Carol Browner, Administrator
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Dear Administrator Browner:
Periodically I have brought to your attention materials concerned
with problems with RCRA current municipal solid waste (Subtitle D)
and hazardous waste (Subtitle C) landfills in providing groundwater
quality protection for as long as the wastes in the landfill will be a
threat. As you are no doubt aware, the June 30 issue of The New
York Times Magazine carried an article by John Tierney which
claimed that recycling of municipal solid wastes is inappropriate and
an unnecessary expense, since today's landfills are safe. When I saw
this article, I teamed with a member of the National Sierra Club Solid
Waste Committee (Dr. William Sheehan) to develop a letter to the
editor. Further, I followed up this letter with a paper that I
specifically developed on the highly inappropriate assessment of the
safety of today's landfills and why recycling is an important part of
protecting groundwater quality. Enclosed is a copy of the letter and
my paper. Basically, the issue is that today's landfills, both Subtitle C
and D, only postpone groundwater pollution. Recycling of waste is
an important component of protecting groundwaters, since it reduces
the need for additional landfills.
While the Tierney article is not even good fiction and represents a
gross distortion of information available on the topic, his article has
stimulated the environmental groups of the country to address these
issues including the safety of today's landfills. I urge that the US
EPA administration acknowledge what is well known that today's
landfills are not protecting groundwater; and that your
administration start to revise RCRA so that a bipartisan effort can be
initiated to develop landfills that will in fact protect the groundwater
resources of future generations from pollution by landfill leachate.
As discussed in the enclosed paper, the basic problem with RCRA is
that environmental groups working through Congress dictated in the
early 1980s to the US EPA how to design landfills. While in the early
1980s when this was done we did not understand well the problems
with compacted soil and plastic sheeting liners. By the late 1980s we
began to understand that the drytomb landfilling approach which
involves trying to store wastes in these types of lined landfills is
obviously technically flawed and will only postpone when pollution
occurs. We need now to significantly change our landfilling
approach so that it properly reflects what is known today on how
landfills should be developed, operated, closed and maintained for as
long as the wastes represent a threat. As backup to The New York
Times Magazine rebuttal article, I have enclosed several other papers
I have recently developed that deal with these issues from a more
technical perspective.
If you or your colleagues have any questions or comments on the
enclosed or wish further information on any aspect of these
discussions, please contact me. Also, if I can be of further assistance
in helping to correct the error that occurred in the early 1980s with
the development of the drytomb landfill approach involving
compacted soil and plastic sheeting liners please let me know.
Sincerely yours,
G. Fred Lee, PhD, PE, DEE
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