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[GreenYes] Disposal Impacts
Stoneyfield Farms writes: "The Tellus [life cycle] study findings were
surprising, indicating that less than 5% of the total environmental cost of
packaging is in the disposal. Over 95% of the environmental cost is in the
production of the package!"

While Stoneyfield is correctly quoting Tellus's LCI findings, those findings
are WRONG, suffering from the typical problem with these studies, garbage
in, garbage out.

If one ASSUMES that disposal is perfectly safe when specifying the inputs
for an LCI run, then, it is not at all that surprising that the outputs will
show no significant impacts from disposal.  But that does not add terribly
much to the fount of human knowledge, and the fact that it is encased in a
LCI wrapper confers no legitimacy upon flawed research.

At the time that that study was being prepared for publication, we attempted
to correct their perfectly-safe disposal assumption, but were put off
because EPA had told them that there are no significant impacts because the
Subtitle D regulations promulgated in 1991 have ended open dumps and
mandated highly engineered sanitary landfills.  No amount of technical
information would sway Tellus.

For the six years that followed, we have continued to hammer the point,
first raised by Fred Lee and Bob Ham, that liner based landfills were
fatally flawed, in that all manmade barriers will ultimately deteriorate and
fail.  By adding an elaborate system of barriers, all that we have done is
postponed instead of preventing pollution, and to the very worst time when
the responsible parties have long left the scene and the monitoring wells to
detect the leakages and leachate collection systems to relieve the hyraulic
head pressure have failed.

And, by dint of persistence, this has now become the conventional wisdom
even among those in the landfill business:

                        EPA Inspector General

"EPA officials have stated that based on current data and scientific
prediction, the release of contaminants may eventually occur, even with the
application of best available land disposal technology. There is concern
that these barriers will merely postpone the inevitable release of
contaminants until after the 30-year liability has expired. As previously
stated, some sites contain materials which are highly resistant to
decomposition or which remain toxic forever. There have been several studies
to determine the expected life span of landfill liners, and opinions on this
issue vary widely. The bottom line is that not even the manufacturers claim
that their liners will last forever. Many liners are only warrantied for a
period of 20 years, and landfill caps are only expected to last for 20
years. Leachate collection systems have a finite life, as drains clog, and
pumping capacity declines with time. In our sample, we found several
examples of barriers failing during the first 30 years. Most of the states
in our sample reported animal or weather-related damage at their sites.
"EPA officials acknowledge the lack of criteria or scientific basis for
establishing the 30-year post-closure time frame. Initially, the proposed
post-closure care time frame for Subtitle C hazardous waste disposal
facilities had been set for a period of 20 years. Comments expressed in a
1980 Federal Register Notice asked EPA to extend the time frame of 20 years
of post-closure for Subtitle C facilities to as long as the wastes remain
hazardous, possibly in perpetuity. However, some who commented were
concerned that an extended time frame would place an economic burden on
smaller businesses. Therefore, EPA made the decision to establish the time
frame at 30 years, seemingly based on a compromise of these competing
interests. EPA officials we spoke to agreed that the 30-year time frame was
not based on specific scientific criteria or research studies." (Office of
the Inspector General, RCRA Financial Assurance for Closure and Post-Closure
(2001-P-007) (March 30, 2001), at pp. 31-34.)

    John Skinner, Executive Director of the Solid Waste Management

"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
post-closure 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 governments." (John Skinner,
Composting and Bioreactors," MSW Management (July/August 2001), at p. 16.)

    Peter White, Procter & Gamble Environmental Engineer

"...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 future." (Peter White, et. al.,
Integrated Solid Waste Management: A Lifecycle Inventory (Aspen Pub. 1999),
at p. 275.)

        John Pacey, Landfill Engineer

"The containment provided by these landfills offers environmental protection
initially; however, at some point beyond the 30-year [postclosure] period,
there may be partial failure(s) of the containment lining system (underlying
and overlying the waste). The primary environmental issue associated with
partial containment system failure and moisture infiltration is the
potential associated increase in gas and leachate production and the
resulting impact of uncontrolled leachate and/or landfill gas releases to
the environment. The nature and magnitude of the releases exiting the
landfill and their resulting impacts is directly related to the amounts of
organic waste not yet decomposed." (John Pacey, et. al., The Bioreactor
Landfill - An Innovation in Solid Waste Management, Monograph (2001), at p.

                Pat Sullivan, Landfill Engineer

"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." (Pat
Sullivan, "Just What is a Bioreactor Landfill," MSW Management (July/August

    Christopher Campman, Landfill Engineer

"The major environmental concerns regarding MSW landfills are related to gas
migration and leachate discharges. The current federal regulations governing
MSW landfills under Subtitle D of the Resource Conservation and Recovery Act
emphasize minimizing infiltration, collecting leachate generated by the
landfill, and mandate maintenance of the landfill integrity for a minimum
period of 30 years. These regulations create conditions that delay, rather
than eliminate, the eventual degradation of MSW, leading to the creation of
a 'dry tomb.' Landfills continue to generate leachate and gas for decades
following waste placement, possibly beyond the current 30-year postclosure
monitoring period. Research has shown that a significant portion of the
biodegradable fraction of waste placed in conventional MSW landfills remains
relatively unstabilized following decades of landfilling." (Christopher
Campman, "Bioreactors, An Idea Whose Time Has Come," MSW Management
(Sept./Oct. 2002).

    All this has enormous implications for recyclers in communities that
expect us to "make money," i.e. not cost more to divert than to discard.
Because recycling competes against disposal, if landfills are permitted to
pollute, that means we're unfairly being asked to compete against someone
who is being subsidized.  When it recognized that almost all of the licensed
MSW landfills are tomorrow's superfund sites, then it can be seen that
today's tipping fees of $20-30 per ton really should be recorded at more
than $50/ton once those future multi-million dollar remediation costs are
present valued back to the present.

    Though Tellus' analysis of production impacts is a reasonable and
valuable first cut look at front end impacts, their study incorrectly fails
to recognize the critical facts about back end externalities, and, in doing
so, does recycling a grave injustice.

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

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