[Forwarded Nov. 22, 2000 from Peter Anderson, chair of National Recycling Coalition's Policy Work Group 608-231-1100 anderson@recycleworlds.org]
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By now most of us have heard about proposed changes in landfill designs to reverse course and switch from the so-called "dry tomb" approach, which we had previously been told protects the groundwater from contamination and air from greenhouse gases, to a design that deliberately fosters early decomposition. That debate over bioreactors also holds enormous implications for recyclers that we need to understand.
To appreciate the connection, a short background is in order. Although not popularly recognized, among the experts the current so-called "entombment" regulations for landfills are now generally recognized as being a short-term fix for what is essentially a long-term problem. That is to say, all the much advertised landfill containment systems will ultimately fail, as EPA's own technical staff has repeatedly acknowledged ("even the best liner and leachate collection systems will ultimately fail due to natural deterioration, and recent improvements in MSWLF containment technologies will be delayed by many decades at some landfills"). Moreover, because of the fatally flawed entombment strategy, those systems will fail after the responsible entities have passed from the scene leaving an environmental tragedy in the making.
The source of this intractable problem that we once thought solved is the organic fraction of the waste stream. As the barriers and extraction systems degrade over time and water enters the site, the organic matter will decompose creating greenhouse and carcinogenic landfill gases and VOC laden leachate that will escape into the environment.
Bioreactors are said to be a way to address this problem by deliberately encouraging early decomposition before the landfill is sealed through recirculation of leachate. There are many confounding factors that create concerns that the cure might be worse than the disease.
It must be emphasized that there are many bioreactor proponents to whom this does not apply. But, at the same time we cannot fail to recognize that, on a political plane, the most significant part of the bioreactor's backers are those seeking specific design standards for recirculation that do not increase net costs over Subtitle D designs. Done "on the cheap," it appears that bioreactors may not be specified to, among other things:
- Preshred the bagged garbage to expose the entire organic fraction to water leaving much of the waste that is later sealed and decomposed;
- The underlying liners will not be reinforced to withstand the additional hydraulic loadings;
- The landfill sidewalls will not be reinforced to avoid landslides; and
- Very costly entirely new types of gas extraction systems will not be installed (most landfills today don't even try to collect much of the landfill gas during the first two years when bioreactors would be generating massive volumes of greenhouse gasses).
The Agency's own tests found no difference between leachate characteristics at municipal versus hazardous landfills, presumably due to the "small generator exemption" for handling toxic material. Yet, while it concluded that double composite liners were required at sites legally designated as hazardous, it did not apply the same standard at MSW facilities. Similarly, it struck the requirement to maintain postclosure care after the initial 30 year period even though its own experts repeated stated that the containment systems would fail after that time.
But, for another thing, regardless of the resolution of how one concludes the regulatory/political process will resolve the devil-in-the-details concerning bioreactors, there is a far more critical issue which the NRC has raised.
If the problem is how to deal with the organic fraction of our waste stream once it is mixed with the toxic elements in it, why mix the benign with the hazardous in the first place. Why not separately collect the decompostible fraction and compost it into a soil amendment?
This is the next frontier in recycling and the current structure of the bioreactor debate is attempting to completely ignore it. That is the reason why the NRC has asked the EPA to prepare an environmental impact statement which honestly compare this critical choice before irreversible commitments are made.
Recyclers who want to add their voice to those calling for equal consideration to composting, along with recirculation, should write to the RCRA Docket Information Center; Office of Solid Waste (5305W), U.S. Environmental Protection Agency Headquarters (EPA HQ); 1200 Pennsylvania Avenue, N.W.; Washington, DC 20460, in Docket No. F-2000-ALPA- FFFFF and state that you join in the National Recycling Coalition's request for an environmental impact statement to contain a vigorous alternatives analysis giving equal weight to composting.
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