Closed Landfill Maintenance
Monday, February 06, 2012
By Neal Bolton
So, you have a closed landfill.
This isn’t surprising. There are tens of thousands of them across the country. As you know, or will soon discover, closed landfill post-closure care is an ongoing process. You are—or will be—responsible for landfill maintenance, monitoring, inspections, and upkeep. Having a closed landfill is what you might call a long-term relationship…very long.
The EPA’s primary landfill rules, Subtitle D, apply universally to all states. These rules initially required a 30-year post-closure maintenance period. In other words, once you closed your landfill, you were bound by these rules to maintain your landfill for 30 years.
At the time, this was a bitter pill to swallow, with many owners of closed landfills feeling that 30 years was a very long time.
However, there was some logic to the number. At the time, 30-years was expected to be long enough that the waste mass inside the landfill would settle and stabilize. Essentially, many thought that the nasty business of decomposition and leaching would occur within the 30-year period, and at that point the risk of landfills would be minimized.
More than two decades ago that sounded pretty reasonable. But today, two-thirds of a way through that initial 30 years for many landfills, we now know that the risk of those closed landfills is a bit more long lasting than we had initially anticipated.
The talk now is more along the lines of perpetual care rather than 30 years of post-closure maintenance.
Let’s not mince words here. We are talking perpetual, lifetime, perpetuity. The landfill and all of its associated risks are yours, forever. Period.
When you are gone, the responsibility gets passed on to the next person in line. It’s sort of like an inheritance.
And like the red hair or big ears that you inherited from mom and dad, the closed landfill inheritance is something you are stuck with as well.
Along that long, it’s much better to accept it and make the most of it, than try to ignore it.
So what’s the answer?
The answer is to set yourself up to succeed. Make sure that every decision about long-term post-closure care is directed toward long-term success.
Site History
Review the history of the closed landfill. I’m talking about the regulatory inspection history. Identify what problems have occurred at the site and identify whether they have been fixed or if they are recurring.
And then focus your effort on those recurring problems. Brainstorm to come up with ideas to fix the underlying problems. Then, come up with a plan—not a closure plan or a budget plan, but a combat plan. It’s a plan that helps you identify the ongoing problems that are taking your resources and money.
Sit down with you regulator or inspector, and brainstorm about your goals for making the site better and eliminating ongoing problems.
Chances are, their goals are the same as your goals: to make sure the site is safe and secure, to protect human health and the environment.
This kind of approach will foster goodwill between you and the regulators and also between you and adjacent landowners.
Remember, your neighbors are also stuck with being next to a landfill forever. They will very likely welcome long-term solutions.
Common Violations at Closed Landfills
By and large, the same issues persist at most closed landfills. These include drainage problems, erosion problems, illegal dumping, settlement related problems, poorly maintained site security, and overall vegetation control/fire prevention.
Fire Prevention
It’s a funny thing. When we site new landfills, we place them in remote areas, where the topography can be steep and inaccessible. Then we strive to encourage vegetation growth around the perimeter of the landfill to act as a visual or environmental buffer for the facility. During the operating phase the risk is lower, because if a wildfire were to break out, there is a good chance that there is enough equipment onsite to deal with it.
But once the landfill is closed, it’s generally out of sight, out of mind. And while your response capabilities may be drastically diminished, the threat of a wildfire—and its potential to damage gas-monitoring systems or other structures—continues to increase.
Because of that, developing a fire prevention plan geared toward closed landfills is a good idea. Keep in mind that this is not going to be same plan that worked while the landfill was operating. The equipment and staff that you had at the active landfill won’t be what you currently have at your closed site.
Do you have a reasonable, sufficient buffer zone and fire break around the landfill? This is your first line of defense from keeping a fire that starts on the landfill from becoming a wildfire.
Removing vegetation or even controlling or even providing moderate control can be a balancing act.
In some areas, the vegetation that is increasing and creating a higher risk for wildfire can also be providing critical habitat for animals, endangered species, thus you’ll have to work out the various details with the agencies and regulations involved.
Also keep in mind that wildfire protection does not require a clear-cut mineral earth perimeter.
Often, a mosaic type fuel break around the perimeter of the landfill will work well in terms of fire protection and also provide an aesthetically pleasing and environmentally acceptable alternative.
Regardless of what type of fuel break you use, what method of site security you employ, or even how you tackle erosion issues, the key thing is to make sure your plan is geared toward long-term stabilization.
Author's Bio: Neal Bolton is a consultant specializing in landfill operations and management. |
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