Describe how air emissions are determined.
Assess the political environment as it relates to solid waste and solid waste management.
Reading Assignment Chapter 8: Landfills
Unit Lesson Landfill discussions in an academic setting usually focus on presenting the design criteria and the basic operational aspects of how a landfill works (U.S. Government Printing Office, 2012). What is commonly left out are the regulatory requirements that establish the foundation for the design criteria and the operational processes of the facility. One of the most important requirements is that of recordkeeping and the need to file monthly and annual reports with regulatory and permitting authorities (North Dakota Department of Health, 2014). When a new facility is ready to start up and accept waste at the landfill, the new owner/operator must first submit and receive an approval for an initial report that details the site, the facility design and operation, location maps, plans, schematic drawings, and test results certifying that the design of the facility is in compliance with the requirements of the permit. The initial report must also describe the formal records that are intended to be maintained at the site including a description of the waste categories that will be accepted at the site. Tracking the weights or volumes of the waste will give authorities an indication of the rate that the landfill capacity is being used by the municipality. All official records need to be located and made available at a single location to facilitate a formal audit of the site and facility operations. The data and information in the records and reports must be backed up by either an electronic or a paper trail. The requirement to keep records can extend to the 30-year period following closure of the landfill. If the landfill begins to leak leachate into the groundwater, these records will be important to show the types of waste that were received and disposed of at the facility. They will also be assessed to determine the potential impact that the chemical in the leachate can exert on the environment. What makes groundwater contamination so challenging is that it is mobile and it has the potential to travel large distances down gradient, especially if the sub-soil geology is porous (like limestone) or if the groundwater feeds an aquifer. Unknowingly, the contaminated groundwater can be pumped to the surface by a farmer to irrigate crops, to provide potable water for dairy herds, or even to be used by a family as their primary source of potable water. If the groundwater contaminated by the leachate contains certain types of chemical structures, these chemicals can pass into the milk of the cow and be consumed by a child when milk is purchased at the supermarket in another region of the county. This situation is analogous to the potential hazards that exist today with fracking operations. In these scenarios where fracking goes bad, chemicals are intentionally injected into the underground geology, and, occasionally, some of these make their way into the groundwater as contaminants. When a suitable landfill site is selected, there are many variables that need to be considered. These include the obvious criteria of not building close to an airport (blowing papers and debris can impede pilot visibility and get into the engine), not building on a floodplain (landfills are to be kept dry otherwise leachate generation
UNIT VII STUDY GUIDE
Structure and Design of Municipal Solid Waste Landfills
MEE 5901, Advanced Solid Waste Management 2
UNIT x STUDY GUIDE
rates rapidly increase), and not building in areas that are unstable or are known to be active seismic zones. The textbook covers these criteria as well as more site selection criteria in greater detail. The records to be kept about the site selection should document the criteria used to select and qualify the site. This can include maps that show the distance of the site from airports, floodplains, and locations with seismic activity. The owner/operator of the landfill should also document the training records of its employees and contractors. This requires recording the identity of the trainee, the date of the training, a summary of the material that was covered in the training, and some metrics that show how well the material was learned by the trainee. The work practices, processes, and procedures that are used at the site should also be recorded and archived within a formal management of change program. Should an employee retire and later claim harm, these records are essential for showing the practices that were in effect at the time when the plaintiff claims that he or she was harmed. Matching this documentation with the waste categories that were handled and disposed at the landfill will also help to prove or disprove if hazardous materials like asbestos-containing construction debris went into the landfill. This is one reason why landfill operators record the names of vehicle drivers and the vehicle VIN numbers along with the locations where the vehicle collected the trash intended for disposal in the landfill. If it turns out later during discovery in a litigation case that the documents showed that a transport driver improperly collected hazardous wastes (asbestos, polychlorinated biphenyls [PCBs], radioactive wastes) from a manufacturing or construction site, the transport company will also be declared to be a legally responsible for the harm caused to workers, the community, or the environment. The records are a key defense in being able to prove in the future that proper procedures were followed and that the landfill was compliant with its operating permit and work practices. In addition to what is reported to the local and state regulatory authorities, additional information must be collected and reported. This includes gas generation rates at the landfill. If the methane levels get close to the lower explosive limit (LEL) at the surface of the landfill, the operator must take steps to protect human health, especially that of the workers placing refuse and fill into the landfill. If these events continue to repeat themselves, a remediation plan must be developed and placed into the site operational plan. Another requirement is to maintain all records related to groundwater sampling and testing for chemical components commonly found in leachate. Often, up-gradient groundwater samples are taken when there is suspicion that the contaminant in the groundwater may be caused by another source and not from the landfill. Successfully convincing the regulators and the courts can transfer the costs and burden of remediation to the noncompliant party. When the capacity of the landfill nears its limit and closure protocols are implemented, the site records must include details and documentation about how the landfill was closed. After the post-closure plans are initiated, the party (often an environmental consultant) monitoring the state of the landfill will also need to keep the records updated and available. This includes ensuring that surface gradients and slopes are maintained to keep water from infiltrating the landfill to form leachate. If soil erosion has occurred or if the cap has developed deep cracks exposing the waste, the cap must be reestablished and regraded and the types of vegetation and plants that provide protection to the soil must be established. Methane generation levels must be tracked and analyzed to give an estimate of the level of stabilization that has occurred in the landfill. The groundwater wells must be periodically monitored for pollutants to confirm the integrity of the landfill liner. If there is a liner breach, procedures must be put into place to pump and capture contaminated groundwater, and a remediation plan will need to be implemented to address the condition of the liner. All this must go into the records and be maintained for a minimum of 30 years after the landfill is closed and capped. Just as important as the landfill itself is maintaining an adequate buffer zone that separates the landfill from surrounding properties used for residential or commercial purposes. When the condition of a landfill is ignored and odors, leachate, and surface runoff start to adversely affect close neighbors, those neighbors will likely use the court system to address these issues. Whenever there is an adverse event, it will be the records of the site that were generated and maintained during the design, construction, active life, and post-closure timeframes that will be instrumental in assessing the potential impact to human health and to the environment as well as assigning fault and liability to responsible parties when adverse events are litigated in the courts.
MEE 5901, Advanced Solid Waste Management 3
UNIT x STUDY GUIDE
References U.S. Government Publishing Office. (2012). Code of Federal Regulations: Part 258 – Criteria for municipal
solid waste landfills. Retrieved from https://www.gpo.gov/fdsys/pkg/CFR-2012-title40-vol26/xml/CFR- 2012-title40-vol26-part258.xml
North Dakota Department of Health (2014). Guideline 4 – Recordkeeping and reporting by owners or
operators of municipal waste landfills. Retrieved from http://www.ndhealth.gov/wm/publications/Guideline4RecordkeepingAndReportingByOwnersOrO peratorsOfMunicipalWasteLandfills.pdf
Suggested Reading To learn more about the requirements for landfills created by the Environmental Protection Agency (EPA), click on the link below. These requirements include monitoring, recordkeeping, and reporting of information required of landfills. United States Environmental Protection Agency. (1999). Municipal solid waste landfills, volume 1:
Summary of the requirements for the new source performance standards and emission guidelines for municipal solid waste landfills. Retrieved from https://www3.epa.gov/airtoxics/landfill/lf-vol1.pdf
Learning Activities (Non-Graded) Practice the skills learned in this unit by completing the following activity: Review the regulatory requirements related to allowable air emissions, then discuss the following.
Describe how air emissions are determined.
Describe the allowable limits that can be discharged into the atmosphere.
Describe two techniques for controlling landfill emissions.
Describe monitoring requirements and techniques for quantifying air emissions. Non-graded Learning Activities are provided to aid students in their course of study. You do not have to submit them. If you have questions, contact your instructor for further guidance and information.
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