To: Activists concerned about landfills
Fr: Greenpeace Research Division
Da: 2 May 1989
If landfills are an issue in your area, you should find the
following information of interest:
"Disposal of "nonhazardous" solid waste is regulated under
Subtitle D of the Resource Conservation and Recovery Act (RCRA).
These Subtitle D wastes include many different types of waste
streams, such as municipal solid waste, industrial waste, and oil
and gas waste."
"More than 11 Billion Tons of Subtitle D Waste Are Produced
Annually in the United States. Of this total more than 95 percent
are industrial nonhazardous waste, oil and gas waste, mining waste,
and municipal solid waste. Each type of waste presents unique
management problems and risks."
"There are 226,732 Subtitle D units in the United States.
Eighty-four percent of this total are surface impoundments, 8
percent are land application units, 6 percent are landfills, and 2
percent are industrial waste piles. Of the nearly 13,000 landfill
units identified, 6,584 are municipal solid waste landfill units."
"Shortages of Municipal Solid Waste Landfill Capacity are
Occurring in Some Areas of the Nation. The shortages are due to
several factors: (1) 83 percent of the municipal solid waste
generated in 1986 was landfilled; (2) 45 percent of all municipal
solid waste landfills will close by 1991; (3) some States have not
conducted long-term planning; and (4) siting of new disposal
facilities is difficult."
"Municipal solid waste landfills have degraded and may continue
to degrade the environment."
"... the data indicate that releases to the ground water from
municipal solid waste landfills present potential risks to human
health."
"Acute human health impacts associated with methane releases have
been documented."
"... the limited available data on industrial Subtitle D
facilities indicate that there is cause for concern and a need for
further study. Current findings include: (1) the use of design
controls at industrial facilities is very limited; (2) the number of
industrial facilities is large and the amount of industrial
nonhazardous waste generated annually dwarfs the amount of municipal
solid waste; ..."
"Waste tires, infections waste, and municipal waste combustion
ash are examples of special Subtitle D wastes. The special
management concerns posed by these waste streams arise from the
unique characteristics of these wastes. Current data are not
sufficient to estimate reliably the risks posed by these wastes."
"Federal and some State solid waste regulations lack the
following essential requirements: location criteria, appropriate
design criteria, ground-water monitoring, corrective action, closure
and post-closure care, and financial responsibility."
1
"... HSWA [1984 Hazardous and Solid Waste Amendments to RCRA]
requires EPA to revise the current criteria for facilities that may
receive household hazardous waste or small-quantity generator
hazardous waste."
"... the Subtitle D waste stream is very diverse. Such different
waste types as waste tires, infectious waste, industrial
nonhazardous waste, and municipal solid wastes are all regulated
under Subtitle D of RCRA. .. the industrial nonhazardous waste
category includes waste from the pulp and paper industry, the
organic chemical industry, the textile manufacturing industry and a
variety of other industries."
"Each Subtitle D waste type presents unique problems and risks."
"Table 1. Subtitle D Waste Categories and Quantities
Estimated Annual Generation Rate
Waste Category (million tons)
Industrial Nonhazardous Waste 7,600 (a,b)
Oil and Gas Waste (c)
-drilling waste 129 - 871 (d,e)
-produced waters 1,966 - 2,738 (e,f)
Mining Waste (c) > 1,400 (g)
Municipal Solid Waste 158 (b)
-household hazardous waste 0.002 - 0.56 (b)
Municipal Waste Combustion Ash 3.2 - 8.1 (h)
Utility Waste (c)
- ash 69 (i)
-flue gas desulfurization waste 16 (i)
Construction and Demolition Waste 31.5 (j)
Municipal Sludge
- wastewater treatment 6.9 (b)
- water treatment 3.5 (b)
Very-Small-Quantity Generator
Hazardous Waste (<100 kg/mo) 0.2 (e)
Waste Tires 240 million tires (g)
Infectious Waste 2.1 (e,l)
Agricultural Waste Unknown
Approximate >11,387
a: Not including industrial waste that is recycled or disposed
of off site.
b: These estimates are derived from 1986 data.
c: Waste category is the subject of a separate report to
Congress
d: Converted to tons from barrels: 42 gals = 1 barrel, ~17
lbs/gal
e: These estimates are derived from 1985 data.
f: Converted to tons from barrels: 42 gals = 1 barrel, ~8
lbs/gal
g: These estimates are derived from 1983 data.
h: This estimate is derived from 1988 data.
i: These estimates are derived from 1984 data.
j: This estimate is derived from 1970 data.
k: Small quantity generators (100-1,000 kg/mo) have been
regulated under RCRA, Subtitle C, since October 1986. Before
then, approximately 830,000 tons of small-quantity generator
hazardous wastes were disposed of in Subtitle D facilities
every year.
2
l: Includes only infectious hospital waste.
"This study estimates that there are 226,732 Subtitle D units
located at approximately 128,000 establishments. (An establishment
may have more than one unit.) Of these units, 84 percent are
surface impoundments, 8 percent are land application units, 6
percent are landfills, and 2 percent are industrial waste piles ...
More than half the units are oil and gas surface impoundments.
Municipal solid waste landfills account for nearly half of the
landfills and more than two-thirds of the land application units
are municipal sewage sludge units."
"Most of the Subtitle D facilities are privately owned. This is
because of the overwhelming number of privately owned oil and gas,
industrial, and mining waste facilities. In addition,
approximately 17 percent of municipal solid waste landfills are
privately owned. However, municipal solid waste landfills are
predominantly publicly owned. Nearly 78 percent of municipal solid
waste landfills are owned by local governments, approximately 4
percent by the Federal government, and 1 percent by State
government."
"Table 2. Estimated Number of Active Subtitle D Units
Unit Type
Waste Category Landfills Surface Land Waste
Impoundments Application Piles Total
Municipal solid
waste 6,584(a) b b b 6,584
Industrial waste 2,757(c) 15,253 (c) 4,308(c) 5,335 (c) 27,654
Municipal Sewage
Sludge d 1,938 11,937 b 13,875
Oil and Gas Waste (e) b 125,074 726 b 125,800
Agricultural Waste d 17,159 b b 17,159
Mining Waste (e) d 19,183 b d 19,813
Municipal Runoff b 488 b b 488
Construction and
Demolition Debris 2,591 b b d 2,591
Miscellaneous
Waste 1,030 11,118 621 d 12,769
Appropriate Total
Number of Units 12,962 190,843 17,592 5,335 226,732
a: The results of a previous census of the States indicated 9,300
municipal solid waste landfills. However, the table entry is
considered more accurate. It is based on a 1986 Survey.
b: Unknown, none or few thought to exist.
c: These estimates differ from previously published results from a
census of the States. Table entries are considered to be more
accurate. They are based on a 1986 Industrial Survey.
d. Unknown, some may exist.
e. Waste category is the subject of a separate report to Congress.
"Approximately 83 percent of the municipal solid waste generated
in 1986 was disposed of in landfills, while only 11 percent was
recycled, and only 6 percent was combusted."
"Nearly three-fourths (74 percent) of all municipal solid waste
landfills are expected to close within 15 years, with 45 percent
expected to close in 5 years .... These shortages are becoming
critical in densely populated areas of the country, particularly in
3
the Northeast."
"Municipal solid waste landfills and the waste they receive have
been characterized reasonably well, and some impacts associated with
municipal solid waste landfills have been identified. However,
leachate and gas data for these facilities are limited."
"Comparatively less is known about industrial wastes and
facilities. Specific industrial waste streams have not been well
characterized and little is known about the hazards they may pose."
"... the data indicate that some municipal solid waste landfills
present potential risks to human health. Human health impacts from
exposure to contaminant releases to ground water from municipal
solid waste landfills are difficult to isolate due to the complex
interaction of factors that affect human health."
"With regard to air emissions from municipal solid waste
landfills, acute impacts associated with methane releases have been
documented. The Agency is currently determining the extent of human
health risks that may result from emission of volatile organic
compounds, which have been estimated to be in the range of 200,000
megagrams per year."
"The number of industrial facilities is very large, as is the
amount of waste they handle. Because current data are limited, it
is not possible to draw conclusions regarding the risks posed by
these facilities. Existing data however, do suggest that these
facilities need to be further investigated to determine the need for
additional regulatory action."
"Data on post-1980 facilities [solid waste landfills] are very
limited. (These newer sites represent only 30 percent of the
municipal solid waste landfills in existence today)."
"... on a national basis, EPA found little difference in the
location, design, and operation of newer municipal solid waste
landfills versus older landfills."
"Some large-quantity [hazardous waste] generators may also be
illegally disposing of their hazardous wastes in municipal solid
waste landfills."
"... environmental impacts and threats to human health have been
documented at 163 municipal solid waste landfills."
"Ground-water and surface water quality were adversely affected
at 146 and 73 municipal solid waste landfills, respectively. While
the impacts identified range in severity, 33 sites have contaminated
drinking water resources, and three other sites pose a threat to
water supply systems. For example, one active municipal solid waste
landfill has contaminated a square mile of a sole-source aquifer and
has closed a major community well field. ... Elevated levels of
organics, including pesticides, and metal contaminants have been
found in ground water and/or surface water at many sites."
"Impacts on fish or other aquatic life have been documented at 13
sites. ... this small number of cases does not likely reflect the
actual number of occurrences."
Superfund Statistics
"To be listed on the NPL [Superfund National Priorities List], a
site must present or be capable of presenting significant
environmental and/or human health impacts. Of the 850 sites listed
or proposed for listing on the NPL in May 1986, 184 sites (22
percent) were identified as municipal solid waste landfills."
"Halogenated organics, aromatics, and metals were found at most
4
of these sites. Releases of hazardous materials to ground water
were documented at nearly 75 percent of the sites. Forty-three
percent had releases to surface water, and 16 percent had
significant air emission problems."
Methane Damage
"Methane is produced in municipal solid waste landfills through
anaerobic decomposition of organic waste, and is explosive at
sufficiently high concentrations (the lower explosive limit). ...
where methane is not controlled, it can cause fires and explosions."
Ground-Water Risk Assessment
"To characterize typical leachate from a municipal solid waste
landfill, the AGency chose eight constituents from more than 200
chemical constituents found in municipal solid waste leachate. ...
The eight constituents and the effect of concern for each are as
follows:
- Vinyl Chloride human health risk (cancer)
- Arsenic human health risk (cancer)
- Iron resource damage (taste and
odor)
- 1,1,2,2,-Tetrachloroethane human health risk (cancer)
- Methylene chloride human health risk (cancer)
- Antimony human health risk (systemic
poisoning)
- Carbon Tetrachloride human health risk (cancer)
- Phenol resource damage (taste and odor)"
The analysis estimates human health risk for the maximum exposed
individual and the total population using ground water as a drinking
water source within one mile of the facility. ... Current data
indicate that 54 percent of existing municipal solid waste landfills
have no downgradient drinking water wells within one mile."
"For the subgroup of landfills located within one mile of a
drinking water well (46 percent of all landfills), nearly 40 percent
have risk exceeding 10(-6), with 14 percent posing risk in the 10(-
5) to 10(-4) range."
"The overall risk distribution changes significantly if it is
assumed that all drinking water wells are located at the facility
boundary (assumed to be 10 meters from the landfill unit). This
scenario, although certainly very conservative, helps to identify
the number of landfills that may contaminate the ground water
beneath the facility above health-based limits. Making this
assumption, over 67 percent of the landfills would hypothetically
pose risks exceeding 10(-6), with approximately 35 percent posing
risks in the 10(-5) to 10(-4) range."
"In present-value terms, the Agency estimates that resource
damage from municipal solid waste landfills ranges from $0 to more
than $4 million per site. The model predicts that nearly a third of
the landfills would have resource damage exceeding $200,000, and
about 13 percent have resource damage in excess of $1 million."
"The model estimates that the resulting total plume area from
6,000 new facilities placed in existing landfill locations would be
roughly 1,114 square miles (an area slightly smaller than the state
of Rhode Island) over the 300-year modeling period."
"Municipal solid waste landfills receive a variety of wastes ...
While the overall waste stream is considered to be less hazardous
than that received at RCRA Subtitle C (hazardous waste) facilities,
5
it nevertheless is a source of concern. By far, the majority of
waste disposed of at municipal solid waste landfills is household
waste (72 percent of the total waste stream). Household waste
is primarily made up of nonhazardous materials such as paper. Some
nonhazardous material, however may contain hazardous constituents,
such as, lead in newsprint. In addition, within a landfill, some of
these nonhazardous materials may degrade biologically and/or
chemically and form more toxic constituents. ... Also, about 0.35 to
0.40 percent of the overall household waste stream includes
hazardous components. Constituents of concern in household
hazardous waste include solvents, pesticides, other organics, acids,
bases, medicines, and inks ...
"Table 4: Wastes Disposed of in a Typical Municipal Solid Waste
Landfill
Waste Types Waste Composition Percentage (a)
(mean value)
Household Waste 72
Commercial Waste 17
Construction/Demolition Waste 6
Industrial Process Waste 2.73
Other Waste 1.18
Sewage Sludge 0.50
Other Incinerator Ash 0.22
Asbestos-Containing Waste 0.16
Municipal Incinerator Ash 0.08
VSQG Hazardous Waste 0.08
Infectious Waste 0.05
(a) Percentages are rounded and do not add to 100 percent.
"The other 28 percent of wastes received at municipal solid waste
landfills includes very-small-quantity generator (VSQG) hazardous
waste, commercial waste, industrial process waste, infectious waste,
municipal incinerator ash, and asbestos-containing wastes. Some of
these waste streams may contain potentially hazardous constituents.
Congress, in the 1984 amendments to RCRA, was particularly concerned
with VSQG waste. This waste stream accounts for a small part of the
overall waste stream received at municipal solid waste landfills;
however, some relatively hazardous or toxic materials are present in
the VSQG waste stream ... Used lead acid batteries are the largest
single source of VSQG waste.
"Categories of Very-Small-Quantity Generator Wastes
Arsenic waste Photographic wastes
Cyanide wastes Solutions of sludges
Dry cleaning filtration containing silver
residues Solvent still bottoms
Empty pesticide containers Spent plating wastes
Heavy metal dust Spent solvents
Heavy metal solutions Strong acids or alkalies
Heavy metal waste materials Used lead-acid batteries
Ignitable paint wastes Waste formaldehyde
Ignitable wastes Waste inks containing flammable
Ink sludges containing solvents or heavy metals
chromium or lead Waste pesticides
Mercury wastes Wastes containing ammonia
Other reactive wastes Wastewater containing
Paint wastes containing wood preservatives
6
heavy metals Wastewater sludges containing
Pesticide solutions heavy metals"
"Of the 70 sites [municipal solid waste landfills] for which EPA
has data, 53 of them were analyzed for some organic constituents,
and 62 for some inorganic constituents. ... A total of
approximately 82 leachate constituents were found -- 63 organics and
19 inorganics. ... the median concentration values of the leachate
constituent data were compared to EPA drinking water and/or human
health criteria concentrations. ... The median concentrations of
all the carcinogens (nine constituents) were above the health-based
criteria for these compounds. In a number of cases, the median
concentrations of all the carcinogens (nine constituents) were above
the health-based criteria for these compounds. In a number of
cases, the median concentrations would take more than a 1000-fold
dilution in order to meet the health criteria."
"... leachate quality tends to change over time as the landfill
moves through the stabilization process. However, where leachate
data are available for both pre- and post-1980 landfills, no trend
is apparent. Median concentrations for leachate from post-1980
landfills are higher than those for pre-1980 landfills for
approximately 50 percent of the constituents."
"Landfill gas adds to the potential for impacts from municipal
solid waste landfills ... Methane, which is explosive, accounts for
about 50 percent by volume of the total gas stream. ... trace
constituents (up to 2 percent) of volatile organic compounds (VOCs)
and toxic constituents also may be present. Toxic constituents
commonly found in municipal solid waste landfill gas include vinyl
chloride, benzene, trichloroethylene, and methylene chloride."
MSW Disposal on Indian Lands
"At present there are 314 Federally recognized Indian Tribes and
198 Alaskan Native villages in the United States covering an area of
approximately 87,000 square miles ... The total population of this
land is approximately one million. The Indian Health Service (IHS)
has identified 576 municipal solid waste disposal sites on Indian
lands."
"Several EPA-sponsored surveys indicate that Indian Tribes
perceive municipal solid waste disposal as current and future
environmental problem. One survey reported that on half of the
reservations surveyed (24) "community dumps" were used for disposal.
Another reported 66 open dumps on Indian lands in EPA's Region 5
alone. Roadside dumping and other illegal dumping were also
reported. Landfill leachate was cited several times by the Tribes
surveyed as the potential source of water pollution.
[unfinished: more on Industrial Subtitle D facilities; waste
tires; infectious waste; municipal solid waste combustion ash]
--Source: "Report to Congress: Solid Waste Disposal in the United
States," Volume I, EPA 530-SW-88-011, October 1988
7
=====================================================================
Citizens fighting landfill problems will also be interested in
the following resources:
"Landfill Packet" A series of ten articles about problems with
landfills, available from the Environmental Research Foundation,
P O Box 3541, Princeton NJ 08543, 609-683-0707.
"Debunking the Landfill High Technology Myth" A thick, excellent
report on the facts behind what the disposal companies try to
tell you. By Blythe Coza, produced by People Against Hazardous
Landfill Sites, 219-759-1800.
"Recycling Kit" Produced by Bryan Bence of Greenpeace. Write to
Bryan at Greenpeace, 1436 U St NW, Washington DC 20009, 202-462-
1177.
---===000===---
8