IFETCER2019 Academic year:2022-2023

IFET COLLEGE OF ENGINEERING

(An Autonomous Institution)

DEPARTMENT OF CIVIL ENGINEERING

19UCEPE702-HAZARDOUS WASTE MANAGEMENT

Year/Sem: IV / VII Pattern Theory: 100%

UNIT III SECURE LANDFILLS

Hazardous waste landfills - Site selections - landfill design and operation - Regulatory aspects - Liner
System - Cover system - Leachate Collection and Management - Environmental Monitoring System -
Landfill Closure and post closure care. Activity: Landfills case studies*.

3.1. Hazardous waste landfills

Landfills used specifically for the disposal of hazardous waste. These landfills are not used for the disposal
of solid waste.

Summary of Federal Requirements

In terms of hazardous waste, a landfill is defined as a disposal facility or part of a facility where hazardous
waste is placed in or on land and which is not a pile, a land treatment facility, a surface impoundment, an
underground injection well, a salt dome formation, a salt bed formation, an underground mine, a cave, or a
corrective action management unit.

A hazardous waste landfill is a treatment, storage, and disposal facility (TSDF) and as such must be
appropriately permitted and the permit will specify all design and operating practices necessary to ensure
compliance.

Landfill Controls

All hazardous waste landfills are required to have a run-on control system, a runoff management system, and
control the wind dispersal of particulate matter.

The run-on control system must have the capacity to prevent flow onto the active portion of the landfill
during peak discharge of a 25-yr storm and the runoff management system must have an adequate capacity
to collect and control water from a 24-h, 25-yr storm and the contents tested to determine correct disposal
methodology.

The collection and holding tanks or basins for run-on and runoff control systems must be emptied
expeditiously after storms.

Documentation

For each hazardous waste landfill there must be a map with the exact location and dimensions, including
depth of each cell with respect to permanently surveyed benchmarks. The contents of each cell and the
approximate location of each hazardous waste type within the cell must be recorded.

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Landfill Contents

Bulk or noncontainerized liquid waste or waste containing free liquids must not be placed in the landfill. The
exemption to this rule is that containers holding free liquids may only be placed in a landfill if they meet one
of the following standards:
All free-standing liquid has been:
• Removed by decanting, or other methods
• Mixed with sorbent or solidified so that free-standing liquid is no longer observed otherwise
eliminated.
• The container is very small, such as an ampule
• The container is designed to hold free liquids for use other than storage (for example, a
battery or capacitor)
• The container is a lab pack.

In order to dispose of the sorbents used to treat free liquids in a hazardous waste landfill, the sorbent must be
nonbiodegradable.

• Inorganic minerals, other inorganic materials, and elemental carbon

• High molecular weight synthetic polymers, except for polymers derived from biological material or
polymers specifically designed to be degradable
• Mixtures of nonbiodegradable materials.)

Unless they are very small (such as ampules), containers must be at least 90 percent full and crushed,
shredded, or similarly reduced in volume to the maximum practical extent.

Closure
The final cover of a hazardous waste landfill must be designed and constructed for the long term to:

• Minimize migration of liquids through the closed landfill

• Function with minimum maintenance
• Promote drainage and minimize erosion or abrasion of the cover
• Tolerate settling and subsidence so that the cover's integrity is maintained
• Have a permeability less than or equal to the permeability of the bottom liner system or natural
subsoil present.

The following documents are required as a part of closure:

• A certification of closure sent to the Regional Administrator by registered mail within 60 days of
closure
• A survey plat submitted to the local zoning authorities (or the authority with jurisdiction over local
land use) and the Regional Administrator no later than the submission of the certification of closure.

Post closure

During post closure the integrity and effectiveness of the final cover must be maintained, including making
repairs to the cap (cover) as necessary to correct the effects of settling, subsidence, erosion, or other
disruptive events.

During post closure all leak detection systems and groundwater monitoring system are required to be
maintained.

Post closure care usually lasts 30 years after closure.

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Figure 3.1. Hazardous waste landfill

3.2. Site selections
Hazardous waste landfills should preferably be located in areas of low population density, low alternative
land use value, low ground water contamination potential and at sites having high clay content in the
subsoil.
A HW landfill will be selected following the guidelines published by MoEF The step-by-step procedure will
be as follows:
(i) Earmarking a 'search area' taking into account the location of the waste generation units and a 'search
radius' (typically 5 to 250 km). The search area will be so chosen that it minimizes the number of
HW landfills in any region or state.
(ii) Identification of a list of potential sites on the basis of
(a) availability of land
(b) collection of preliminary data
(c) restrictions listed in the locational criteria
(iii) Collection of preliminary data as follows:

(a) Topographic Maps: A topographic map will help find sites that are not on natural surface water drains or
flood plains. Topographical maps may be procured from Survey of India.

(b) Soil Maps: These maps, primarily meant for agricultural use, will show the types of soil near the surface.
They are of limited use as they do not show types of soil a few metre below the surface. They may be
procured from Indian Agricultural Research Institute

(c) Land Use Plans: These plans are useful in delineating areas with definite zoning restrictions. There may
be restrictions on the use of agricultural land or on the use of forest land for landfill purposes. Such maps are
available with the Town Planning Authority or the Municipality

(d) Transportation Maps: These maps, which indicate roads and railways and locations of airports, are used
to determine the transportation needs in developing a site.

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(e) Water Use Plans: Such maps are usually not readily available. A plan indicating the following items
should be developed private and public tube wells indicating the capacity of each well, major and minor
drinking water supply line(s), water intake wells located on surface water bodies, and open wells.

(f) Flood Plain Maps: These maps are used to delineate areas that are within a 100-year flood plain. Landfill
siting must be avoided within the flood plains of major rivers.

(g) Geologic Maps: These maps will indicate geologic features and bedrock levels. A general idea about soil
type can be developed from a geological map. Such maps can be procured from Geological Survey of India.

(h) Aerial Photographs / Satellite Imagery Aerial photographs or satellite imageries may not exist for the
entire search area. However, such information may prove to be extremely helpful. Surface features such as
small lakes. intermittent stream beds and current land use, which may not have been identified in earlier map
searches, can be easily identified using aerial photographs.

(i) Ground Water Maps Ground water contour maps are available in various regions which indicate the
depth to ground water below the land surface as well as regional ground water flow patterns. Such maps
should be collected from Ground water Boards or Minor Irrigation Tube well Corporations.

(j) Rainfall Data: The monthly rainfall data for the region should be collected from the Indian
Meteorological Department.

(k) Wind Map: The predominant wind direction and velocities should be collected from the Indian
Meteorological Department.

(l) Seismic Data: The seismic activity of a region is an important input in the design of landfills. Seismic
coefficients are earmarked for various seismic zones and these can be obtained from the relevant BIS code
or from the Indian Meteorological Department.

(m) Site Walk Over and Establishment of Ground Truths A site reconnaissance will be conducted by a site
walk-over as a part of the preliminary data collection. All features observed in various maps will be
confirmed. Additional information pertaining to the following will be ascertained from nearby inhabitants:
(a) flooding during monsoons; (b) soil type; (c) depth to G.W. table (as observed open wells or tube wells);
(d) quality of groundwater and (e) depth to bedrock.

(n) Preliminary Boreholes and Geophysical Investigation: At each site, as a part of preliminary data
collection, one to two boreholes will be drilled and samples collected at every 1.5m interval to a depth of
20m below the ground surface. The following information will be obtained: (i) soil type and stratification;
(ii) permeability of each strata; (iii) strength and compressibility parameters (optional); (iv) ground water
level and quality and (v) depth to bedrock. In addition to preliminary boreholes, geophysical investigations
(electrical resistivity/seismic refraction/others) may be undertaken to assess the quality of bedrock at
different sites.
(iv) Selection of two best ranked sites from amongst the list of potential sites on the basis of the ranking
system stipulated by MoEF (1991).
Environmental Impact Assessment for the two sites for the following parameters:
(a)ground water quality: (b) surface water quality. (c) air quality - gases, dust, litter, odour; (d) land use
alteration; drainage alteration; (f) soil erosion; (g) ecological impacts (h) noise; (i) aesthetics - visual,
vermin, flies; (j) traffic alteration; and (k) others.
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(vi) Assessment of public perception for the two sites.

(vii) Selection of final site.
(viii)The above site selection procedure shall not be applicable for location of facility within industrial areas
of State Industrial Development Agencies. However, EIA requirement will apply.

3.3. landfill design and operation

Planning and design criteria
3.3.1 Essential Components:
A HW landfill shall have the following seven essential components:
(a) A liner system at the base and sides of the landfill which prevents migration of leachate or gas to the
surrounding soil.
(b) A leachate collection and treatment facility, which collects and extracts leachate from within and from
the base of the landfill and then treats the leachate to meet standards, notified under E(P)Act 1986.
(c) A gas collection and treatment facility (optional) which collects and extracts gas from within and from
the top of the landfill and then treats it or uses it for energy recovery.
(d) A final cover system at the top of the landfill, which enhances surface drainage, prevents infiltration of
water and supports surface vegetation.
(e) A surface water drainage system, which collects and removes all surface runoff from the landfill site.
(f) An environmental monitoring system which periodically collects and analyses air, surface water, soil-gas
(optional) and ground water samples around the landfill site.
(g) A closure and post-closure plan which lists the steps that must be taken to close and secure a landfill site
once the filling operation has been completed and the activities for long-term monitoring operation and
maintenance of the completed landfill.

3.3.2. Design life

A landfill design life will comprise of an 'active' period and a 'closure and post-closure' period. The 'active'
period shall comprise of the period for which waste filing is in progress at the landfill and typically range
from 10 to 25 years depending on the availability of land area. The 'closure and post-closure period for
which a landfill will be monitored and maintained shall be 30 years after the 'active period' is completed.

3.3.3. Waste Volume, Waste Compatibility and Landfill Capacity

The volume of waste to be placed in a landfill will be computed for the active' period of the landfill taking
into account (a) the current generation of waste per annum and (b) the anticipated increase in rate of waste
generation on the basis of past records.
A landfill will comprise of separate units. In each unit. only compatible wastes will be disposed. The actual
capacity of each landfill unit will be computed taking into account the volume occupied by the liner system
and the cover material [daily/weekly (optional) intermediate and final cover] as well as the compacted
density of the waste. In addition, the amount of settlement a waste will undergo due to overburden stress and
due to bio-degradation (if any) shall also be taken into account.
The total landfill area should be computed on the basis of the designed height of the landfill (usually
between 5 to 20m). Approximately 15 to 20% area more than the area required for landfilling should be
adopted to accommodate all infrastructure and support facilities as well as to allow the formation of a green
belt around the landfill. This additional area shall be computed separately and may be as high as 30% of the
total area in case of small to medium landfills. The total landfill area is computed on trial-and-error basis.
There is no standard method for classifying landfills by their capacity. However, the following nomenclature
is often observed in literature:
Small size landfill: less than 5-hectare area
Medium size landfill: 5 to 20 hectare areas

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Large size landfill :greater than 20 hectare area.

3.3.4. Landfill Layout

A landfill site will comprise of the area in which the waste will be filled as well as additional area for
support facilities. The area in which waste is to be filled may comprise of separate landfill units with each
unit, accommodating a group of compatible wastes. Within each unit work may proceed in phases with only
a part of the area under active operation. Such a layout must be prepared for all landfills. The following
facilities must be located in the layout: (a) access roads; (b) equipment shelters, (c) weighing scales; (d)
office space; (e) location of waste inspection facility (if used); (f) temporary waste storage and/or disposal
sites for special wastes; (g) demarcation of the landfill areas and areas for stockpiling cover material and
liner material; (h) location of surface water drainage facilities; (i) location of landfill leachate management
facilities; (j) location of gas management facilities (optional): (k) location of monitoring
wells/environmental monitoring facilities, (1) fencing and green belt along the peripheral boundary and (m)
emergency exit. It is essential that for each landfill site, a layout be designed incorporating the above-
mentioned facilities.

3.3.5. Landfill Section

Landfills may have different types of sections depending on the topography of the area. The landfills may
take the following forms (a) above ground landfills; (b) below ground landfill; (c) slope landfills, (d) valley
landfills (canyon landfills); and (e) A combination of the typical landfill sections. It is recommended that the
landfill section be arrived at keeping in view the topography, depth to water table and availability of liner
and cover material Above ground landfills shall be preferred to below ground landfills, as leachate collection
in the former is by gravity flow and does not require the use of pumps. Slope landfills and valley landfills
are normally adopted in hilly areas, above-ground landfills in flat undulating ground and below-ground
landfills in low-lying areas, depressions or pits.

3.3.6. Phased Operation

Before the main design of a landfill can be undertaken it is important to develop the operating methodology.
A landfill is operated in phases because it allows the progressive use of the landfill area, such that at any
given time a part of the site may have a final cover, a part being actively filled, a part being prepared to
receive waste, and a part undisturbed.
For each landfill unit, a phased operation plan will be drawn up.
The term 'phase' describes a sub-area of the landfill. A phase' consists of cells, lifts, daily/weekly (optional)
or intermediate cover, liner and leachate collection facility, gas control facility (optional) and final cover
over the sub-area.
Each phase is typically designed for a period of 12 months. Phases are generally filled from the base to the
final/intermediate cover and capped within this period leaving a temporary unrestored sloping face.
A 'phase plan' shall be drawn up for the active life of the landfill as soon as the landfill layout and section
are finalized. It must be ensured that each phase reaches the final cover/intermediate cover level at the end
of its construction period and that it is capped before the onset of monsoons.
During the monsoon months the waste may stockpiled in a temporary holding area (covered with roof).
During this period and the landfill may be kept capped with the final cover/intermediate cover and
landfilling operations suspended to reduce infiltration of rain water into the landfill. However, if the
incoming waste quantity is too large for temporary stockpiling or the monsoon period lasts for a long period,
special phases may have to be designed with high leachate handling capacity and special operating
procedures adopted.

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Figure 3.2. Landfill design

3.3.7. Estimation of Leachate Quantity
Leachate is generated on account of the infiltration of water into landfills and its percolation through waste
as well as by the squeezing of the waste due to self-weight. The quantity of leachate generated in a landfill is
strongly dependent on the quantity of infiltrating water. This, in turn, is dependent on weather and
operational practices. The amount of rain falling on a landfill, to a large extent controls the leachate quantity
generated. Precipitation depends on geographical location.
Significant quantity of leachate is produced from the 'active' phases of a landfill under operation. The
leachate quantity from those portions of a landfill which have received a final cover is minimal.
For design, computer simulated models (e.g. HELP) have to be used for estimation of leachate quantity
generation. It is recommended that such studies be conducted to estimate the quantity of leachate and design
the leachate drainage, collection and removal facility.

3.4. Liner System

Leachate control within a landfill involves the following steps: (a) prevention of migration of leachate from
landfill sides and landfill base to the subsoil by a suitable liner system; and (b) drainage of leachate collected
at the base of a landfill to the side of the landfill and removal of the leachate from within the landfill.
On a basis of review of liner systems adopted in different countries and in consideration with Indian
conditions, it is recommended that for all HW landfills the liner system criteria adopted in consultation with
SPCB/PCC and commensurate with local area specified needs.

Introduction
Modern landfills are highly engineered containment systems, designed to minimize the impact of solid
waste (refuse, trash, and garbage) on the environment and hu- man health. In modern landfills, the waste is
contained by a liner system. The primary purpose of the liner system is to isolate the landfill contents from
the environment and, therefore, to protect the soil and ground water from pollution originating in the
landfill. The greatest threat to ground water posed by modern landfills is leachate. Leachate consists of
water and water- soluble compounds in the refuse that accumulate as water moves through the landfill. This
water may be from rainfall or from the waste itself. Leachate may migrate from the landfill and contaminate
soil and ground water, thus presenting a risk to human and environmental health. Landfill liners are
designed and constructed to create a barrier between the waste and the environment and to drain the leachate
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to collection and treatment facilities. This is done to prevent the uncontrolled release of leachate into the
environment.
Society produces many different solid wastes that pose different threats to the environment and to
community health. Different disposal sites are available for these different types of waste. The potential
threat posed by the waste determines the type of liner system required for each type of landfill. Liners may
be described as single (also referred to as simple), composite, or double liners.

Single-Liner Systems
Single liners consistofa clay liner, a geosynthetic clay liner, or a geomembrane (specialized plastic sheeting). Single
liners are sometimes used in landfills designed to hold construction and demolition debris (C&DD).
Construction and demolition debris results from build- ing and demolition activities and includes concrete,
asphalt, shingles, wood, bricks, and glass. The design and operation of C&DD landfills are regulated under
the Ohio Administrative Code (OAC). Licensing requirements are addressed under OAC. These landfills are
not constructed to contain paint, liquid tar, municipal garbage, or treated lumber; consequently, single-liner
systems are usually adequate to protect the environment. It is cheaper to dispose of construction materials in
a C&DD landfill than in a municipal solid waste landfill because C&DD landfills use only a single liner and
are therefore cheaper to build and maintain thanother landfills.

Figure 3.3. Single liner system

Composite-Liner Systems
A composite liner consists of a geomembrane in combi- nation with a clay liner. Composite-liner systems are
more effective at limiting leachate migration into the subsoil than either a clay liner or a single
geomembrane layer. Composite liners are required in waste landfills.
Municipal solid waste landfills contain waste collected from residential, commercial, and industrial sources.
These landfills may also accept C&DD debris, but not hazardous waste. Municipal solid waste landfill design,
construction, and operation are regulated by Subtitle D of the federal Resource Conservation and Recovery
Act (1976). The minimum requirement for MSW landfills is a composite liner. Frequently, landfill designers
and operators will install a double liner system in MSW landfills to provide additional monitoring capabilities
for the environment and the community.
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Figure 3.4. Composite liner

Double-Liner Systems
A double liner consists of either two single liners, two composite liners, or a single and a composite liner.
The upper (primary) liner usually functions to collect the leachate, while the lower (secondary) liner acts
as a leak-detection system and backup to the primary liner. Double-liner systems are used in some
municipal solid waste landfills and in all hazardous waste landfills.
Hazardous waste landfills (also referred to as secure landfills) are constructed for the disposal of wastes that
once were ignitable, corrosive, reactive, toxic, or are designated as hazardous by the U.S. Environmental
Protection Agency (U.S. EPA). These wastes can have an adverse effect on human health and the
environment, if improperly managed. Hazardous wastes are produced by industrial, commercial, and
agricultural activities. Subtitle C of the federal Resource Conservation and Recovery Act, 1976, under Title
40 of the Code of Federal Regulations, provides minimum standards for the disposal and management of
hazardous waste. Hazardous wastes must be disposed of in hazardous waste landfills. Hazardous waste
landfills must have a double liner system with a leachate collection system above the primary composite
liner and a leak detection system abovethe secondary composite liner.

Figure 3.5. Double liner system

Leachate Collection Systems

Integrated into all liner systems is a leachate collection system. This collection system is composed of sand
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and gravel or a geonet. A geonet is a plastic net-like drainage blanket. In this layer is a series of leachate
collection pipes to drain the leachate from the landfill to holding tanks for storage and eventual treatment. In
double-liner systems, the upper drainage layer is the leachate collection system, and the lower drainage
layer is the leak detection system. The leak detection layer contains a second set of drainage pipes. The
presence of leachate in these pipes serves to alert landfill management if the primary liner has a leak.
Components of the liner system are protected by a layer that minimizes the potential for materials in the
landfill to puncture the liner. This protective layer was traditionally composed of soil, sand, and gravel,
but many landfills now use a layer of soft refuse instead of soil. Soft refuse consists of paper, organic refuse,
shredded tires, and rubber.

Liner Components
Clay: To protect the ground water from landfill contaminants, clay liners are constructed as a simple liner
that is two- to five-feet thick. In composite and double liners, the compacted clay layers are usually
between two- and five-feet thick, depending on the characteristics of the underlying geology and the type
of liner to be installed. Regulations specify that the clay used can only allow water to penetrate at a rate of
less than 1.2 inches per year. The effectiveness of clay liners can be reduced by fractures induced by
freeze-thaw cycles, drying out, and the presence of some chemicals.
In theory, one foot of clay is enough to contain the leachate. The reason for the additional clay is to safeguard
the environment in the event of some loss of effectiveness in part of the clay layer. The efficiency of clay
liners can be maximized by laying the clay down in four- to six-inch layers and then compacting each layer
with a heavy roller.
The efficiency of clay liners is impaired if they are allowed to dry out during placement. Desiccation of the
clay during construction results in cracks that reduce the liner efficiency. In addition, clays compacted at
low moisture contents are less effective barriers to contaminants than clays compacted at higher moisture
contents. Liners that are made of a single type of clay perform better than liners constructed using several
different types.
Geomembranes: Geomembranes are also called flexible membrane liners (FML). These liners are
constructed from various plastic materials, including polyvinyl chloride (PVC) and high-density
polyethylene (HDPE). The preferred material for use in MSW and secure landfills is HDPE. This material is
strong, resistant to most chemicals, and is considered to be impermeable to water. Therefore, HDPE
minimizes the transfer of leachate from the landfill to the environment. The thickness of geomembranes used
in landfill liner construction is regulated by federal and state laws. In Ohio, HDPE geomembranes must have a
minimum thickness of 0.060 inches for use in MSW landfills.
Geotextiles: In landfill liners, geotextiles are used to prevent the movement of small soil and refuse particles
into the leachate collection layers and to protect geomembranes from punctures. These materials allow the
movement of water but trap particles to reduce clogging in the leachate collection system.
Geosynthetic Clay Liner (GCL): Geosynthetic clay liners are becoming more common in landfill liner
designs. These liners consist of a thin clay layer (four to six millimeters) between two layers of a geotextile.
These liners can be installed more quickly than traditional compacted clay liners, and the efficiency of these
liners is impacted less by freeze-thaw cycles.
Geonet: A geonet is a plastic net-like drainage blanket which may be used in landfill liners in place of sand
or gravel for the leachate collection layer. Sand and gravel are usually used due to cost considerations, and
because geonets are more susceptible to clogging by small particles. This clogging would impair the
performance of the leach- ate collection system. Geonets do, however, convey liquid more rapidly than sand
and gravel.

Detection of the Leakage of Landfill Liner Systems

The basic reasoning (no pollution of groundwaters by landfill leachate has been detected) that isbeing used
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in support of continued development of Subtitle D minimum single composite-lined landfills and Subtitle
C double composite-lined landfills is fundamentally flawed for a variety of reasons. These issues are
discussed below.

Travel Time of Leachate. The way that leakage through a Subtitle D single composite liner is detected is by
pollution of the groundwaters at the point of compliance for monitoring the presence of leachate. The point
of compliance can, in a properly developed landfill that complies with minimum Subtitle D requirements,
be no more than 150 meters from the down groundwater gradient edge of the waste management units. This
means that any leakage from a Subtitle D landfill liner system must travel through the liner and unsaturated
geological strata below the liner to the groundwaters and then horizontally to the point of compliance.
Since Subtitle D landfill liner systems have only been required by the US EPA for less than three years, it
is entirely possible that at many landfill sites the leakage through the liner that is likely occurring has not
yet reached the point of compliance.

Unreliable Groundwater Monitoring. One of the primary reasons why Subtitle D and, for that matter,
Subtitle C landfills have not been found to be polluting groundwaters is that the method of detection of
groundwater pollution involves vertical monitoring wells spaced hundreds to a thousand or more feet
apart at the point of compliance for monitoring. These monitoring wells have zones of capture into the
aquifer of about one foot based on a three-borehole volume purgeof the well before sampling. This means
that unless there is widespread general leakage throughout the whole bottom of the landfill liner system,
the plumes that are generated from initial leakage would not likely be detected by the groundwater
monitoring wells. The approach that should be used to develop reliable groundwater monitoring systems
for lined landfills. Basically, the zone of capture of the monitoring wells at the point of compliance for
groundwater monitoring must be of such dimensions (lateral extent) to intersect the leachate plumes that
arise from leaks through the liner system.
This creates a situation in which the groundwater monitoring systems used have a low probability of
detecting groundwater pollution before widespread pollution occurs beyond the point of compliance for
groundwater monitoring. In most plastic sheeting-lined landfills there will be several long, finger-like
plumes of leachate extending well beyond the point of compliance before the failure of the liner system
to prevent groundwater pollution is detected. This is one of the primary reasons why it is fundamentally
flawed reasoning to assert that because the groundwater monitoring systems at Subtitle C and D landfills
have not yet detectedgroundwater pollution that these types of landfills will be protective of groundwater
resources for as long as the wastes in the landfill will be a threat.

Leakage Through Double-Lined Landfills. One of the best ways to judge whether leakage will occur
through a single composite liner is to examine the results obtained for leaks into the leak detection
system for landfills lined with double composite liners that have a leak detection system between the two
composite liners. Examining this issue is the best indicator available at this time on what can be expected
in the way of leaks through both the double composite liner and a single composite liner landfill system.

One of the issues that is of considerable concern with respect to leakage through composite liners in a
double composite-lined system is the approach that is used to establish excessive leakage rates through the
upper composite liner. Several years ago the US EPA attempted to establish a Liner Action Leakage Rate
of a few gallons per acre per day as the rate at which a single composite liner in a double composite-lined
system would be allowed to leak before remediation efforts would have to be undertaken. As it turned out,
based on the review by Bonaparte and Gross, allowing only a few gallons per acre per day of leakage
through the upper composite liner would mean that essentially all of the upper composite liners of double
composite-lined systems would be found to have failed. This caused the US EPA and the states to take a
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different approach where the Liner Actual Leakage Rate is based on what can be achieved with current
liner technology, rather than what is necessary to protect groundwater from pollution by landfill leachate.

The appropriate approach to take in establishing the Liner Action Leakage Rate is not what can be
achieved with these types of liner materials, but what is necessary to protect the groundwaters from
pollution by landfill leachate. This is the purpose of the liners. The approach that should be used is to
determine, on a site-specific basis, the rate of leakage through the upper composite liner that can be
allowed and not result in groundwater pollution if the lower composite liner were not present. For most
situations, this will be on the order of a few gallons per acre per day.

Development of Liner Leak Detection Systems. While landfill applicants and their consultants often claim
that a single and/or double composite liner system will not leak, it is obvious from the literature,
principles of chemical thermodynamics and common sense that such claims have no technical validity.
The facts are that composite-lined systems often can leak at the time of construction due to imperfections
in the construction. It is for this reason that I-Corp International of Daytona Beach, Florida; Gundle - GSE
of Houston, Texas; and Robertson Barrier System Corp. of Vancouver, British Columbia have developed
leak detection systems for liners. Such leak detection systems are needed to detect leaks that are occurring
at the time of construction of the liner system that are not detected by conventional QA/QC approaches.

Landfill Operations Caused Leaks. Another important source of leaks for new landfills is the inadequate
protection of the liner system from the initial placement of the wastes in the landfill. Often inadequate
attention is given to developing a protective layer between the liner system and the lowermost layer of
wastes to prevent punctures from occurring in the liner system associated with the initial placement of the
wastes. An example of this type of problem occurred with Chemical Waste Management of Indiana's
hazardous waste landfill unit located near New Haven, Indiana where as part of placing the first layer of
wastes in that landfill, the landfill operator punched 83 holes in the liner. The leakage through these holes
was of sufficient magnitude so that the state of Indiana required that the wastes that had been placed in
the landfillbe removed and the liners repaired.

Solvent Permeation. There is a special type of leakage of landfill liners that, thus far, is largely being
ignored by the regulatory agencies, even though it is well-documented in the literature.
This is the problem associated with permeation of the liner by various types of organic solvents. Common
organic solvents that are present in municipal solid wastes and in treated hazardous waste residues such as
the chlorinated solvents, benzene, TCE and its degradation products such as vinyl chloride, etc., can pass
through an intact, with no holes, flexible membrane liner in a short period of time. This is a chemical
process that does not cause the liner to deteriorate, but involves the diffusion of the organics into the
plastic sheeting and then through the plastic sheeting into the media on the other side of the plastic
sheeting which typically is the compacted clay layer.
It is important to note that this mechanism of leakage is particularly significant since it results in the
transport of highly hazardous persistent mobile constituents through the liner system under conditions
where the liner is perfectly formed and intact. It occurs not only from concentrated solvent solutions, but
also occurs with dilute aqueous solutions of the solvents. The various solvents that are of concern can be
purchased by the public at the local hardware store and therefore are not exotic chemicals that would not
be expected at a landfill, but are common chemicals that are expected in today's municipal landfills.
Many of these solvents are known or expected carcinogens. The US EPA, as part of promulgating
Subtitle D regulations, noted that one of the best ways to detect liner leakage of leachate is through
measurement of organic solvents.

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Long-Term Plastic Sheeting Liner Deterioration. Even if the liner is perfectly formed and no holes are
punched in the liner at the time of waste deposition and if no organic solvents are present in the landfill,
it is still only a matter of time until the liner system fails to prevent leachate from passing through it. The
US EPA, as part of promulgating Subtitle D regulations governing municipal landfills, stated, First, even
the best liner and leachate collection system will ultimately fail due to natural deterioration, and recent
improvements in MSWLF (municipal solid waste landfill) containment technologies suggest that releases
may be delayed by many decades at some landfills."

Since the US EPA developed that position on the ultimate deterioration of flexible membrane liners,
considerable additional work has been done which now further strongly supports this position. The focus
of the Hsuan and Koerner's work is on the breakdown of the polymers in the plastic sheeting liners. They
predict that this breakdown will occur due to free radical polymer chain scissions in 40 to 120 years.
These estimates are indicated by Koerner to consider only some of the key issues that could cause
breakdown. It is possible that breakdown could begin much earlier. Even if the breakdown of the plastic
sheeting polymers took 100 years or so, there is still no question that ultimately the plastic sheeting in the
flexible membrane liners will break down leading to an inability to prevent leachate from passing through
it leading to groundwater pollution in the area.

It is important to put the ultimate breakdown of the flexible membrane liner in the perspective of the time
at which the treated waste residues in a hazardous waste landfill and in a municipal solid waste landfill
represent a threat. Both types of landfills contain waste components that will be a threat, effectively
forever. Therefore, since it is only a matter of time until disintegration of the flexible membrane liner
occurs, it is only a matter of time until groundwater pollution occurs at landfills lined with HDPE plastic
sheeting.

Compacted Clay Liners. Today’s Subtitle C and D landfills require that the plastic sheeting layer(s) be
backed by compacted clay. The minimum design requirements for the clay layer are two feet of clay that
has a permeability, at the time of construction, of no greater than 10-7 cm/sec. There are a variety of
well-known mechanisms that cause the compacted clay layers to increase their permeability over time.
Factors such as desiccation cracking are important causes of increased permeability for clay liners.

There is an increasing tendency to substitute thin bentonite mats of clay for the two feet of compacted
clay. These bentonite mats have advective permeabilities of about 10-9 cm/sec. However, the diffusional
transport through such layers is much higher than this amount. Gray (1988) has found that diffusion is a
much more important process for determining the transport through bentonite mats than the advective
permeability. bentonite clays are subject to significant shrink/swell properties where, for certain types of
wastes that have excess calcium and magnesium over sodium, the sodium bentonite clay present in these
mats would undergo ion exchange with calcium and magnesium, leading to a shrinkage of the clay and
increased permeability. There are significant questions about the advisability of relying on bentonite mats
as a reliable barrier for the transport of landfill leachatethrough them.
Overall, compacted clay layers will not prevent leachate transport through them. They have finite
permeabilities which will ultimately allow, under design specifications, the transport of leachate through
the layer. Further, there are a variety of mechanisms which can result in an increased permeability from
that prescribed in the design and achieved at the time of construction.

Developing Protective Landfills

One of the issues that needs to be considered is whether Subtitle C and D landfills could be developed
using the "dry tomb" landfilling approach that would be protective of groundwater resources for as long
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as the wastes in the landfill represent a threat. Basically, it involves the constructionof all hazardous waste
landfills and so-called non-hazardous waste landfills using double composite-lined systems with a reliable
leak detection system between the two composite liners. This is the approach that is used in Michigan's
Rule 641 for municipal solid waste landfills. Such landfills consist of a double composite lined system
where the lower composite liner is part of a leak detection system for the upper composite liner. It is also
the approach that is used by the US EPA in Subtitle C landfills except that the US EPA has failed to
develop adequate Liner Action Leakage Rates which will be protective of the groundwaters in the vicinity
of the landfill when the lower composite liner is no longer an effective barrier and leachate passes through
it.

The approach that should be followed is that whenever the leachate leakage through the upper composite
liner is sufficiently great so that the groundwaters under the landfill could be polluted,
i.e. impaired use for domestic or other purposes, by the leakage through the liner, then the landfill
owner/operator must stop the leakage through the upper composite liner or exhume the waste.

Since this liner cannot be inspected and repaired without removal of the wastes, stopping the leakage
through it will require that an impermeable cover be installed on the landfill which has a primary
component a leak detection system that is operated and maintained in perpetuity, i.e. as long as the wastes
in the landfill represent a threat. The Robertson system, the Gundle -GSE leak detection system, the I-
Corp leak detection system as well as others that are being developed can all potentially be used for this
purpose. While these systems cannot function effectively in the landfill liner system, they can be made to
work in the landfill cover, which is accessible for repair.

Today’s RCRA Subtitle C and D landfill covers involve the use of the equivalent of a composite liner in
which thin plastic sheeting and a compacted clay layer is constructed on top of the waste layer. This low
permeability layer is designed to minimize but not prevent moisture from entering the landfill and
generating leachate. The variety of factors that influence the stability of a landfill cover such as the
differential settling of the waste which can be highly disruptive of the cover integrity. Typically landfill
owners/operators will assert at a landfill permitting hearing that if any problems develop in the integrity
of the landfill cover, that these will be repaired. However, the low permeability layer of the landfill cover
(the plastic sheeting and compacted clay) are buried below several feet of top soil and a drainage layer.
Cracks can develop in the low permeability layer which cannot be perceived upon visual inspection of the
landfill cover.

If the landfill owner/operator cannot or will not stop the leakage of leachate through the upper composite
liner, then the owner/operator must remove (exhume) the wastes in the landfill, properly treat them, and
manage the residues from such treatment in such as way as to not lead to further groundwater pollution.
Failure to adopt this approach will mean that the waste in a landfill will pollute the groundwaters of the
area. such an approach requires that a dedicated trust fund be developed from disposal fees during the
landfill's active life. This trust fund should be of sufficient magnitude to ensure that sufficient funds are
present to operate and maintain the leak detectable cover, leachate collection system and the leak
detection system between the two composite liners. While other financial instruments are currently
allowed in RCRA post-closure funding, such financial instruments are likely to be unreliable. The
importance of using a dedicated trust as a reliable financial instrument to address long-term contingencies
associated with "dry tomb" type landfills.

The typical 30-year post-closure fund associated with both hazardous and non-hazardous waste landfills is
grossly deficient compared to the funds that will likely be required during the 30-year period, much less
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the infinite period of time that funds will be needed to address contingencies that will ultimately have to
be addressed at the landfill. An important aspect of this situation is whether private landfilling companies
will, in fact, be economically viable in the future when the funds will be needed-20, 50, 100 or so years
from now. Private landfilling companies are accruing massive liabilities that ultimately will cause these
firms stockholders to sell their stock from the firms, making the firms financially unstable, ultimately
leading to their bankruptcy. This past year, at the annual meeting of the Waste Management of North
America Stockholders, the WMX CEO, D. Buntrock, noted that WMX was losing money on its
hazardous waste management business. D. Buntrock is quoted in the Chicago Tribune as stating at this
meeting, "Most of us in the company wish today we never heard of the business." Situations such as this
give little confidence that landfill companies will, in fact, meet their long-term obligations associated with
post-closure care of landfills.

The US Congress General Accounting Office (GAO 1990) informed Congress in a report entitled,
"Hazardous Waste Funding of Post closure Liabilities Remains Uncertain," that the current regulatory
approaches do not necessarily provide the funding that will be needed to address contingencies during
their post-closure period, i.e., while the wastes remain a threat. Further, the GAO (1995) has reviewed the
potential for funding the monitoring and maintenance of hazardous waste landfills and concluded that, at
this time, there are high degrees of uncertainty about whether federal and state funds will, in fact, be
available to provide for monitoring and maintenance and periodic (five-year review) of hazardous waste
landfills in accord with current regulatory requirements. Some states, such as South Carolina, are
beginning to address this issue by requiring that waste management companies post cash bonds to address
long-term landfill contingencies.

While generally today, regulatory agencies are not adequately addressing the long-term issues associated
with municipal and hazardous waste landfills ultimately failing to protect public health, groundwater
resources and the environment from waste derived constituents, there is growing recognition of the
deficiencies of current regulatory approaches where the minimum landfill design for Subtitle C and D
landfills is recognized as being badly out of date and not protective of public health and the environment
for as long as the wastes in the landfill will be a threat. An encouraging situation recently developed in
the state of Indiana where the Hazardous Waste Facility Siting Authority reviewed a Chemical Waste
Management of Indiana proposal to expand a hazardous waste landfill where it became clear, that
ultimately, that landfill would pollute groundwaters of interest to the city of New Haven which is located
immediately adjacent to this landfill. The Siting Authority concluding in an eight to one vote that the
landfill should not be expanded because of its potential to ultimately pollute groundwaters of interest to
New Haven, Indiana.
With respect to Subtitle D landfills, a number of states, such as New York, New Jersey, Michigan,
Pennsylvania, Kentucky, Oregon and Arizona, have adopted double composite-lined landfills as the
minimum landfill liner design for situations where there are groundwaters underlying the landfill that
could be polluted by landfill leachate at any time in the future.
California has had regulations since the mid-1980s that require that hazardous waste landfills not leak
leachate through the liner system for as long as the wastes in the landfill represent a threat, and municipal
solid waste landfills not allow sufficient leachate to pass through the liner system to potentially impair the
uses of the groundwaters based on the concentrations of constituents in the unsaturated zone underlying
the landfill for as long as the wastes represent a threat. Instead, the regional boards have been allowing
landfill applications to construct landfills that, obviously, will not protect groundwaters from pollution by
landfill leachate for as long as the wastes in the landfill will be a threat.

The justification for this approach is based on that mention is made in the regulations of minimum landfill
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liner cover - containment system design requirements. Even though the regulations explicitly state that the
minimum requirements are not necessarily protective at all sites and that the liner cover - containment
system must protect groundwaters from impaired use for as long as the wastes in the landfill represent a
threat. The inappropriate interpretation of the regulations that is routinely occurring today in California by
regional boards where the minimum design is determined to be equivalent to the groundwater quality
protection performance standards set forth in the regulations is extremely short-sighted and contrary to
public health, groundwater resources and the protection of the environment. This approach has allowed
the construction of municipal solid waste landfills that will obviously not conform to the basic regulatory
requirements of protecting groundwaters from impaired use from waste associated constituents for as long
as the waste represent a threat.

3.5. Leachate Drainage, Collection and Removal

A leachate collection system shall be designed at the base of all landfills. It shall comprise of a drainage
layer, a perforated pipe collection system. sump collection area, and a removal system.
The leachate collection layer (drainage layer) will usually be a 30 cm thick sand-gravel layer with a slope of
2% or higher and a permeability of greater than 102 cm/sec (10 m/sec). A system of perforated pipes and
sumps is provided within the drainage layer. The pipe spacing will be governed by the requirement that the
leachate head shall not be greater than the drainage layer thickness.
Leachate will be removed from the landfill (a) pumping in vertical wells or chimneys (b) pumping in side
slope risers. (c) by gravity drains through the base of a landfill in above-ground and sloped landfills. Side
slope risers may be preferred to vertical wells to avoid any down drag problems. Submersible pumps have
been used for pumping for several years, educator pumps are also being increasingly used. The leachate may
be stored in a holding tank (for a few days) before being sent for treatment.

The design of following components should be undertaken:

(a) leachate pipe and leachate trench network
(b) leachate sumps and pumps
(c) leachate wells/side slope riser
(d) leachate holding tank
(e) backwashing/backflushing arrangement to prevent clogging/choking/head loss.
The material used for pipes etc., should be such that it is not affected by the leachate quality.

Figure 3.6. Leachate collection

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3.5.1. Leachate Management

The following alternatives shall be considered for leachate management:
(a) Offsite treatment of leachate: This involves storage, pretreatment and transportation of leachate to off-
site facilities not associated with the landfill e.g. industrial effluent treatment facility etc. This will be
feasible where offsite facilities are available at a reasonable distance and where pretreatment requirements
for the leachate (such as adjustment of pH, reduction in concentration etc.) are not very stringent
Transportation of leachate to offsite facility will be undertaken through a manifest system in accordance
with HWM rules of MoEF.
(b) Onsite treatment of leachate: This involves complete treatment of the leachate at the landfill site to meet
discharge standards for lined drains. Treatment processes may be biological, chemical or physical processes.
Processes, which have been judged as having been "demonstrated", should be adopted.
(c) Recirculation: One of the methods for treatment of leachate is to recirculate it through the landfill. This
has two beneficial effects: (i) the process of landfill stabilization is accelerated and (ii) the constituents of
the leachate are attenuated by the biological. chemical and physical changes occurring with the landfill
Recirculation of a leachate requires the design of a distribution system to ensure that the leachate passes
uniformly throughout the entire waste. Leachate recirculation has been used in some municipal waste
landfills. Information on its efficacy in HW landfills is scanty.

3.5.2. Gaseous Emissions Management

Landfill gas is generated as a product of waste biodegrading or on account of presence of VOCs in the
waste. Gas generation can be reduced or eliminated by avoiding disposal of biodegradable/organic wastes.
For HW landfills where gaseous emissions are anticipated (as in the case of mixed waste having
biodegradable components), the gas management strategy shall be (a) controlled passive venting or (b)
controlled collection and treatment/reuse.

Figure 3.7. Leachate management

3.6. Final Cover System

A final landfill cover, comprising of several layers, each with a specific function shall be installed after each
landfill phase reaches the full height. The final cover system shall enhance surface drainage, minimize
infiltration, support vegetation to prevent erosion and control the release of landfill gases. On the basis of a
review of HW landfill covers adopted in different countries and in consideration with Indian Conditions the
cover system adopted in consultation with SPCB/PCC and commensurate with local area specified needs.
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Figure 3.8. components of final cover system

3.7. Environmental Monitoring System

Definition:
Monitoring is the collection and analysis of data (chemical, physical, and/or biological) over a sufficient
period of time and frequency to determine the status and/or trend in one or more environmental parameters
or characteristics. Monitoring should not produce a “snapshot in time” measurement, but rather should
involve repeated sampling over time in order to define the trends in the parameters of interest relative to
clearly defined management objectives. Monitoring may collect abiotic and/or biotic data using well-defined
methods and/or endpoints. These data, methods, and endpoints should be directly related to the management
objectives for the site in question.

Monitoring and Its Objectives

Many types of monitoring may be conducted at a site, such as detection monitoring (to detect changes in
ambient conditions), compliance monitoring (to evaluate compliance with regulatory requirements), and
remedial monitoring (to evaluate remedy effectiveness). Depending on the nature of the site, one or more
types of monitoring may be necessary and each type will have its own monitoring objectives.
As previously stated, the objectives of a Monitoring Plan will depend directly on the specific site activity
and associated management objectives. Monitoring objectives may therefore address the following:
• Evaluation of remedy effectiveness and protection of human health and the environment;
• Evaluation of contaminant migration;
• Evaluation of effectiveness of habitat mitigation; or
• Compliance with regulatory requirements.
At a project location, the monitoring, objectives and study design may also vary, depending on the physical,
chemical, and biological nature of the site (such as a freshwater polychlorinated biphenyl compound [PCB]
site, a soil lead site, or a prairie restoration site). In all instances, the associated Monitoring Plan objectives
ultimately should support a management objective for the site and its activity.

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Figure 3.9. Landfill monitoring system

Examination of the Site Activity

Identification of monitoring objectives will generally be based on the examination of the site
activity, which helps to identify physical, chemical, and/or ecological parameters that could be used later
in developing the Monitoring Plan study design. Examination of the site activity should address:
• The outcome of the site activity (what is it intended to accomplish and what are the
specific entities [e.g., biological or environmental parameters such as community
structure or contaminant concentration] expected to be affected bythe site activity;
• The mode of action of the site activity (how is the activity expected to meet its intended
objectives.
For activities related to contamination and risk issues, examination of the site activity should also
address:
• The human health and ecological endpoints determined to be at risk at the site (e.g.,
residential child, insectivorous bird); and
• The COCs and associated cleanup criteria (what are the contaminants driving the risk,
and what are the cleanup levels for reducing risks to acceptable levels?).
The time frame for implementation, operation, and completion of the site activity (such as a
removal action or habitat restoration) should be identified to provide temporal bounds to the monitoring
objectives and subsequent monitoring studies. Activities associated with, but not directly related to, the
objectives of the site activity should be identified at this time since these may also require consideration in
the Monitoring Plan. For example, mitigation measures may be needed to minimize environmental
impacts associated with the implementation and operation ofa remedial action. These mitigation measures
should be identified and evaluated to determine whether they need to be included in the Monitoring Plan.
If so, then additional monitoring objectives specific to those measures should be developed.

Available information on the site activity may be found in a variety of sources, such as risk
assessments, decision documents, environmental characterization reports, engineering design documents,

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habitat recovery plans, wetland delineations, and natural resource management plans. For example, under
CERCLA, relevant information regarding these parameters (e.g., the COCs, endpoints at risk, etc.) can
often be found in the ROD and its supporting technical reports, such as the baseline risk assessment
(BRA) and the feasibility study (FS). Under RCRA, similar information may be found in the Statement of
Basis/Response to Comments (SB/RTC), which documents the selected corrective measure and its
supporting technical reports, such as the RCRA Facility Assessment (RFA), RCRA Facility Investigation
(RFI), and the Corrective Measures Study (CMS)
Identify the Activity Outcome: Each site activity has a unique set of physical, chemical, and/or
biological endpoints that are the target of the site activity, and these endpoints should be considered by the
monitoring objectives. For example, the target endpoints for a grassland mitigation project may be a
specified level of plant species diversity or a specific community structure, while the target endpoint for a
bioremediation project may be a specified acceptable contaminant level in site soil. For the former
example, the monitoring objective would likely be related to demonstrating attainment of the target
species diversity or community structure. For the latter example, the monitoring objectives would be
related to demonstrating attainment of a specified COC soil concentration. Information regarding the site
activity outcome and its endpoints may also be useful during development of monitoring decision rules
andin the design of specific monitoring studies.

Identify the Activity Mode of Action: The mode of action of an activity defines how the activity is
expected to attain its desired outcome and relates the activity endpoints to the objectives. For example, at
a CERCLA soil bioremediation project the activity objective might be to reduce risks associated with the
contaminated soil to acceptable levels, with the activity targeting soil COC concentrations. The mode of
action of the bioremediation may be the microbial conversion of the COCs to less toxic breakdown
products, thereby reducing soil COC concentrations to acceptable levels. Monitoring objectives related to
this mode of action may focus on demonstrating that bioremediation is effectively reducing soil COC
concentrations. Information on the activity mode of action may also be useful during development of
monitoring decision rules and in the design of specific monitoring studies. In the case of a remedial action
involving implementation of a cap, the mode of action of the cap would be the elimination of exposure
pathways to human and/or ecological receptors. The associated monitoring objectives would focus on
ensuring cap integrity, which may include compliance with institutional controls that were established to
complement the on-going physical obligations associated with maintenance of the cap, and demonstrating
that exposure is not occurring at the site.

Monitoring at a landfill site shall be carried out in four zones (a) on and within the landfill; (b) in the
unsaturated subsurface zone (vadose zone) beneath and around the landfill; (c) in the groundwater
(saturated) zone beneath and around the landfill and (d) in the atmosphere/local air above and around the
landfill.
The parameters to be monitored regularly are:
(a) long-term movements of the landfill cover;
(b) leachate head within the landfill;
(c) leachate quality within the landfill;
(d) gas quality (optional) within the landfill;
(e) quality of pore fluid in the vadose zone;
(f) quality of pore gas (optional) in the vadose zone;
(g) quality of groundwater in the saturated zones and
(h) air quality above the landfill, at the gas control facilities, at buildings on or near the landfill and along
any preferential migration paths.

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The indicators of leachate quality and landfill gas quality must be decided after conducting a study relating
to the type of the waste, the probable composition of leachate and gas likely to be generated and the
geotechnical as well as hydro-geological features of the area.
A monitoring programme must specify a properly selected offsite testing laboratory capable of measuring
the constituents at current detection levels (ii) a methodology for acquiring and storing data; and (iii) a
statistical procedure for analyses of the data.
The following instruments/equipment shall be used for monitoring:
(a) Groundwater samplers for groundwater monitoring wells.
(b) Leachate samplers for leachate monitoring within the landfill and at the leachate tank.
(c) Vacuum lysimeters, filter tip samplers, free drainage samplers for leakage detection beneath landfill
liners.
(d) Surface water samplers for collection of sample from sedimentation basin.
(e) Downhole water quality sensors for measuring conductivity, pH, DO temperature in leachate wells,
groundwater wells and sedimentation basins.
(f) Landfill gas monitors (portable) for onsite monitoring of landfill gases.
(g) Active and passive air samplers for monitoring ambient air quality

It is recommended that the location of each type of instrument/equipment be finalized in conjunction with an
expert on the basis of the topography of the area and the layout of the landfill. A minimum of 4 sets of
ground water monitoring wells (one up-gradient and three down gradient) for sampling in each acquifer are
considered.

3.8. Closure and Post-Closure Maintenance Plan

A statement on the end-use of landfill site is an essential part of the plan for landfill closure and post-closure
maintenance. Some possible uses of closed landfill sites near urban centres include parking area, recreational
area etc. A closed landfill should be aesthetically landscaped.
A closure and post-closure plan for HW landfills must be evolved and should indicate the following
components:
• Plan for vegetative stabilization of the final landfill cover and side slopes
• Plan for management of surface water run-off with an effective drainage system.
• Plan for periodical inspection and maintenance of landfill cover and facilities.
• Plan for post-closure management of leachate and gas
• Plan for post-closure environment monitoring.

Closure and Post-Closure Care Requirements for Hazardous Waste Treatment, Storage and Disposal
Facilities
When a hazardous waste management unit stops receiving waste at the end of its active life, it must be
cleaned up, closed, monitored, and maintained in accordance with the Resource Conservation and Recovery
Act (RCRA) closure and post-closure care requirements. All hazardous waste management units, and the
treatment, storage and disposal facilities (TSDFs) where they are located, are subject to closure and post-
closure care requirements.

Closure
At TSDFs where multiple hazardous waste management units are in operation, one unit may cease operation
while the remaining units continue operating. This is known as partial closure. The closed units, or inactive
portion of the facility, are subject to all applicable closure standards. Final closure occurs when all
hazardous waste management units cease operation and close according to the regulations. When closing
units or facilities, two approaches are possible clean closure or closure with the waste in place:

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• In clean closure, owners remove all wastes from the unit and decontaminate or remove all
equipment, structures, and surrounding soils. Regulations require this approach for containers, tanks,
waste piles, incinerators, drip pads, and containment buildings.

• Closing with the waste in place, sometimes referred to as “closure as a landfill,” is the required
closure method for landfills, land treatment units, and any other hazardous waste management unit
that cannot meet the clean closure requirements. This also includes when owners cannot remove all
waste and contamination from tanks, waste piles, drip pads, and containment buildings.

Figure 3.10. Closure

Closure Plans
All TSDFs are required to prepare and submit written closure plans. A permitted facility submits this plan as
part of its permit application. Once the plan is approved by the permitting agency, it becomes part of the
facility’s operating permit. Interim status facilities must have written closure plans within six months of
becoming subject to the closure regulations.

All closure plans must include:

• A description of how each hazardous waste management unit will be closed.

• A description of how final closure of the facility will be achieved.
• An estimate of the maximum amount of hazardous waste kept on site during the facility’s operating
life.
• A detailed description of closure methods, including waste removal and site decontamination.
• A description of any other required steps, such as groundwater monitoring and leachate management.
• A schedule of closure dates, including closure dates for each unit and the entire facility.

Closure Timeframes
The regulations specify a strict timeline for completing closure. This process actually begins before the final
shipment of waste is received by a unit or facility with a notification of intent to close. Facilities with
landfills, surface impoundments, land treatment units, and waste piles are required to notify the EPA
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Regional Administrator 60 days prior to the date on which they intend to begin partial or final closure.
Facilities with containers, tanks, incinerators or boilers and industrial furnaces must make the notification 45
days in advance.

After a unit receives its last shipment of hazardous waste, it has 30 days to commence closure operations.
Within 90 days of receipt of the last shipment, all waste must be removed (if clean closing) or disposed on
site (if closing with waste in place). All closure operations must be completed within 180 days of receiving
the final waste shipment. In some cases, it may be possible for the facility to receive extensions on the 90-
and 180-day deadlines from the EPA Regional Administrator.

After closure operations are complete, the facility has 60 days to certify closure completion by submitting a
written certification via registered mail to the EPA Regional Administrator. This certification must be signed
by an independent, registered, professional engineer. At the same time (i.e., within 60 days of completing
closure), a survey plat indicating the location and dimensions of the closed hazardous waste management
unit(s) or facility must be submitted to the EPA Regional Administrator or local zoning authority.

Delay of Closure
Some facilities may be able to delay final closure and continue to receive nonhazardous waste after receipt
of the final shipment of hazardous waste. This option is only available to landfills, surface
impoundments and land treatment units. Only units with sufficient excess capacity that receive permission
from the EPA Regional Administrator may delay closure.

Post-Closure Care
Post-closure care is required for land disposal units that leave waste in place upon closure (i.e., landfills,
land treatment units, surface impoundments, or any other hazardous waste management unit that cannot
achieve the clean closure standards). These sites must monitor and maintain liners, final covers, leachate
collection and removal systems, leak detection systems, and gas collection systems to protect the
surrounding environment and population from releases of hazardous constituents. The standard post-closure
care period is 30 years, but this can be shortened or extended on a case-by-case basis by the permitting
authority (i.e., the EPA Region or the authorized state regulatory agency).

All units and facilities required to provide post-closure care are subject to the general post-closure
requirements found at 40 CFR. Each unit is also subject to unit specific post-closure care requirements
found in 40 CFR part 264 or 265 subparts:

• K (Surface Impoundments)
• L (Waste Piles)
• M (Land Treatment)
• N (Landfills)
• X (Miscellaneous Units)
All facilities required to provide post-closure care need to obtain a post-closure care permit. In applying for
a permit, the facility must complete and submit a post-closure care plan. This plan includes:

• A description of the planned groundwater monitoring program.

• A description of planned maintenance activities for the waste containment systems (e.g., liners, final
covers, leachate management systems).
• Contact information during the required post-closure care period.

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Once the post-closure care period ends, the facility owner/operator must provide (via registered mail) a
certification of post-closure care completion to the EPA Regional Administrator. This certification is due
within 60 days of completing post-closure care and must be signed by the facility owner/operator and an
independent, registered professional engineer.

Figure 3.11. Post closure

3.9. Landfill liner and cover criteria
Liner Criteria
The liner system shall be designed, constructed and installed to satisfy the following:
(a) Prevent migration of waste, leachate or gas to the adjacent subsurface soil or ground water or surface
water.
(b) Constructed of materials that have adequate chemical properties, physical properties and engineering
properties to prevent failure on account of loads, climatic conditions, and contact with waste or leachate.
(c) Placed in a stable manner on the base and side slopes.
(d) Installed to cover all surrounding soils likely to come in contact with the waste or leachate.
The base of the liner system (at the lowest point in a landfill) shall be atleast 2.0 meter above the highest
anticipated ground water table level.

Figure 3.12. Liner and cover system

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