EPA SAYS ALL LANDFILLS LEAK, EVEN THOSE USING BEST AVAILABLE
LINERS
People who are enthusiastic about garbage incinerators often
fail to mention that every incinerator has a landfill associated
with it. The ash left over from incineration needs to be
landfilled, and the ash is toxic. Some engineers (especially
those employed to promote garbage incinerators) try to argue
that the toxic constituents of the ash will remain safely in the
landfill "forever." But this is a flawed view: the weight of
evidence and opinion in the technical world does not agree with
this argument. On the contrary, even the U.S. Environmental
Protection Agency says that all landfills will leak. The agency
has published this opinion on many occasions in the FEDERAL
REGISTER. But before we look at the EPA's reasons for believing
all landfills will leak, let's look at the way landfills are
constructed:
A landfill is a carefully-engineered depression in the ground
(or built on top of the ground, resembling a football stadium)
into which wastes are put. The intention is to avoid any
hydraulic [water-related] connection between the wastes and the
natural environment. To achieve this goal, there are four
important parts of all landfills: a bottom liner, a leachate
collection system, a cover, and the natural hydrogeologic
setting (the earth).
The hydrogeologic setting can be selected to slow the entry
of wastes into the natural environment. The other three
components must be engineered. The bottom liner can be one or
more layers of clay or a synthetic flexible membrane liner [FML],
for example, a sheet of plastic; the liner effectively creates a
bathtub in the ground. The leachate collection system consists
of sloping the sides of the landfill and putting pipes in the
lowest places, to pump out contaminated water and other fluids (leachate)
as they accumulate; the pumped leachate is treated at a
wastewater treatment plant (and the solids removed from the
leachate during this step are returned to the landfill, or are
sent to some other landfill). The cover or cap will consist of
several sloped layers of clay or FML (to prevent rain from
intruding), overlain by a very permeable layer of sandy or
gravely soil, overlain by topsoil in which vegetation can root
(to stabilize the underlying layers of the cap).
Each of these components is critical to success. If the
bottom liner fails, wastes will migrate directly into the
environment. If leachate collection pipes clog up and leachate
remains in the landfill, fluids can build up in the bathtub; the
resulting liquid pressure becomes the main force driving waste
out the bottom of the landfill when the bottom liner fails. If
the cover (cap) is not maintained, rain will enter the landfill,
resulting in buildup of leachate to the point where the bathtub
overflows its sides and wastes enter the environment.
In the FEDERAL REGISTER Feb. 5, 1981, the EPA first stated
its opinion that all landfills will eventually leak:
"There is good theoretical and empirical evidence that the
hazardous constituents that are placed in land disposal
facilities very likely will migrate from the facility into the
broader environment. This may occur several years, even many
decades, after placement of the waste in the facility, but data
and scientific prediction indicate that, in most cases, even
with the application of best available land disposal technology,
it will occur eventually." [pg. 11128]
"Manmade permeable materials that might be used for liners or
covers (e.g., membrane liners or other materials) are subject to
eventual deterioration, and although this might not occur for
10, 20 or more years, it eventually occurs and, when it does,
leachate will migrate out of the facility." [pg. 11128]
"Unfortunately, at the present time, it is not
technologically and institutionally possible to contain wastes
and constituents forever or for the long time periods that may
be necessary to allow adequate degradation to be achieved." [pg.
11129]
"Consequently, the regulation of hazardous waste land
disposal facilities must proceed from the assumption that
migration of hazardous wastes and their constituents and
by-products from a land disposal facility will inevitably
occur." [pg. 11129]
More than a year later, on July 26, 1982, the EPA again put
its opinions into the FEDERAL REGISTER, emphasizing that all
landfills will inevitably leak:
"A liner is a barrier technology that prevents or greatly
restricts migration of liquids into the ground. No liner,
however, can keep all liquids out of the ground for all time.
Eventually liners will either degrade, tear, or crack and will
allow liquids to migrate out of the unit." [pg. 32284]
"Some have argued that liners are devices that provide a
perpetual seal against any migration from a waste management
unit. EPA has concluded that the more reasonable assumption,
based on what is known about the pressures placed on liners over
time, is that any liner will begin to leak eventually." [pgs.
32284-32285].
In the FEDERAL REGISTER May 26, 1981, pgs. 28314 through
28328), the EPA argued forcefully that all landfills will
eventually leak. Another EPA quote:
"Many organic constituents are stable (degrade very slowly);
other hazardous constituents (e.g., toxic metals) never degrade.
Yet the existing technology for disposing of hazardous wastes on
or in the land cannot confidently isolate these wastes from the
environment forever.
"Since disposing of hazardous wastes in or on the land
inevitable [inevitably?] results in the release of hazardous
constituents to the environment at some time, any land disposal
facility creates some risk." [pg. 28315]
EPA went on to estimate that the duration of the hazard from
a landfill would be "many thousands of years." [pg. 28315] And
the Agency said, "The longer one wishes to contain waste, the
more difficult the task becomes. Synthetic liners and caps will
degrade; soil liners and caps may erode and crack. ...EPA is not
aware of any field data showing successful long-term containment
of waste at facilities which have not been maintained over
time." [pg. 28324]
"Ultimately, waste reduction and resource recovery probably
provide the best alternative to land disposal," said the EPA
[pg. 28325], though it has never begun any programs to make this
happen.
--Peter Montague, Ph.D.
Descriptor terms: ash; epa; landfills; soil; leachate;
hazardous wastes; land; land disposal; metals; water pollution;