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[GreenYes] Disposal and Recycling
Wayne Turner offered commentary in yesterday's GreenYes on the euphemistic
change in the name from "dumps" to "landfills".  Of course, the change in
nomenclature is more extreme than just that.  We also have the phrase
"sanitary landfill" and "state of the art" landfill.

In addition to the dialogue on the generalized feelings of those with
familiarity of the real nature of today's disposal facilities, let me offer
the following facts that bear upon how today's underground disposal sites
should be considered and then on how all that bear's on recycling's fortunes
and what we must do to succeed.

First, it is useful to refer to the statutory requirements for landfill
rules defined in the federal statutes. The applicable statute is found in
the Resource Conservation and Recovery Act, which specifically and
unambiguously provides that any regulations developed by EPA shall "at a
minimum" insure that "there is no reasonable probability of adverse effects
on health or the environment from disposal of solid waste."

The facts are simply incontrovertible that the so-called "dry tomb" designs
fail completely in this regard. Although, the statutes purport to define
household and commercial waste in engineered landfills to be "sanitary" as a
matter of law, municipal waste is, in fact, hazardous. The actual field data
examined by the EPA has "not reveal[ed] significant differences in the
number of toxic constituents and their concentrations in the leachate"
between sanitary and hazardous waste streams.
Moisture mixed with the organic material in the waste stream sustain
biological processes that drain those dangerous substances out of the waste
load and form leachate that pools at the bottom of the landfill. This
hazardous leachate must be isolated from groundwater, especially from our
drinking water supplies, to protect the environment and public health. To do
this, EPA regulations require composite liners on the top, bottom and sides
of the landfill to keep precipitation from entering into and the leachate
from leaking out of the facility.

However, this is probably one of the worst strategies to have used. For even
composite liners "will ultimately fail" within decades after the agency's
post-closure care requirements have expired, EPA has acknowledged, and when
they do, "leachate will migrate out of the facility." Yet, the EPA
recognizes, the duration of a landfill's hazardous loadings that needs to be
isolated may be "many thousands of years," long after the time when
discharges will occur.

This means that today's landfill's designed to Subtitle D standards will
almost certainly leak - just not until after the landfill owner's legal
liability has ended, yet before the toxic constituents in the waste load has
become benign. Rather than adding additional layers of protection, these
elaborate barriers required by current rules have actually only shifted in
time the occurrence of environmental damage to a future world long after the
responsible entities are gone.

For these reasons, EPA's rules totally fail to protect the environment as
required by the statute,

This indictment of the current rules as failing to protect the environment
is also shared throughout the industry-

SWANA DIRECTOR JOHN SKINNER: "The problem with the dry-tomb approach to
landfill design is that it leaves the waste in an active state for a very
long period of time. If in the future there is a breach in the cap or a
break in the liner and liquids enter the landfill, degradation would start
and leachate and gas would be generated. Therefore, dry-tomb landfills need
to be monitored and maintained for very long periods of time (some say
perpetually), and someone needs to be responsible for stepping in and taking
corrective action when a problem is detected. The federal Subtitle D rules
require only 30 years of postclosure monitoring by the landfill operator,
however, and do not require the operator to set aside funds for future
corrective action. Given the many difficulties of ensuring and funding
perpetual care by the landfill operator, the responsibility of responding to
long-term problems at dry-tomb landfills will fall on future generations,
and the funding requirements could quite likely fall on state and local

P&G SCIENTIST DR. PETER WHITE: "...The dry containment method of operating a
landfill has been described as long-term storage of waste rather than waste
treatment or waste disposal, and does have some significant drawbacks. There
will always be pockets of moisture within waste, and it is generally
accepted that all lining and capping systems will eventually leak so rain
and/or groundwater will eventually enter the site. Thus, the decomposition
of the organic fraction of the waste will eventually occur, with resulting
emissions of landfill gas and leachate. Since pipes and pumps buried within
the waste eventually clog up and fail, there will be less chance of
collecting and treating these emissions if they occur in the distant

LANDFILL ENGINEER PAT SULLIVAN: "The driving force behind the use of
reactive landfill technologies arises from market concerns and community
expectations that conventional landfills are no longer practical and
profitable as a means of disposal for MSW."

Recycling competes, in an economic sense, against the cost of disposal.  The
cheaper the disposal option the more difficult for diversion programs to
financially justify themselves (when subsidies are ignored), and the more
expensive disposal, the easier job that recycling has to do so.

Obviously, that does not mean that disposal costs should be increased JUST
to make recycling "look" better. But, on the other hand, it most definitely
does mean that we simply cannot let disposal continue to be done in a manner
that is going to bequeath a toxic legacy for our grandchildren when the
intricate barrier systems fail.  The twentieth century has left the 21st
with 3,000 LICENSED superfund sites that is going to costs hundreds of
billions of dollars to attempt to remediate.

It is terribly wrong that the price of disposal today does not reflect the
actual future costs that it will impose on society, and just as wrong that
recycling's economics is being compared against failed disposal systems.
Bioreactors, just to note quickly to keep the size of this note manageable,
as they are being designed on-the-cheap, are more likely to make the present
untenable situation worse.

There is an all-pervasive belief in EPA's leadership, which mindlessly
reflects what it is told by the waste industry, that changes in landfill
requirements cannot be permitted which increase disposal costs above
$20-30/ton.  Where that comes from is a good question. Last I looked,
nowhere is that written on Mose's tablets, nor on the parchment of our

Raising disposal costs to a level where there is some reasonable chance that
the environment will be protected, as the law does require, might increase
tip fees to $60/ton.  That works out to about two bucks per household per
month ... the price of one latte, or an extra channel on cable.

Is the American public willing to pay that small amount? If they are
educated to understand that keeping their grandchildren's drinking water
free of dangerous levels of benzene and other cancer causing compounds from
leaking landfill, it is just obscene to argue that they would prefer a 151st
cable station first.  Who would say such a thing.  The answer is everyone in
the executive suites of the EPA and the vertically integrated national waste
companies. It is they who are out of touch and it is our responsibility to
inform the public of the travesty that is being done in their name.

There is no more important single battle for recyclers to wage than to
prevent the coming train wreak, both to protect our progeny, and to provide
an economic foundation on which we can solidly build a positive
environmental alternative in recycling.


Peter Anderson
4513 Vernon Blvd. Suite 15
Madison, WI 53705
Ph:    (608) 231-1100
Fax:   (608) 233-0011
Cell:   (608) 345-0381

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