 
 
 
        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
          
 
 
 
 
          
          
 
 
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        =====================================================================
 
        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.
 
 
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