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#231 - EPA Proposes A Perfect Solution For New Municipal Solid Waste Landfills, 30-Apr-1991

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

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.

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

--Peter Montague


(Berkeley, Ca: Premier Press, 1980), pg. 509. This is a reprint of
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.

Descriptor terms: msw; landfilling; epa; leachate; groundwater
contamination; cancer; health effects; regulations; landfill liners;
pollution prevention;