmental problem. One survey reported that on half of the reservations surveyed (24) "community dumps" were used for disposal. Another reported 66 open dumps on Indian lands in EPA's Region 5 alone. Roadside dumping and other illegal dumping were also reported. Landfill leachate was cited several times by the Tribes surveyed as the potential source of water pollution. [unfinished: more on Industrial Subtitle D facilities; waste tires; infectious waste; municipal solid waste combustion ash] --Source: "Report to Congress: Solid Waste Disposal in the United States," Volume I, EPA 530-SW-88-011, October 1988 7 ===================================================================== Citizens fighting landfill problems will also be interested in the following resources: "Landfill Packet" A series of ten articles about problems with landfills, available from the Environmental Research Foundation, P O Box 3541, Princeton NJ 08543, 609-683-0707. "Debunking the Landfill High Technology Myth" A thick, excellent report on the facts behind what the disposal companies try to tell you. By Blythe Coza, produced by People Against Hazardous Landfill Sites, 219-759-1800. "Recycling Kit" Produced by Bryan Bence of Greenpeace. Write to Bryan at Greenpeace, 1436 U St NW, Washington DC 20009, 202-462- 1177. ---===000===--- 8