vvEPA
United States
Environmental Protection
Agency
     State of the Practice for
     Bioreactor Landfills

     Workshop on
     Bioreactor Landfills
     Arlington, Virginia
     September 6-7, 2000

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                                            EPA/625/R-01/012
                                               January 2002
      State of the Practice for
         Bioreactor Landfills

Workshop on  Bioreactor Landfills
           Arlington, Virginia
         September 6-7, 2000
                       by
          Science Applications International Corporation
                  Reston,VA20190

                EPA Contract 68-C7-001 1
                    Prepared for:

         National Risk Management Research Laboratory
             Office of Research and Development
             U.S. Environmental Protection Agency
                 Cincinnati, Ohio 45268
                                        Recycled/Recyclable
                                        Printed with vegetable-based ink on
                                        paper that contains a minimum of
                                        50% post-consumer fiber content
                                        processed chlorine free.

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                                         Notice

    This document was compiled from presentations and open discussion at an EPA Workshop on
Landfill Bioreactors held September 6-7,2000, in Arlington, VA.The agenda, as well as participants,
is given in the appendices. Case studies from several states have been included as well.The purpose
of the Workshop was to provide a forum for discussion of the state of the art for the bioreactor theory,
operation, monitoring, and regulatory control. Comments have not been attributed to individuals in the
Workshop. Information presented herein does not necessarily represent the views of EPA, nor is it
specifically tied to reference materials. In many cases, the information presented is the opinion of the
speaker, generated by his or her background and operations experience. Every attempt has been
made to capture the Workshop discussion as a tool for looking at the research and regulatory needs
of the landfill industry. The document is not intended as an operational guide and should not be quoted
or used as such.
                                           11

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                                      Foreword
    The U.S. Environmental Protection Agency is charged by Congress with protecting the Nation's
land, air, and water resources. Under a mandate of national environmental laws, the Agency strives to
formulate and implement actions leading to a compatible balance between human activities and the
ability of natural systems to support and nurture life. To meet this mandate, EPA's research program
is providing data and technical support for solving environmental problems today and building a science
knowledge base necessary to manage our ecological resources wisely, understand how pollutants
affect our health, and prevent or reduce environmental risks in the future.

    The National Risk Management Research Laboratory is the Agency's center for investigation of
technological  and management approaches for preventing and  reducing risks from pollution that
threatens human health and the environment.  The focus of the Laboratory's research program is on
methods and  their cost-effectiveness for prevention and control of pollution to air, land, water, and
subsurface resources; protection of water quality in public water systems; remediation of contaminated
sites, sediments and ground water; prevention and control of indoor air pollution; and restoration of
ecosystems. NRMRL collaborates with both public and private sector partners to foster technologies
that reduce the cost of compliance and to anticipate emerging problems. NRMRL's research provides
solutions to environmental problems by: developing and promoting technologies that protect and
improve the environment; advancing scientific and engineering information to support regulatory and
policy decisions; and providing the technical support and information transfer to ensure implementation
of environmental regulations and strategies at the national, state, and community levels.

    This publication has been produced as part of the Laboratory's strategic long-term research plan.
It is published and made available by EPA's Office of Research and Development to assist the user
community and to link researchers with their clients.


                                            E. Timothy Oppelt, Director
                                            National Risk Management Research Laboratory
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                                 Acknowledgments



    The State-of-the-Practice for Bioreactor Landfills Workshop Report was prepared for the U.S. En-
vironmental Protection Agency by Science Applications International Corporation. Ms. Joan Colson of
the Office of Research and Development's National Risk Management Research Laboratory (NRMRL)
served as project manager. Dr. Fran Kremer, Mr. John F. Martin, Mr. David Carson and  Dr. Wendy
Davis-Hoover of NRMRL provided technical guidance for the development of the workshop. The plan-
ning group wishes to acknowledge the contributions of the many speakers, facilitators and participants
who contributed to the success of the workshop.

    Special appreciation is given to Mr. Robert Dellinger, Mr. Dwight Hlustick and Ms. Deborah Hanlon
of EPA's Office of Solid Waste for their participation in the planning of the meeting. Several workshop
participants provided  reviews of the  report including Ms. Susan Thorneloe, Ms. Michelle Laur of the
USEPA, Mr. Robert Phaneuf of the New York State Department of Environmental Conservation, Kerry
Callahan from the Association of State and Territorial Solid Waste Management Officials, and Mr. Kevin
Wolfe of Civil and Environmental Consultants. Dr. Debra Reinhart of the University of Central Florida
served as an editor of the report. The assistance of these people is greatly appreciated.
                                         IV

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                                  Table of Contents
Notice      	.!!
Foreword    	)"
Acknowledgments	IV
List of Tables	Y1
Acronyms   	•	v"

1.0   Introduction  	1'1
2.0   Regulatory Framework	2-1
      2.1   RCRA Subtitle D	2-1
      2.2  Effluent Guidelines	2-3
      2.3  Air Regulations	2-5
           2.3.1  CAA Section 111 New Source Performance Standards	2-5
           2.3.2 CAA Section 112 MACT	2-6
           2.3.3 Landfill Bioreactors and Air Regulation/Compliance Issues	2-7
      2.4  State Agency Perspectives	2-8
           2.4.1  State of New York Bioreactor and Leachate Recirculation Experience	2-8
           2.4.2 Association of State and Territorial Solid Waste Management
                 Officials'Experience	2-10
           2.4.3 Delaware Solid Waste Authority Experience	2-13

3.0   Bioreactor Theory, Operations, and Expected Business Benefits	3-1
      3.1   Definition and Characteristics of Bioreactor Landfills	3-1
      3.2   Bioreactor Process	3-5
            3.2.1  Factors Affecting the Bioreactor Process	3-6
            3.2.2  Metals	3-7
            3.2.3  Completion of the Bioreactor Process	3-8
      3.3   Bioreactor Landfill Systems	>	3-9
            3.3.1  Liners	3-9
            3.3.2  Leachate Collection and Internal Drainage Systems	3-10
            3.3.3  Gas Collection and Management	3-11
            3.3.4  Physical Stability of the Landfill and Waste Mass	3-12
            3.3.5  Temporary and Final Covers	3-14
      3.4   Operations	3-16
            3.4.1  Liquids Addition	3-16
            3.4.2  Waste Preprocessing	3-20
            3.4.3  Daily Cover	3-22
            3.4.4  Fires	3-22
            3.4.5  Control of Mud on Vehicles	3-22
            3.4.6  Nitrification and Odor Control	3-23
            3.4.7  Training	3-23
      3.5   Monitoring	3-24
            3.5.1  Leak Detection Systems	3-24
            3.5.2  Groundwater Monitoring	3-25
            3.5.3  Air and  Gas Monitoring	3-27
            3.5.4  Solids Monitoring	3-29
      3.6   Performance Measures and  Performance Optimization	3-31
      3.7   Closure and Post-Closure	3-33
      3.8   Benefits	3-33

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 4.0    Economics  	  4_-|
       4.1   Economic Analysis Conducted by EPA OSW	."!!!!!"!!!."!"!!."!!!!."!!'.!!!"!."!"!! 4-1
            4.1.1  Economic Study Overview	.....4-2
            4.1.2  Preliminary Results	".'.".'.'.'.'.'.'.'. 4-3
       4.2   Modeled Economics of Landfill Bioreactors by Private Industry	."".'.'".'.".'.'I".'.'.'.'4-4
            4.2.1  Economic Model Assumptions	4-4
            4.2.2  Preliminary Findings	4.5
       4.3   Decision Support Tool for Estimating Landfill Gas Emissions	!.".'.".'.'."""! 4-8
       4.4   Economic Aspects Identified by Workshop Participants	4-10

 5.0    Bioreactor Research and Data Needs	5-1
       5.1   EPA Office of Research and Development Bioreactor Landfill Research Directions ... 5-1
       5.2   Landfill Bioreactor Research Needs and Data Gaps	       5-2
            5.2.1  Design	5.3
            5.2.2  Operation	5.5
            5.2.3  Monitoring	5.5
            5.2.4  Life-Cycle	"!!!!.""""!!".!!!.'""!" 5-7
            5.2.5  General Suggestions	5-8

 6.0    Regulatory and Rule Change Needs	6-1
       6.1   EPA Perspectives	6-1
       6.2   Workshop Participant Suggestions	""""'.."!."!!! 6-2

 7.0    Conclusions and Recommendations	7-1

 Appendix A. Agenda for USEPSA Workshop on Landfill Bioreactors
 Appendix B. Workshop Attendee List
 Appendix C. Case Studies of Bioreactor Landfill Performance
                                         List of Tables

5-1   Research Needs and Data Gaps for Bioreactor Landfill Operations.
.5-6
                                               VI

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                                   Acronyms
ASTSWMO       Association for State and Territorial Solid Waste Management Officials
BOD            biological oxygen demand
C A A            Clean Air Act
C & D            construction and demolition
c f m             cubic feet per minute
CO 2             carbon dioxide
C O             carbon monoxide
COD            chemical oxygen demand
CRADA          Cooperative Research and Development Agreement
C W A            Clean Water Act
DOE            Department of Energy
D Q O            data quality objective
D S W A          Delaware Solid Waste Authority
EPA            Environmental Protection Agency
FEMA            Federal Emergency Management Agency
FT1R             Fourier Transform InfraRed
HAP            hazardous air pollutant
HPLC            high pressure liquid chromatography
LIDAR           light detection and ranging
MACT           maximum achievable control technology
M S W           municipal solid waste
MSW -DST       municipal solid waste decision support tool
NCER           National Center for Environmental Research
NMOC           nonmethane organic compounds
N O x            nitrogen oxide
NRMRL           National Risk Management Research Laboratory
NSPS/EG         New Source Performance Standards and Emission Guidelines
NYSDEC         New York State Department of Environmental Conservation
O R D            Office of Research and Development
O S W            Office of Solid Waste
POTW            publicly owned treatment works
 p V C             polyvinyl chloride
 RCRA            Resource Conservation and Recovery Act
 RD&D            research, development, and demonstration
 SBREF           A Small Business Regulatory Enforcement Fairness Act
 SCADA           supervisory control and data acquisition
 SITE             Superfund Innovative Technology Evaluation
 STAR           Science,to Achieve Results
 S W A N A        Solid Waste Association of North America
 T D S            total dissolved solids
 T S S             total suspended solids
 V O C            volatile organic compound
 W M I            Waste Management, Inc.
 X L              excellence and Leadership
                                         vn

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Increased interest in advancing landfill technology and encouraging results from laboratory research
and pilot program field studies suggest that municipal solid waste can be rapidly  degraded and can be
made less  toxic.  EPA  is interested in evaluating this potentially promising technology to help verify
claims being made and document potential environmental  benefits or  impact.  A method of active
landfill operation, discussed in this document as a landfill bioreactor, operates with the express purpose of
degrading waste mass inside a modern containment system. Degradation can be accelerated and optimized through
a variety of processes and/or steps with the goal of minimizing long term environmental risk. There are a variety of
different designs, but typically these systems include liquid, usually leachate, and/or air circulation systems, with
leachate and gas  collection. Such bioreactor landfill operations may be able to degrade the waste mass within a
shorter period of time than is  experienced in traditional landfill  operations.  As a result of these operations,
leachate may rapidly improve and landfill, volume may decrease.  This recovered airspace would offer landfill
operators the opportunity to utilize the landfill volume more  efficiently and to extend the  landfill's useful life and
may reduce the need for construction of new landfill sites.

Bioreactor landfill operations may  also result in significantly increased landfill gas  emissions and at a
faster rate over those seen in conventional municipal solid waste landfills.  These landfill gases consist
of methane, carbon dioxide (C02), trace amounts of volatile organic compounds (VOCs), and hazardous air
pollutants (HAPs) for those landfills operated anaerobically. Landfills are typically in urban areas and their impact
on air quality has resulted in Clean Air Act (CAA) regulations requiring large landfills to collect and control landfill
gas. However, these rules were based on conventional landfilling practice and not the increased rate and amount
of landfill gas that can result from  bioreactors. Landfill gas can be flared or recovered for its energy potential
which helps to offset fossil fuel consumption. One of the potential advantages of bioreactors is to help make
energy recovery projects more economical by increasing the  quantity and rate of landfill gas production.

The purpose of the Environmental Protection Agency  (EPA) Workshop  on Landfill Bioreactors, held
September 6-7, 2000 in Arlington, Virginia, was to provide a forum to EPA, state government,  local
government, solid waste industry, and academic research representatives to exchange information and
ideas on bioreactor landfills.   This interactive workshop provided opportunities to:
 •       Assess  the state-of-the-practice  of bioreactor landfill design, operation,  and maintenance

 •       Hear case studies of bioreactor landfill use, especially where data exist for comparison between
         conventional and bioreactor approaches

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 •      Discuss long-term monitoring needs for environmental compliance for groundwater, gas emissions, leachate
        quality, liner stability, physical stability, and other factors to satisfy life-cycle integrity and economic
        viability concerns

 •      Exchange views,  technical  concerns, and implementation concerns regarding pending and
        planned regulations affecting landfills in general and the regulatory framework to be developed
        for bioreactor landfills

 •      Examine the economic viability, impacts,  and benefits of bioreactor landfill implementation at
        full scale

 •      Identify additional research needs.


This document is intended to summarize  the Workshop  discussions, presentations,  and recommenda-
tions.  It addresses the salient features of.the discussions, but does not present a transcript of discus-
sions nor specific participant remarks.  Furthermore, this summary of Workshop discussions is not
intended to reflect EPA policy and does not constitute guidance to states or to landfill owners.
This document is organized as follows:

•       Section 2 summarizes the information presented on the current regulatory framework for land-
        fills, Federal regulatory agency concerns and data needs, and state agency experiences in regu-
        lating  and operating bioreactor landfills

•       Section 3 presents information  on bioreactor definitions, designs,  operations, monitoring, clo-
        sure, and potential benefits as  described throughout Workshop presentations

•       Section 4 provides an overview of bioreactor landfill economic analyses conducted by Federal
        agencies  and private industry as well as economic or financial considerations identified by
        Workshop participants

•       Section 5  discusses current  EPA-sponsored bioreactor landfill research as well as research needs
        and data gaps for bioreactor design,  operation, and monitoring identified in Workshop presen-
        tations

•       Section 6 identifies potential issues and considerations  in developing regulations for bioreactor
        landfills

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•      Section 7 highlights conclusions from the Workshop.

Supporting this Workshop summary are three appendices. Appendix A provides the Workshop agenda,
Appendix B lists the Workshop attendees,  and Appendix C summarizes the six case studies presented
during the Workshop. An acronyms list is also provided at the beginning of the document.

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This section summarizes the existing and. planned Federal regulatory framework applicable to bioreactor
landfills, Federal regulatory agency concerns and data needs, state regulatory program experiences, and
state agency experiences with bioreactors and leachate recirculation. Section 2.1 presents the status of
landfill regulatory programs under the Resource Conservation and Recovery Act (RCRA) Subtitle D as
well as information needs  sought in the April 6, 2000 Federal Register requests pertaining to bioreactor
landfills. Section  2'.2 reviews the recent effluent guidelines established under the Clean Water Act
(CWA) for hazardous and nonhazardous waste landfills. Section 2.3  summarizes the existing and planned
regulatory  requirements for municipal solid waste landfills under the CAA as well as air-related con-
cerns regarding bioreactor landfill gas generation,  monitoring, and management. Section 2.4 addresses
the bioreactor experience and regulatory issues confronted by state government agencies as both regu-
lator and landfill operator.

2.1    RCRA SUBTITLE D
On October 9,  1991, EPA issued minimum  national standards for municipal landfills under the provi-
sions  of 40 CFR Part 258 of RCRA Subtitle D, which is  administered by the Office of Solid Waste
(OSW).  As of August 11, 2000,  EPA acknowledges 48 fully or partially approved state and municipal
solid waste landfill permitting programs under D.  While the Subtitle D standards  allow for leachate
circulation in a municipal landfill with a specified composite liner, other Subtitle D requirements (e.g.,
daily cover, closure/post-closure care, limitations on liquid addition to landfills, and prohibiting leachate
recirculation at landfills with alternative liner systems approved by  states) may be barriers to bioreactor
operation.

Upon initiation of 40 CFR Part 258,  EPA had not received any formal requests to change these stan-
dards as they related to leachate recirculation and the associated limitations to bioreactor operations.
However, over the last 2  years, EPA, state  and local governments,  and the solid waste industry have
engaged in a significant amount of discussion regarding leachate recirculation and bioreactors.  One
outgrowth of these discussions is the potential need for EPA to  consider making changes  in the RCRA
Subtitle D municipal solid waste landfill requirements to support more widespread application of
these waste management techniques.

At the same time, Section 610 of the Small Business Regulatory Enforcement Fairness Act (SBREFA)
 requires a review of regulations affecting small businesses every 10 years.  These requirements  specifi-

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cally affect the economic impact analysis prepared prior to issuing the RCRA Subtitle D requirements in October
1991 • EPA announced this SBREFA review in the Federal Register on November 22,1999 and requested comments
by February 29, 2000 on the entire EPA solid waste management program. In the April 6, 2000 Federal Register,
EPA issued a public request for additional data and information on alternatives for liner performance, leachate
recirculation, and bioreactor landfills with a comment response deadline of August 7,  2000, and  a later date
(October 6) for bioreactor landfill responses.  As feedback from these information requests is compiled and
assessed, EPA expects to issue additional information request notices.

EPA is interested in receiving information about the  RCRA landfill rules in general and the bioreactor
landfills in particular.   Specific topics of interest include, but are not limited to, the following:
•      Liners
       -      Alternative liner performance as compared to composite liners
       —      Types of alternative liner design  for leachate recirculation

•      Leachate Recirculation
       -      Impacts of leachate  quality, quantity,  and loading on the liner system
       -      How quickly leachate recirculation affects the rate and extent of landfill waste mass
               stabilization
       —      How to measure stabilization
       -      How to determine when a landfill is sufficiently stabilized

•      Bioreactors  Landfill Design,  Operation,  and Closure
       —      Nature and  scope of current bioreactor projects
       -      Design, operation, and performance
       -      Advantages  and  disadvantages  of leachate generation
       -      Gas  generation
       -      Experience with alternative liner designs
       -      Modifications needed to daily and final cover requirements
       -      Monitoring needed to ensure proper bioreactor functioning
       -      Technology and timing impacts on current closure and post-closure requirements
       -      Impacts of adding liquid wastes other than recirculated leachate to a landfill (types of
               liquids, volumes,  performance  impacts)
       —      Methods for waste mass aeration and aerobic bioreactor landfill operations
       -      Methods of waste mass temperature  monitoring,  and control
       -      Management and  safety issues associated with gas generation, internal waste  mass tem-
               peratures, air injection, and other aspects  of bioreactor landfill operation and whether
               additional regulation will be needed in these areas
•      Economics
  CHAPTER TWO";

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       -      Costs associated with bioreactor design, construction, and operation
       -      Comparative cost-effectiveness of bioreactor landfill versus  composting organics in a
               conventional municipal landfill

•      Regulatory changes potentially needed to allow bioreactor operation if bioreactors are found
       to be protective of human health and the environment.
Information received from the Federal Register notices as well as independent literature searches will form the
basis for EPA determinations of the need for any regulatory changes to Subtitle D.  EPA recognizes that there are
many different definitions of bioreactors and that leachate recirculation and bioreactor landfills are not necessarily
the same.  Therefore, if any new regulations are developed, they will have to address a broad range of liquid
additions and/or recirculation, and at all times will emphasize protection of human health and the environment.

2.2    EFFLUENT GUIDELINES
Effluent guidelines  are national baseline  regulations for both direct dischargers (to waters of the United
States) and indirect dischargers (to  publicly-owned treatment works [POTWs]).  These guidelines  are
industry-specific, numerical, and technology-based,  but do not directly address bioreactor landfills.
The landfill effluent guidelines cover less than  150 facilities nationwide and are estimated to reduce
pollutant discharges to  surface waters by over 900,000 pounds per year, including significant quantities
of ammonia and toxic  organic constituents.

EPA first proposed the  landfill effluent guidelines in the Federal Register on February 6,  1998 with the
final rule published on January 19,  2000.  The  landfill effluent guidelines apply to both RCRA Subtitle
C (hazardous waste) and Subtitle D (municipal) landfills.  However, these  guidelines do not apply to
"captive" landfills  associated with  industrial facilities since EPA found  in the background research for
developing these guidelines that the  leachate generated in the industrial landfills was generally similar
to the industrial product at the site  rather than to leachate generated  in other types of landfills.  This
leachate was typically  treated in the facility's industrial wastewater plant because of its similarity to
other onsite waste streams.

In addition,  the  landfill effluent guidelines did not establish POTW pretreatment standards for a num-
ber of reasons.   Theses include the small quantity  of landfill wastewater  discharged to POTWs,  few
instances of POTW upset or interference resulting from landfill leachate, and the preference to address ammonia
discharges locally.

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 The landfill effluent guidelines address the following types  of wastewater from landfills and their
 operation:
 •      Leachate
 •      Gas collection condensate
 •      Drained  free liquids
 •      Contaminated storm water
 •      Laboratory-derived wastewater
 •      Truck equipment wash water.

 The landfill effluent guidelines exclude the groundwater and wastewater from recovery pumping wells
 from regulation.  The rationale for this exclusion involves the dilute nature of these waste streams, the
 site-specific nature of the constituents, and the management controls already in place under RCRA
 corrective action measures. The guidelines also exclude non-contaminated storm water such as runoff
 from cap, daily cover, intermediate cover, and final cover because these flows  are believed to  be  ad-
 equately controlled by the storm water multi-sector general permit as published in the Federal Register,
 Volume 60, page 50803.

 In developing these effluent guidelines, EPA conducted extensive background  research  involving  the
 following:
 •       Screening surveys of 4,000 facilities regarding landfill type,  amount of waste landfilled, amount
        of leachate generated,  wastewater discharges,  and wastewater treatment

 •       Detailed questionnaire surveys of 220 facilities regarding landfill type, amount of waste landfilled,
        wastewater treatment types, wastewater monitoring data,  wastewater treatment design,  and
        economic data

 •       Detailed monitoring questionnaire surveys of 27 facilities requesting up to 3 years of analytical data

 •       Raw wastewater grab sampling at  15 landfills (commercial,  private, municipal)

 •       Raw wastewater and treated effluent sampling at 6 landfills (hazardous  and nonhazardous).
From this information, EPA established different effluent limitations for each landfill category (hazardous, nonhaz-
ardous) . This subcategorization was necessary because EPA found that while both landfills had similar concentra-
         ••••*
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tions of ammonia, hazardous waste landfills had a wider range of toxic organic pollutants and higher concentra-
tions of metals.  For the nonhazardous waste landfills, EPA identified 32 pollutants of interest and established
surface water discharge limits for biological oxygen demand (BOD), total suspended solids (TSS), ammonia, zinc,
phenol, paracresol, and benzole acid. For the hazardous waste landfills, EPA identified 63 pollutants of interest
and established surface water discharge limits for BOD, TSS, ammonia, seven organics, and three metals.

In this regulatory  development process,  EPA identified 9,882 Subtitle D landfills and 595 Subtitle C
landfills.  Many are closed and no longer discharge.

EPA research indicated that simple gravity flow drain fields are the most common type of leachate
collection system.  Other systems in use include french drain, compound collection, and a number of
miscellaneous  technologies.  No leachate collection systems were found at 46 nonhazardous  landfills.

EPA also found that over 338 landfills had no  direct wastewater  discharges to surface waters or to a
POTW. These  landfills manage their wastewater by recirculation back into the landfill, transport off-
site for treatment/disposal, and underground injection.

Access to publicly  available landfill effluent guideline data in the  form of development  documents and
databases is provided on the Office of Water website at http://www.epa.gov/ost/guide/landfills/.
2.3   AIR REGULATIONS
EPA concerns regarding bioreactor landfill operations are primarily linked to the compliance timing
for gas collection and control in current municipal solid waste regulations developed under Section
111 of the CAA (40 CFR 60 Subparts WWW and Cc) and the rapid generation of large quantities of
landfill gas produced under bioreactor landfill operations.  Changes in landfill gas constituent concen-
trations and leachate gas generation potential are additional concerns.

2.3.1 CAA SECTION 111 NEW  SOURCE PERFORMANCE STANDARDS
EPA developed new source performance standards and emission guidelines (NSPS/EG) for municipal
solid waste landfills (40 CFR 60 Subparts WWW and Cc) under the statutory authority of Section 111

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of the CM. The rulemaking effort began in  1987, the rule was proposed in May 1991, and the final
rule was promalgated in March 1996. Bioreactor landfills and leachate recirculation were not consid-
ered in the development of this regulation.

The goal of the NSPS/EG  regulation is to  establish performance standards for  new sources and
existing sources that reflect the degree of emissions limitation and the percentage reduction achievable
through best available technology.  Landfill gas is the pollutant of interest in the landfill NSPS/EG (40
CFR Part 60  Subparts WWW and Cc),  which uses nonmethane organic compounds (NMOC) as a
surrogate for landfill gas.  Therefore, the standard limits are specified as a reduction of NMOC.  How-
ever, it should be noted that some level of co-control exists since the control devices also destroy VOC
and HAP contained in the landfill gas.

This standard  applies to municipal solid waste landfills that accepted waste  after November 7,  1987.
Compliance requirements depend on the landfill size and the  volume of estimated emissions. For
many landfills, compliance generally involves only reporting and recordkeeping.   However, landfills
over a certain  size  (2.5 million megagrams of waste and 2.5 million cubic meters in size) must estimate
uncontrolled NMOC emissions.  For landfills with uncontrolled NMOC emissions estimated  at  50
Mg/yr  or more, additional compliance requirements apply, including collection/control of landfill gas
and adherence to specific operational standards.

This regulation also establishes time limits for installing and beginning operation of a landfill gas
control system once the size NMOC thresholds are exceeded.  Installation timing varies depending  on
the age of the waste in place and the landfill cell status  (e.g., active,  at final grade/closed). Clearly,
existing air regulations are based on conventional landfilling practices and  do not  address concerns
associated with bioreactor operations.

2.3.2 CAA SECTION 112  MACT
The goal of Section 112 of the CAA is to reduce the  emissions of toxic air pollutants from all affected
sources to levels achieved by the best performing affected sources using a technology- based approach.
Pollutants of interest are the HAP listed in Section 112(b) of the CAA.  Of  the  188 HAPs listed, EPA
identified approximately 30 HAPs  typically contained in landfill  gas.

EPA is developing a maximum achievable control technology (MACT) regulation (40 CFR 63 Subpart

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AAAA)  under the statutory authority of Section  112 of the CAA.  Publication of the proposed MACT
in the Federal Register occurred on November  7, 2000. Publication of the final promulgated rule is
anticipated in September 2001.

MACT standards typically apply to major source categories, but can include area sources.  These regu-
lations establish emission limits either for a single HAP or for a combination of HAPs.  The landfill
MACT regulation will affect landfills that accepted waste after November 7,  1987, and are major sources
as defined in the regulations.  In addition, there may be some circumstances where these regulations
also apply to area sources since landfills were listed as an urban air toxic concern under the Urban Air
Toxics Strategy.

Landfills affected by these regulations are required to:
•       Comply with NSPS regulations
•       Develop and follow a startup, shutdown, and malfunction  plan
•       Continuously comply with control device operational standards
•    •  Conduct semiannual rather than annual  compliance reporting.

2.3.3  LANDFILL BIOREACTORS AND AIR REGULATION/COMPLIANCE ISSUES
The primary bioreactor concern identified  by  EPA with regard to air  quality is  the impact of the
increased quantity and faster generation rate of landfill gas over what is typically seen in traditional
municipal solid waste landfills.  Additional concerns included changes in landfill gas constituents, con-
centrations, and in landfill gas generation potential.  The current air regulations  do not adequately
address the  design and operation issues specific to  bioreactor landfills.  Of particular note is the poten-
tial for bioreactor landfills to see significant gas generation within 60 to 90  days after recirculation
begins,  while the regulations allow 30 months to  5 years before a gas collection and control system
must be installed and operating.

EPA currently anticipates that the landfill MACT air regulation will address the design of landfill gas
collection and control systems, the criteria that require their installation, and the timing of their instal-
lation to name just a few items. The preamble of the proposed MACT  regulation discussed the air
issues associated with bioreactors.

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2.4    STATE AGENCY PERSPECTIVES
Workshop presentations provided background on state agency experiences with bioreactors and leachate
recirculation from regulatory, operational,  and demonstration project perspectives. Section 2.4.1 pre-
sents experience in the State of New York regarding  bioreactor landfill and leachate recirculation
regulation as well as demonstration project experience.  Section 2.4.2 summarizes the experiences of
10  states in regulating and operating bioreactors and leachate recirculation under a newly formed
Association  of State and Territorial Solid Waste Management Officials (ASTSWMO) Bioreactor Land-
fill  Work Group.  Section 2.4.3 provides leachate recirculation demonstration project experience of the
Delaware Solid  Waste Authority (DSWA).

2.4.1  STATE OF NEW YORK BIOREACTOR AND LEACHATE RECIRCULATION EXPERIENCE
The State of New York solid waste management regulations (6 NYCRR Part 360)  have encouraged the
use of bioreactor landfill operations since October 9, 1993. These  regulatory requirements are "pas-
sive" in that they ask  landfill operators to consider active landfill management concepts and tech-
niques (bioreactor landfill concepts). These provisions were included in the State's solid waste  manage-
ment regulations as an acknowledgment that there are  numerous potential benefits which could result
from a properly designed and operated bioreactor landfill,  including:
•       Optimization of solid waste compaction and increased waste mass densities

•       Optimization of landfill disposal capacity and conservation  of land resources

•       Extension of the operational site life of existing and proposed landfills

•       Reduction of the volume and  pollution potential  of leachate generated from landfills

•       Enhanced  quality and rate of generation of landfill gases, maximizing  the potential energy
        recovery and associated revenues along with minimizing air emissions

•       Minimization of the long-term pollution potential of the wastes being disposed.

It is not the intent of New York State  to mandate that all landfills pursue bioreactor operations.  The
State's regulatory provisions encourage landfill owners to consider promoting rapid waste mass stabilization
methods (bioreactor landfill operations) in their operations.  These regulations offer the flexibility to landfill
operators to pursue landfill bioreactor concepts in a manner which best fits into their landfills' operation.
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Overall, the State of New York has conservative regulatory requirements for municipal solid waste
(MSW) landfills.  The State's regulations require that all MSW landfills be lined with double composite
liners with dual leachate collection and removal systems with required upper liner performance moni-
toring.  As of September 2000, there were 38 double-lined landfills operating in the State.  New York
State's Department of Environmental Conservation  (NYSDEC) experience with double-lined land-
fills  has been favorable in that they have been  demonstrated to be working as designed, affording a
high degree of leachate containment. Based on required liner system performance monitoring and
results from groundwater monitoring conducted at these  double-lined landfills, it is clear that these
double-lined landfills, when properly operated, pose little to no  threat to groundwater quality.  As
confidence grew in the ability of the modem landfill's liner systems to prevent groundwater contamination it was
determined appropriate to look ahead to modern/alternative landfill operations that would limit a landfill's long-
term pollution potential.

NYSDEC has been involved with six bioreactor landfill projects that have taken place in New York
State, lasting in duration from  90  days to approximately  5 years, and there is currently one additional
project being proposed.  The projects which have taken  place  have been pilot and/or research, devel-
opment and demonstration projects  which have not been integrated into a permanent form of long-
term landfill operation.  Four of the bioreactor projects, including the one which is proposed, have used or
will  use an aerobic decomposition  process to help enhance  the initial waste mass decomposition process.
The  other three projects studied the benefits of anaerobic waste mass decomposition and processes.

In general, NYSDEC's  experiences with these bioreactor projects  were positive.  These projects, al-
though they were of limited duration, did establish that the merits of a bioreactor landfill operations
are  achievable to varying degrees.  These demonstrations also established  that enhanced odor and
landfill gas generation could contribute to operational compliance problems  if effective landfill  odor
and gas control provisions  are not applied early upon initiation of leachate recirculation.

NYSDEC considers bioreactor landfill operational methods to be an alternative form  of landfill op-
 eration.  Since NYSDEC experience has been largely with double-lined landfills, the issue of whether
 the  act of leachate  recirculation  has the  potential to generate additional upper liner system leakage
 during bioreactor landfill operations is of great interest.   To date,  NYSDEC has not experienced
 increased upper liner  system leakage as a result of leachate recirculation in its demonstration projects.
 In one instance, leachate generation was shown to have decreased upon leachate recirculation; there-


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 fore, the bioreactor landfill operation appeared to consume the recirculated leachate within the decomposing
 waste mass rather than generating more leachate. Operational experience indicates the importance of not over
 saturating the waste mass, which could increase the head on the liner system and cause excessive liner system
 leakage. Over saturation of the waste mass can also diminish the decomposition process and pose waste mass
 geotechnical stability problems and as such needs to be avoided.

 New York State's regulatory perspective on bioreactor landfill operations hinges on the double-lined
 landfill's ability to  demonstrate both  acceptable leachate accountability and acceptable overall opera-
 tional compliance from a bioreactor landfill proposal. It  is NYSDEC's belief that neither the  State nor
 federal regulations should stymie innovative advances in modern solid waste management, but rather
 need to be flexible while maintaining an ability to assert the needed regulatory controls and  oversight
 to ensure adequate protection  of public health and the environment.  In  such a regulatory framework
 all parties  stand to gain.

 2.4.2 ASSOCIATION OF STATE AND TERRITORIAL SOLID WASTE MANAGEMENT
        OFFICIALS' EXPERIENCE
 ASTSWMO  is a national, non-profit organization representing the managers of solid waste, hazardous
 waste, remediation, recycling/reduction/minimization,  and underground storage tank programs of
 the States and Territories.  Among other programs,  the Association's  membership regulates the imple-
 mentation  of solid waste programs addressed by the 40 CFR Part 258 Solid Waste Disposal Facility
 Criteria of RCRA Subtitle D.

 Due to recent increased interest from  its member states  on the  topic  of bioreactor landfills  the
 ASTSWMO  Solid Waste Subcommittee assembled a  Bioreactor Landfill Work  Group to  develop  com-
 ments in response to the April 6, 2000 Federal Register notice, Alternative Liner Performance.  Leachate
 Recirculation. and Bioreactor Landfills Request for Information and  Data, and to track EPA's  progress
 on developing regulations and guidance on bioreactor landfills.  The Work Group is comprised of 10
 state  solid  waste management  officials who have experience with implementing bioreactor  landfills
 and/or leachate  recirculation  from across the country (CA, DE, FL, IA, KY,  NY, TN, VT, VA,  WI).
 These remarks  are based on the Work Group's collective experience with  bioreactor landfills.

The first Work Group meeting was held on August 17, 2000 with  representatives from California,
Florida, New York, Tennessee, Virginia, and Wisconsin in attendance.  During this initial meeting the
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Work Group concluded the following:

•       All attendees recognized the merits of bioreactor landfill operations and supported bioreactor
        landfill operations as a viable alternative to conventional landfill operations.  All attendees
        expressed having had positive experiences with bioreactor landfills  in their states.

•       With respect to leachate recirculation, each attendee expressed preference for a federal regula-
        tory program that  would allow each State to make its own decisions about what is an accept-
        able minimal liner system.

•       Each attendee expressed preference for  a federal regulatory program that would allow each
        State to make its  own  decisions about whether a landfill can recirculate liquids other than
        leachate as long as  the liquids are aqueous in nature and are found to be compatible with a landfill's
        microbiology.

•       The attendees all agreed that limited data are available from  previous bioreactor pilot projects
        (10 as of September 2000 from the 7  attendee states) and there is uncertainty in what future
        data will show.  The Work Group indicated  that another 5 bioreactor landfill projects will be
        coming into existence among the 10 State members.

•       All  the attendees agreed that active gas  collection and control  systems will lively be necessary at
        bioreactor landfill operations because many of the states had experienced  odor problems at
        their bioreactor landfill projects.

•       The concern for the potential for landfill fires was raised by the attendees as being attributed to
        the increased waste mass temperatures associated with bioreactor landfill operations.  It was
        suggested that monitoring of carbon monoxide (CO) concentrations in bioreactor/ landfill gas could act
        as a good indicator for subsurface landfill fires. The basis for this recommendation is that literature
        indicates that CO concentrations in conventional landfill decomposition gases should only be about 2-4
        ppm.

 •       All attendees agreed that recirculation of liquids heightens regulatory concerns about surface
        seeps, however, all believed that a comprehensive bioreactor operation and  contingency plans
        would be effective in mitigating this concern.

 •       Geotechnical stability of the waste mass  and liner systems associated with bioreactor landfill
        operations were raised by the Work Group as a regulatory concern. The added loading/weight
        attributed to leachate recirculation and other associated bioreactor landfill waste mass density
        increases is the basis for this regulatory concern. The Work Group agrees  that all bioreactor
        proposals should  be supported by a geotechnical analysis demonstrating structural integrity of
        the subgrade, liner  and leachate  collection and removal system,  and that  stability analyses

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         demonstrate acceptability for both static and appropriate seismic conditions for the site.

 •       The Work Group  expressed a need for federal guidance regarding proper bioreactor landfill
         performance  monitoring,  addressing such issues as  how to determine when the waste mass is
         stabilized, when to reduce long-term monitoring, and whether 30 year minimum post-closure
         maintenance and monitoring requirements can be reduced.

 In general, the Work Group noted the need to  avoid developing landfill bioreactor regulations that are
 so prescriptive that practitioners and regulators are kept from being able to continue to learn from the
 bioreactor operation experiences which are yet to be gained.  The Work Group  also suggested the need
 to proceed cautiously with bioreactor landfill implementation since the bioreactor process  is not yet
 well understood and that a single failure,  even  on  an isolated account, could impair the ability to  gain
 public trust and support  for these modern  disposal facilities.  These concerns for proceeding with
 caution should not present a barrier to implementation of bioreactor projects, but rather reinforce the
 need for comprehensive and well thought out operations and contingency plans associated with this
 alternative form of landfill operation.

 The Work Group views the bioreactor landfill as an alternative form of  landfill which involves in-
 creased sophistication and complexity over traditional municipal solid waste landfill operations  and
 management requirements.  As such,  the Work Group advocates that specialized bioreactor landfill
 operator training programs be developed to address this need.  Such training could be offered through
 federal training programs or be incorporated into existing training programs, such as those sponsored
 by the Solid Waste Association of North America (SWANA).

 The Work Group also noted that additional Federal technical guidance is needed. One recommenda-
 tion is to modify the existing solid waste technical guidance document to add a chapter that specifically
 addresses bioreactor landfills. Other areas  needing additional guidance associated with bioreactor land-
 fills include design, operation, monitoring, closure,  and post-closure.

 In summary, the Work Group advocates that the federal regulations need to impart flexibility into the
 current solid waste management regulations.  Such flexibility should allow modification  of conven-
 tional  landfill operations while  maintaining appropriate regulatory attention/concern for the landfill's
liner system design, waste mass stability, and the standard operational criteria as is required for ah1 solid
waste landfills necessary to protect water and air resources and public  health and safety.

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2.4.3  DELAWARE SOLID WASTE AUTHORITY EXPERIENCE
The DSWA is the State entity responsible for landfill operations in all three counties of the State of
Delaware. Since 1980, there are also 10 locations in Delaware where the DSWA has conducted some
type of bioreactor landfill operation.  These operations have included recirculation of leachate for 2 or
more years  at some landfills, use of single- or double-lined landfills,  use of one or more types of
alternate liners,  and use of different  capping materials.

Initial regulations for municipal solid waste landfills were promulgated in the 1970s with increased
stringency in the 1980s.  The regulations became even more restrictive in the 1990s to the extent that
it is becoming more difficult for  DSWA to explore alternate landfill designs and operations.  As a
result, there is  great interest in making some regulatory changes to allow the flexibility needed to
explore bioreactor and  leachate recirculation practices; for  example, the restrictions against leachate
recirculation in RCRA Subtitle D.

The DSWA conducted a Test Cell Program from 1989 to 1998 with EPA participation.  This Test Cell
Program explored various practices  for leachate addition, recirculation, and collection including the
following:
•       Use  of septic pipe leach fields and vertical recharge  wells

•       Horizontal leachate recirculation in conjunction with landfill gas extraction

•       Use  of perforated pipe to spray liquids onto landfill cover

•       Ponding liquids on landfill cover

•       Recharge wells

•       Spraying systems to distribute leachate

•       Concrete manholes for leachate collection

•       Creation of distinct drainage areas with sandy cover material in conjunction with storm water
        runoff controls
•       Use of aboveground  and underground tank systems for liquids management.

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The majority of these technologies dated to the mid-1980s.  Many of the methods for leachate appli-
cation to the test cells resulted in significant odor problems.

DSWA experience to date offers the following considerations in developing regulations for bioreactor
landfills:

•      Allow flexibility to conduct research and to test new technologies

•      Base the regulatory requirements upon good science

•      Favor performance-based requirements rather than prescriptive regulations to provide the nec-
       essary flexibility for these systems

•      Stay in  communication and work together with regulatory partners.

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As a result of increased interest, EPA is evaluating the operation of landfills as bioreactors to deter-
mine their viability as a solid waste management technique and their environmental impact.  This
section summarizes Workshop  discussions on bioreactor definitions, designs, operations, monitoring,
closure, and potential benefits.  Section 3.1 presents the definitions and characteristics of bioreactor
landfills.   Section 3.2  describes the bioreaction process and approaches for determining its  completion.
Section 3.3  discusses bioreactor landfill systems  and their design issues as compared to conventional
municipal solid waste landfills.  Section  3.4 reviews features of landfill operations specific to bioreactor
landfills.  Section 3.5 provides an  overview of the monitoring systems for landfill performance and
release detection and measurement.  Section 3.6 identifies performance measures and factors  to con-
sider in optimizing bioreactor landfill performance.  Section 3.7 considers closure and post-closure
issues specific to bioreactor landfills.  Section 3.8 summarizes some of the potential benefits that may
be achieved from the use of bioreactor landfills and leachate recirculation.

3.1   DEFINITION  AND CHARACTERISTICS OF BIOREACTOR  LANDFILLS
Bioreactor landfills promote microbial  waste  mass decomposition, which results in the generation of
landfill gas  and a decrease in total waste mass and volume.  Some Workshop participants suggest that
bioreactor landfills are essentially large-scale, in-ground composting operations.  Others view bioreactor
landfills as providing  solid waste treatment and draw similarities to a wastewater treatment facility with
the intention of using the landfill  space for treatment rather than indefinite future storage.

Various past studies  of conventional municipal solid waste landfills developed gas generation curves
that show specific changes for internal  landfill conditions over time and enable different phases to be
defined,  as  follows:

•     Phase I (lasts a few hours to 1  week)  - this phase is aerobic in which oxygen in the landfill is
       depleted, the  temperature  of the waste mass increases due to biological activity, and C02 levels
       are  high initially

•     Phase II (lasts 1 to 6 months) - this phase is a transition from aerobic to anaerobic conditions
       with most of the oxygen being  depleted, nitrogen beginning to be displaced, cellulose begin-
       ning to be broken down,  methane gas beginning to  form, and C02 levels declining

•      Phase III  (lasts 3 months to 3 years) - this  phase involves anaerobic conditions within the
        landfill  and is a growth period for bacterial formation of methane (via methanogenesis)

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 •      Phase IV (lasts 8 to 40 or more years) - this phase is an ongoing period of gas generation with landfill
        gases consisting of 50 to 60 percent methane

 •      Phase V - this phase is marked by the decline in methane generation.

 Bioreactor landfills can involve aerobic or anaerobic conditions.  Waste mass temperature may be 130
 to 150°F or more under aerobic conditions with the moisture content above field capacity. Anaerobic conditions
 can involve lower temperatures. In both cases, drier areas within the waste mass tend to have the lowest tempera-
 tures.

 Aerobic bioreactor landfills attempt  to sustain the Phase  I activity over a longer period of time than is
 experienced in  a conventional municipal solid waste landfill. Anaerobic bioreactor landfills attempt to
 significantly  reduce the time involved for Phase IV activities - to possibly 5 to 10 years (a 75 percent
 reduction), with 5 to 7 years  for Phase IV  considered optimum.

 Gas generation  may vary depending  on the  moisture and oxygen conditions within the landfill and the
 effects  of moisture and oxygen conditions  on waste mass  decomposition.

 Presenter information also suggest that  data in the United States and the United Kingdom indicate that hazardous
 air pollutants (HAPs) may enter the landfill gas stream very early in the bioreactor process. This may be true for
 volatile organic compounds (VOCs) as well. One hypothesis for this is the difference in operating temperatures
 between a conventional municipal solid waste landfill (70 to 80°F)  and a bioreactor landfill (150 to 160°F).

Additional discussion proposed that liquid in the form  of moisture within the waste mass  may be  a key
factor in sustaining the bioreactor  operation. Some bioreactor landfills may  operate in a moisture
 deficit with moisture being consumed in waste mass  decomposition and  also being removed through
air emissions, gas collection/removal, and leachate collection/removal. Therefore,  it may be necessary
to add water, wastewater, leachate, or other liquids to replace the water loss and to sustain the bioreactor
activity.  Key to  effective liquids movement and distribution of moisture within the landfill waste mass
is a system for liquid introduction to the waste mass,  open  liquid flow within the waste mass,  and the
leachate collection and removal system.



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In addition to gas generation, decomposition of the landfill waste mass and associated volume loss results in the
Mowing additional bioreactor landfill attributes:
•       Biological generation of humus-like material that acts like a trickling filter to remove some salts and
        metals as leachate or other liquids pass through

•       Partial to  complete biological reduction of the organic constituents in the leachate

•       Decreases in BOD

•       Potential increases in  fatty acid production that cause the  pH to rise and reduce the metal-
        carrying capacity  in the leachate

•       Increased effective density of the waste mass

•       Significant settlement of the waste mass.

Workshop participants also observed that bioreactor landfills undergo more waste mass settlement in
their lifetimes than is  seen  in conventional municipal solid waste landfills. Some participants maintain
that when the low permeability final  cover is applied, both gas generation and the moisture content of
the waste mass drop  dramatically, which significantly affects continued bioreactor function and gas
flow to  any co-located beneficial gas  reuse projects (e.g., energy recovery). Thus, key areas of concern
in full-scale  bioreactor landfill operation involve  the type and timing of final low permeability cover
placement, as well as the use  of alternative temporary covers supporting continued  bioreactor opera-
tions pending installation of the final cover.

The increase in the effective waste mass density and the significant amount of waste mass settlement
combine to reduce the volume of material in the landfill. The airspace "recovered" as a result of such
settlement has economic  value and can extend the useful life of the landfill.
In summary,  the workshop discussions indicated that anaerobic bioreactor landfills result in the follow-
ing,  as compared to conventional municipal solid waste landfills:
•      Nearer term stabilization of the waste mass within 5 to 10 years of initiating bioreactor operations

•      More complete stabilization of leachate within 3 to 5 years
•      Rapid settlement

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•       Earlier gas generation

•       Increased gas flow and yield (total and per unit basis)

•       Minimized future environmental liability related to gas, settlement, and leachate after achieving
        a stabilized waste mass through completion of the decomposition process.

Aerobic bioreactors have the same benefits as anaerobic bioreactors,  only these benefits seem to be
achieved more quickly. Since aerobic bioreactors  do  not produce such significant quantities of meth-
ane, there is no potential to sell methane for  energy.

Some cautions about bioreactor landfills were also noted by participants, specifically:

•       There may be increased potential for fires, explosions, and stability issues.

•       A wet landfill or leachate recirculation does not necessarily mean the landfill is a bioreactor.

•       Some bioreactor benefits (such as waste  mass/volume  reduction) attributable  to microbial
        decomposition may be attributable to settlement/compression  from the addition of liquid.

•       Even after the majority of the waste mass is digested, there can still be significant quantities of
        material that can be reduced further over time and the potential exists for continued generation
        of gases and transport to groundwater.

•       Landfill gas emissions may increase if sites are not well controlled soon after liquids addition.

Some Workshop participants  speculated that all landfill sites may eventually return to aerobic condi-
tions, but others believed that this might not occur for  very long periods of time (several hundred years
or more).  However, if such landfills are reopened at a future date to mine the waste or degraded waste
material, aerobic conditions may be introduced and this  should  be factored into conceptualization of
such operations.

Some websites of interest for more information on bioreactor landfills include the following:

•       www.bioreactor.org
•       lst.sb.luth.se/bioreactor
•       www4.ncsu.edu/~barlaz/.
  _ -•*,; <	•:F. . •	- :> _ " >•»»
  CHAPTER: THREE

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3.2    BIOREACTOR PROCESS

Microbial activity is the primary process operating in bioreactor landfills and the addition of water
helps the microbial system to work more efficiently. However, some bioreactor benefits  attributable to
microbes may in fact be attributable  to settlement from liquid addition.
By understanding the following aspects, bioreactor landfill performance can be influenced as with
other microbial-based systems:
•       Microbial population dynamics in bioreactor landfills
•       Microbe distribution and microbial activity  distribution
•       Microbial population and activity responses  to site-specific parameters such as:
        -    redox potential
        -    pH
        -    soluble nutrients
        -    abundance of water.
To date, there is only very general knowledge of the activities and roles of the microbial populations
within landfills.   There are currently few culturing techniques and few modern molecular techniques
applicable to this situation.

The microbe-based decomposition of wastes in the landfill provides many of the end results discussed
in Section 3.1 and throughout this document, specifically gas generation, decomposition of organics, and nitrogen
cycling.

There are a number of ways to examine gas generation in a bioreactor landfill.  Gas production may be
correlated with waste type  (food, vegetation, paper, other), measured by production rate (rapid, mod-
erate, slow), monitored with respect to landfill age or characterized by methane content.  Numerous
gas generation curves have been developed for  all of these factors, and they all demonstrate that the
methane generation rate in bioreactor landfills can be substantially higher than in conventional munici-
pal solid waste landfills.

Studies have been performed regarding the makeup  of municipal landfill solid  waste and the contribu-
tion each type of waste makes to gas generation.   Municipal solid waste generally consists of food,
vegetation, paper, wood, plastic, rubber, and textiles. Overall, vegetation, food, and paper matter have
a greater and more immediate impact on methane generation  and leachate strength than plastics and
other more inert materials.

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Lignln, however, is resistant to breakdown in anaerobic landfill environments and may be similarly resistant under
aerobic conditions as well. Previous research has demonstrated that the loss of cellulose/hemicellulose changes
(decreases) the ratio of cellulose to lignin over time in the landfill. Soil used for daily cover does not seem to affect
these results.

The following sections present additional discussion of the factors affecting the bioreaction process
(Section 3.2.1), the behavior of metals in the bioreactor landfill (Section 3.2.2), and potential methods
or criteria for determining completion of the bioreactor process (Section 3.2.3).

3.2.1 FACTORS AFFECTING THE BIOREACTOR PROCESS
The experience of some Workshop participants was  that waste materials in plastic garbage bags did not
break  down  (i.e., dry anaerobic conditions existed  in the plastic bag even if wet bioreactor conditions
existed in the rest of the waste mass).  Other participants had found that plastic garbage bags  degraded
under bioreactor landfill conditions of at least 122 °F for 18 months.  Still others suggested that either breaking
open plastic bags to expose the contents (by equipment or during emplacement) or use of degradable bags may be
necessary for optimum bioreactor performance.  Another view was that most plastic bags are ripped or broken.

There  are  also a number of considerations regarding degradation potential for different redox condi-
tions (aerobic, anaerobic,  microaerophilic/facultative/nitrifying)  encountered in bioreactor landfill sys-
tems, including the following:
•       Relationship of waste composition to the choice of bioreactor redox conditions

•       Impacts of waste segregation or pre-processing on bioreactor performance (i.e., enhanced gas
        generation/waste decomposition from waste shredding)

•       Changes of process dynamics from introducing new waste into a partially  or fully decomposed
        waste mass.
Moisture content is a factor affecting the bioreaction process as noted in Section 3.1.  Participants
noted that reactor  performance can decline as dry conditions develop within the waste mass.  How-
ever, oversaturation of the waste mass may achieve negative results; a wet landfill does not necessarily
mean the landfill is a bioreactor.
Additional discussion indicated that bacterial decomposition of the waste may result in a layer of mimic material

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forming at the bottom of the landfill (and possibly in other areas as well) that resembles a trickling filter in its
behavior. The permeability of this layer can affect the movement of liquids throughout the landfill and the ability
of leachate to move through this layer to the leachate collection system at the bottom of the landfill.  Better
understanding of this layer, its attributes, its permeability, and how these change over time is necessary to identify
and mitigate any potential impacts.
3.2.2 METALS
Several Workshop discussions considered the long-term fate of metals in bioreactor systems and im-
pacts of changes in redox/pH conditions in the landfill after stabilization and closure (e.g., potential
for remobilization). Workshop participants speculated that since heavy metals may concentrate during
wastewater biosolids treatment, similar effects could be anticipated in bioreactor landfills during waste
decomposition, and such changes in heavy metal concentrations should be seen in the leachate quality.
Workshop participants also noted the  challenges in addressing  the presence and behavior of metals in
the landfill  environment, including:

•       Microbes may concentrate metals

•       pH and sulfides in the landfill may affect mobilization

•       Filtration of water samples  (leachate, groundwater, etc.)  prior to analysis can remove metals
        entrained in the solids thereby affecting the interpretation of analytical results regarding the
        presence or absence  of "metals

•       Potential for remobilization of metals if landfill conditions become aerobic (e.g., oxidized
        humic acids,  additional C02 that lowers the pH).

Research conducted  at Georgia Tech and elsewhere indicates that while there  is some potential for
mobilization, there are multiple mechanisms for attenuation  of  all metals and therefore the metals
generally precipitate in the waste mass. In addition, a  review of data from 12 landfills indicated that
heavy metals are not an issue  for a fully stabilized anaerobic landfill.  In pH conditions of 7 to 9, as are
typically encountered in these landfills, the metals are immobilized. While metals are present in the
landfill leachate, all of the values are below drinking water standards.

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EPA participants at the Workshop requested information on mercury in landfills - its presence, quan-
tities involved,  potential for emissions, and any technologies to address mercury treatment/control.
Superfund sites were noted to  have mercury problems, but representatives from the solid waste indus-
try noted their belief that modern Subtitle D landfills do not seem to have problems with mercury
contamination.  Ongoing research in Florida has conducted measurements of  mercury emissions at a
few landfills and these measurements seem to conflict with other  reports that had suggested that
mercury emissions were not an issue.  However the fate of mercury in septic sewage sludge and other
landfill materials has not been established.
3.2.3  COMPLETION OF THE BIOREACTOR PROCESS
An important issue in any reaction process is how to determine when the reaction is completed.  For
bioreactor landfills, Workshop participants indicated that this equates to defining when the waste mass
is stabilized.

The decomposition process for organic matter produces methane and C02 under anaerobic condi-
tions and produces C02 under aerobic conditions. Data exist for gas yield per kilogram of cellulose/
hemicellulose.  Therefore, gas generation may be a method of determining stabilization of the waste
mass. However, a concern expressed by many Workshop participants is the potential to continue  gen-
erating methane gas after stabilization is accomplished.

Many questions were raised and discussed during the Workshop regarding how to  define waste stabili-
zation and  the difficulties of selecting an appropriate endpoint.  Examples include:
•       Is partial or full treatment desirable, i.e., achieving an optimal decrease or an absolute decrease
        in gas generation?
•       Is gas generation really a surrogate to measure organic decomposition? Or  to assess how much
        material is left to decompose?
•       Is the landfill stabilized when monitoring shows no more than a specified level, e.g., X cubic
        feet per  minute (cfm), of gas is being generated?
•       Is the drop-off in methane production in an anaerobic bioreactor a good measure of stability?
•       Since methane is not likely to go to zero at any time,  is another measure or some other value
        more appropriate?
•       Is the drop-off in CO  production in an aerobic bioreactor a good measure of stability?

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•      Are there other/better indicators of waste mass stability than gas parameters, such as geochemical
       stability of leachate?

•      Can  leachate from different landfill areas be used to determine solids degradation or comple-
       tion of the waste mass stabilization process since leachate is typically collected from the base
       of the landfill where the greatest decomposition can be expected?

•      Can  changes in characteristics of solids provide a better, although more difficult to obtain,
       method to determine stability?

Research is still ongoing to determine  when  data show stabilization of the waste mass. Workshop
participants also uniformly agreed that  it is critical  to set performance goals  because these in turn
establish operational guidelines.
3.3   BIOREACTOR  LANDFILL SYSTEMS
This section addresses Workshop discussions pertaining to systems  for containing,  managing, and
promoting the bioreaction and its byproducts as well as design considerations specific to bioreactor
landfills.  Section 3-3.1  reviews issues raised  pertaining to liners for  landfill  bioreactors and their
performance.  Section 3.3.2 addresses leachate collection and internal drainage systems to sustain the
bioreaction and manage the liquids from the landfill.   Section 3.3.3  focuses on  gas  collection and
management systems. Section 3-3-4 summarizes issues raised pertaining to  the  physical stability of
the landfill and waste mass  as compared to conventional municipal solid waste  landfills.  Section
3.3.5 considers temporary and final cover requirements for bioreactor landfills.

3.3.1 LINERS
Landfill liner research to date indicates that landfill liners work well.  One study noted by participants
addressed the performance of various liners at 91 landfills considering  both sand layers and geonet
layers for the leak detection system.   This study found that the leakage rate was 4 gallons/acre/day,
which dropped to 1 gallon/acre/day after closure.
Some Workshop participants suggested that the regulations allow flexibility for  use  of single compos-
ite liners, mixed composite liners, and  double liner systems with an interliner detection system.   In
addition, EPA representatives indicated  that alternative liners'are being seriously  considered in the
current regulatory development process.  Workshop participants expressed interest in pursuing perfor-
mance standards rather than prescriptive criteria such as the  composite liner  specification currently
found in the RCRA landfill  regulations.
                                                                                 V *. >•*--,

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3.3.2 LEACHATE COLLECTION AND INTERNAL DRAINAGE SYSTEMS
Leachate collection systems for bioreactor landfills serve to collect, remove, and manage leachate gen-
erated in the landfill, but must also support the management of any liquids added to sustain or pro-
mote the bioreaction. Some practitioners believe that it is necessary to increase the size of the leachate
collection and removal system to support recirculation.  However, the Workshop presentations indi-
cate that bioreactors frequently operate with a moisture  deficit, which raises design questions  regarding
the sizing of these systems.

Many Workshop participants indicated that there will always  be some leachate generated in a landfill.
Others indicated that bioreactor landfills will  generate little leachate  at the conclusion  of their opera-
tion.
A number of Workshop participants recommended that the leachate collection system design for wet
bioreactor landfills should be flexible. Some considered the 0.01 cm/sec leachate collection system
design requirement specified in the regulations to  be too low for  good liquid discharge.  Different
opinions were expressed as to the appropriate size of the stones for the drainage collection layer (e.g.,
AASHTO  #3, 1.5 inches,  2 inches).  Design recommendations and considerations included the following:
•      Use a perforated pipe network within a  stone layer

•      Stone is preferable to sand, which can promote clogging of the collection pipes

•      Avoid wrapping geotextile fabrics around collection pipes to prevent fouling

•      More organic material can be expected to  move through the landfill and into the  drainage
       system at the early bioreaction stages when  the pore space is much  higher in the waste mass
       than at later stages, resulting in  a much higher potential for plugging the drainage system earlier
       in the process.

Leachate collection and removal systems generally involve a pipe network that is difficult to design  and
maintain  because of its location above the landfill liner.  Repair, removal, or replacement of these pipes
can be very expensive once waste is emplaced in the landfill cell.

Internal moisture distribution is another important aspect of bioreactor design.   Building such systems
within the waste mass may improve moisture distribution over that achieved  by trickling liquids down
   RAFTER,	

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through the waste from the top of the waste mass.  This may also help to avoid mounding and the problems
associated with preferential pathways or blockages developing around denser material.

Questions were raised about the potential impacts of high internal bioreactor landfill temperatures on
leachate temperatures.  Experience presented by the Workshop participants indicated that the leachate
temperature does not seem  to change from that found in  conventional landfills because of the cooling
action  of the earth and the insulation provided by the depth of the waste  (i.e., the distance between the
high temperatures within the waste  mass and the leachate collection system at the bottom of the
landfill).

3.3.3 GAS COLLECTION AND  MANAGEMENT
Gas collection and management systems for bioreactor landfills need to be installed earlier and de-
signed for larger flow than  for conventional municipal solid waste landfills because landfill gas forms
earlier and in greater quantities. Workshop discussions indicated that bioreactors can be designed and
operated to:
•       Maximize landfill gas collection and control
•       Minimize occasional landfill fires or appropriate actions are  taken should a fire occur.

Issues identified by Workshop participants pertaining to the collection and control of gas generated
from bioreactor landfills include the  following:
•       What is  an adequate level  of  gas collection  and control?

•       What contingency plans and procedures are needed to  respond to failures and fires in landfill
        gas  collection/control systems?

<»       When will updated models and model  input default values be available that reflect bioreactor
        landfill operations in order to estimate the  life-cycle environmental burdens?

A common misconception is that landfill gas collection is not  necessary for aerobic landfills because
they do not generate  methane.  However, these types of landfills also generate significant quantities of
other gases  that may  also require  control.
  '^^^K^^f^mm^m &••- ^.w*i!

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3.3.4 PHYSICAL STABILITY OF THE LANDFILL AND WASTE MASS
Physical stability of the landfill and waste mass involve the following considerations:
        Density changes and settlement of the waste mass from compaction and decomposition
        Impacts of liquid addition and recirculation
        Shear strength of the waste.
These stability considerations, their impacts,  and design considerations are discussed further in the
following sections.
3.3.4.1
WASTE MASS DENSITY AND SETTLEMENT
Settlement of the waste mass in a bioreactor landfill can be significant over time — easily involving 10
to 25 percent of the landfill height.  Settlement will also be differential rather than  consistent across the
landfill surface.  Gas collection and other internal landfill cell systems (such as leachate collection/
recirculation) must be able to move with this settlement.

When water is added to paper (a significant component of municipal solid waste)  and the wet paper is
put under pressure  (as would be seen in landfill waste emplacement), the wet paper consolidates. Thus,
the 10 percent settlement seen in the  early stages of bioreactor landfill operations  may in fact be more
the result of water  addition than microbial degradation.

A wet landfill can produce a 50 percent increase in the total unit weight of the waste and the  unit
weights increase with height .(for example, doubles in the first 150 feet).   Addition of water or other
liquids to the waste mass to promote the  bioreaction will add additional weight.  Such changes in waste
density may affect seismic  and  other  stability design requirements.  For  example,  increased density of
the waste through the decomposition process and settlement may result in the waste mass becoming
more unstable with steeper slopes,  thereby reducing the  designed safety factor.
3.3.4.2
IMPACTS OF LIQUID ADDITION AND RECIRCULATION
Another major landfill stability concern is leachate (hydraulic head) buildup on the landfill liner system.
Ponding of liquid on the liner can be a significant source of failure as a result of the associated hydro-
static forces.  Addressing  this in  design should be a straightforward issue for bioreactor landfills be-
cause liquid levels, shear strengths,  and other parameters are generally known.
  _.--!!!!!. S . ₯!!=,« WtflH»Ji
  CHAPTER THREE

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However, some of the biggest questions facing designers of bioreactor landfills include the following:
•       How do changes in the waste mass, hydraulic head, and pore water pressure (resulting from
        recirculation  and liquid addition) affect the design parameters?

•       How do these changes affect physical stability factors?

•       What safety factors,  based on the above changes, need  to be addressed in design and operation
        to prevent landfill failure?

•       How will placement of new waste on top of a stabilized waste mass (i.e., reuse of the "recov-
        ered" landfill space) affect landfill  stability?

One critical area is controlling the hydraulic head/pore water.  Pore water pressures  remain high in
bioreactor landfills for a long period of time, while they decrease in  conventional landfills after place-
ment of the final cover.

Of additional note, recirculation of liquid  can affect the stability  of the perimeter  berm in heavy
rainfall or hurricane  conditions in landfills  with steep liner slopes.
3.3.4.3
WASTE MASS SHEAR STRENGTH
A dry waste mass  can be tremendously strong as evidenced by stable modern landfills with waste
heights of up to 300 feet and slopes steeper than 3:1.  However,  the addition of water adds weight but
no shear strength, which affects traditional landfill design factors  such as the waste mass geometry (for
stability). Some geometries used for dry landfills may not work with wet or bioreactor landfills because
of differences in the shear strength of the waste and elastic displacement  caused by water addition.

Some data exist on the shear strength of "new waste", but there do not appear to be any data regarding
the shear strength  of "old waste" such  as might be found  in a bioreactor  landfill after stabilization of
the waste mass is achieved.   One Workshop participant noted that there appears to be some data that
indicate that "old" wet waste may have the same shear strength as new waste.

Testing shear strength to obtain the necessary data for nonhomogenous waste  streams such  as municipal
solid waste can be difficult. To test shear strength, material samples are needed that are five times bigger than
the particle  size.  For municipal solid waste, particle size can  be a telephone book, refrigerator, etc.

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 Liquid addition and waste shredding prior to emplacement both affect the shear strength of the waste,
 and can change the waste mass behavior from that experienced with conventional landfills.  This  raises
 the question as to whether the decomposed and settled waste mass in a bioreactor landfill will be
 sufficiently stable  to allow new waste to be placed on top.
 3.3.4.4       DESIGN CONSIDERATIONS FOR LANDFILL AND WASTE MASS STABILITY
 Factors affecting waste mass stability and their effects include:
 •      Leachate/liquid mounding has  a negative impact
 •      Increased unit weight/density has a negative impact
 •      Decreasing slopes over time has a positive impact
 •      Changes in waste shear strength have an unknown impact
 •      Changes in waste compressibility have an unknown impact.

 Stability concerns were generally not expressed regarding the first waste placement and Workshop
 participants had not encountered any stability problems with a wet landfill or bioreactor landfill.  The
 stability concerns raised in the Workshop generally focused on reuse of the landfill cell to place new,
 unreacted  waste on top of old, decomposed waste.

 One suggested approach was to use a "stabilize as you go" concept. This would involve stabilization
 of the lower parts of the  landfill as waste is emplaced because it is too difficult to go back into  the
 waste mass later to make  adjustments.

 Overall, Workshop participants  recommended following good geotechnical engineering principles when
 designing a landfill for stability,  similar to those followed in building a dam.  Good input data are key to
 good design.

 3.3.5 TEMPORARY AND FINAL COVERS
As noted in Section  3.3.4.1, bioreactor landfills undergo  significantly more waste mass settlement in
their lifetimes than conventional municipal solid waste landfills.  Thus, the type and timing of the final
landfill cover and the potential  need for alternative temporary covers, pending installation of the final
cover,  are key factors in successful bioreactor operation.  Decisions regarding the type and timing of
landfill covers are important because state regulatory agencies have seen a number of final cover
failures in conventional landfill situations as a result of significant or differential settlement.

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Workshop participants generally agreed that it is necessary to seek flexibility in the regulations regard-
ing the timing of final cover placement so that landfill operators can continue to manipulate the waste
mass.  Once a synthetic or other final cover is installed, it is  too expensive to remove and reinstall it.  As
an example,  a number of Workshop participants proposed the use of higher permeability temporary
covers (so-called alternative covers) for filled landfill cells  until the bioreaction process is completed.
Only at that time was it considered appropriate to install a final, low-permeability cover.  A common
argument in  support of this approach is the fact that low-permeability covers will change the internal
landfill conditions, possibly affecting the bioreaction process.  Another argument in support of this
approach is that bioreactor landfills operate at elevated temperatures (such as 160°F), and current low-permeabil-
ity liner materials cannot withstand prolonged exposure to such temperatures without degradation of their perfor-
mance.

Another strong recommendation was to defer final cover placement  until after primary settlement of
the waste mass has  occurred  (5 or more years after bioreaction is initiated).   The overall goal in this
time period  is to allow liquid to enter the  waste mass to  achieve decomposition and to manage the
landfill gas generated from this decomposition.  Only after waste mass stabilization and settlement are
achieved did Workshop participants feel it was appropriate to conduct final compaction and place the
final cover.

One suggestion for alternative final cover design involves the placement of shredded tires at the top of
the waste mass; this layer  is in turn covered by a geotextile with the  top layer consisting of clay.  This
creates a zone underneath  the final cover for  continued  gas collection and removal.

Other factors to consider with regard to alternate, temporary, and final  covers for bioreactor landfills
raised in Workshop  participant discussions  include  the following:
 •      What type of temporary covers can be installed that will withstand the massive  total and differ-
        ential settlement that will occur in a bioreactor landfill?

 •      What type of cover can keep  the gas confined for proper management and extraction yet allow
        rainwater to penetrate?

 •      What is the potential for differential settling when  using biosolids as coyer material?

 •      How do cover requirements vary depending on the landfill type (e.g., dry tomb vs. bioreactor

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        vs. landfill types in between the two) and how do regulations need to consider the range of landfills that
        may be encountered?

 The Sandtown,  Delaware landfill project examined the impacts of a simulated cover failure on a dry
 landfill cell (see case studies provided in  Appendix C).  The chemical oxygen demand (COD) in the
 leachate for this landfill cell had decreased.  The experiment involved opening up an area of the landfill
 cover and adding several thousand gallons of water over a few weeks.  The leachate was monitored
 during and after the water addition. Results indicated that the added liquid took about 45 days to reach
 the leachate collection system and the liquid addition caused the COD to increase to  30,000 mg/L.
 This research experience appeared to indicate that if there is a breach of the cover, liquid addition  may
 re-initiate the bioreaction.

 3.4    OPERATIONS
 This section summarizes Workshop discussions pertaining to bioreactor landfill operations and changes
 they may have on traditional municipal solid waste landfill practices.  Section 3.4.1 discusses the mois-
 ture requirements of bioreactor landfills, moisture sources, and methods for liquid introduction.  Sec-
 tion 3.4.2 reviews the waste compaction and potential waste preprocessing needs of bioreactor land-
 fills.  Section 3.4.3 addresses potential variations for daily cover requirements. Section 3.4.4 summa-
 rizes fire hazard concerns and potential mitigation  measures.  Section 3.4.5 addresses the control of
 mud on vehicles.  Section  3.4.6 reviews Workshop discussions on nitrification and odor control.  Sec-
 tion 3.4.7 presents training suggestions provided by Workshop participants.

 3.4.1  LIQUIDS ADDITION
 The moisture content  of wastes is critical for bioreactor operation; the addition of significant quanti-
 ties of liquid may be  required.  Some estimates presented at the Workshop indicated that about 13
 million gallons  of liquid might be needed for 400,000 tons of waste; others estimated this requirement
 as 54 gallons of water per cubic yard of waste.  Landfills in states with dry conditions will need even
 larger liquid quantities. Also,  more liquid may be needed to sustain bioreactions after a low permeabil-
 ity cover or cap  is installed because the landfill moisture may. be removed via the gas  collection system.

Thus,  the leachate generated in the landfill may not be  sufficient to support the bioreaction moisture
needs,  and additional  liquid sources may be necessary.   Factors raised by Workshop participants  for
         a^«|«iT


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consideration in addressing liquid addition to bioreactor landfills include the following:
•      Whether and how to differentiate between the amounts of liquids needed by different types
       and sizes of landfills
•      Use of temperature as a parameter to monitor or to  control liquid injection since good wetting
       of the waste mass seems to result in the most uniform temperature
•      Timing of liquid addition, e.g., at time of waste emplacement or emplace dry waste first and
       add liquid later
•      Determination of  the desired moisture content and the amount of liquid required is necessary
       to support design of a distribution system  to achieve this.

Workshop participants noted that the moisture needs  of a bioreactor landfill will depend on site con-
ditions and will change as stabilization of the waste mass  proceeds.

The timing of liquids addition was also discussed.  Some projects such as the Worcester County Land-
fill in Maryland (see case studies in Appendix C) began recirculating leachate once the first lift of waste was
emplaced and continued throughout the Me of the landfill.  Other options were more of a retrofit in nature with
recirculation systems added after the landfill cell was filled with waste.

The following sections summarize discussions on alternative liquid sources and techniques for mois-
ture addition.
3.4.1.1
ALTERNATIVE LIQUID SOURCES
Workshop participants explored alternatives to landfill leachate for liquid addition, including wastewa-
ter, biosludges, and biosolids from POTWs.  Stormwater runoff and groundwater were other liquid
sources suggested by Workshop  participants.

Biosolids  considered most suitable for bioreactor use are those in liquid form that typically undergo
land application rather than the  dewatered sludge.  Use of this material  could avoid dewatering costs,
but would involve more trucks to transport  the larger volume of the dilute wastewater.
Concerns were expressed regarding the operational health and safety issues raised by this material and
this practice.  Of particular interest was potential worker exposure to pathogens, risks to workers and
nearby residential areas from aerosols resulting from biosolids application to the landfill surface, and
risks  present after digestion of the biosolids in  the landfill.  Many participants believe that there would

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be little risk associated with this practice because  (1) there have been a number of studies conducted at
wastewater plants indicating that worker safety is not compromised by exposure to this material; (2)
large landfills servicing big urban  areas typically take sewage sludge (hundreds of tons per day)  and mix
It with general trash, so worker exposure is well known and does not seem to have an impact on worker
health and safety; and (3) RCRA Subtitle D landfills already  receive animal carcasses, medical waste,
and  other pathogen-bearing materials, so the biosolids addition does not pose any new or special risk
beyond that experienced in current practices. Some participants suggested that there may not be a
pathogen problem in the leachate because the biosolid material will undergo pasteurization  as it moves
vertically down through the bioreactor landfill waste mass, which is at elevated temperature.

Questions were raised about the best choices in liquids,  based on their composition, to augment the
liquids already present in the landfill.  Of particular note were potential impacts on leachate quality
from the application of high BOD wastewater or  biosludge to a  bioreactor  landfill.  The following
issues were raised:
•      Will such wastewater increase the protein content and thereby increase ammonia  generation,
       which is already a concern?

•      Will heavy metals from sludges result in  accumulation that may be a longer-term problem?

•      Will there be compatibility issues between the wastewater and the landfilled waste or with
       changes to landfill internal conditions from waste addition?  For example, will the  addition of
       high  BOD wastewater lower  the pH of the landfill  within a very short period of time and
       create areas of acidic conditions?

•      Is there a potential need for additives to the wastewater in order to have it work in  the desired
       manner?
A Workshop participant cited a research study conducted by EPA that examined the impacts of adding
different amounts of biosolids to garbage, and evaluated impacts  on leachate and methane generation.
This study spiked the biosolids with heavy metals, which appeared to result in  better  quality leachate.

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3.4.1.2
TECHNIQUES FOR MOISTURE ADDITION
Designs and practices for liquid addition to the waste mass cited by Workshop participants include the
following:
•       Slug injection of liquid followed by continued liquid addition in significant amounts until satu-
        ration occurs

•       A high" initial injection rate to saturate the waste mass followed by continued introduction of
        liquid at a much reduced rate
•       Wetting the waste surface during waste emplacement
•       Pooling the liquid on the top of the landfill
•       Liquid infiltration trenches
•       Nested vertical injection wells to provide liquid to multiple landfill layers at each location
•       Pulsed vertical injection.

Some Workshop participants indicated that wetting the waste surface may initiate the bioreaction  pro-
cess,  but optimum bioreactor performance is expected to require significantly larger liquid quantities.
Others noted  that surface application of liquid may be a key factor in the active  bioreaction phase.
However,  the experience of state representatives with such practices raised concerns about vectors and
odors.  A risk assessment of such a practice may provide useful information, although some Workshop
participants noted that odors can be a significant local community/political issue rather than an actual
risk.  In addition, there may also be worker safety issues to be considered.

Liquid injection can be accomplished through  horizontal or vertical injection.  Benefits  of horizontal
systems are that they are less likely to introduce oxygen into the landfill (a potential fire source).  Hori-
zontal distribution systems were considered by some Workshop participants to  be very expensive and
physically unlikely to survive the waste layering process in a large, active landfill.  Horizontal systems
may have to be abandoned  and new systems installed in upper layers as the height of the waste mass
rises  during active waste emplacement.

In an example of vertical injection,  pulsed  vertical injection wells achieved significant saturation through
overlapping zones of penetration  below 20 feet, but above 20 feet there was  poor saturation. Such
variation  did not necessarily impact the bioreaction results.  This experience suggested that an impor-

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tant focus for liquid addition may be the economics (cost) of liquid injection methods rather than
achieving uniform liquid distribution.

A concern expressed by some Workshop participants regarding the use of vertical injection wells was
the potential for higher decomposition rates in the immediate vicinity of the injection wells to result in
well plugging.  Workshop participants responding to this concern had found somewhat higher decom-
position in the  immediate injection well vicinity, but noted that preferential pathways exist in the waste
mass for injected liquids.

Some aerobic bioreactor programs are looking at closer well spacings. For example, 50  foot well
spacings for liquid injection are common, but it is not clear that this is the optimum spacing.

3.4.2 WASTE  PREPROCESSING
Two forms  of waste preprocessing were discussed: initial waste compaction upon emplacement in the
landfill  and shredding the  waste  prior to placement.  The goal for this preprocessing is to achieve
optimum exposure of waste material to the bioreaction process without creating conditions that pre-
clude or hinder performance.

Some Workshop participants indicated that the method of initial waste compaction appears to  have
little correlation to the waste density ultimately achieved in the bioreactor landfill waste mass.  Others
noted demonstrated experience with the absence of decomposition in bioreactor landfills for waste
inside plastic garbage bags, which may or may not be broken open during conventional compaction
with heavy equipment. Some suggested that either breaking open plastic bags to expose the contents
(by equipment or during emplacement) or use of degradable bags was necessary for optimum bioreactor
performance.

Some Workshop participants questioned the importance of shredding the waste, raising the following
issues:
•      Pore size and capillarity in the waste  mass influence liquid transport and this  can be used to
       operational advantage in lieu of waste shredding

•      Shredding changes  the physical stability of the waste mass, and can impact both waste settle-
       ment and the potential for landfill failure

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•      Differential decomposition may be useful; for example, if only the bottom waste layer decomposes it will
       act as an anaerobic trickling filter for leachate and other liquids from higher layers and this may still be
       progress over no decomposition at all

•      Shredding to achieve uniformity in the waste mass will help to drive the bioreactor process to
       completeness, but may not be  economically feasible.

Workshop participants noted that there are some patents for shredding waste to obtain  a more uni-
form particle size to enhance bioreaction performance.   Participants also noted that some pretreat-
ment of lignin in the waste may be necessary so it will decompose  more readily.

An example of the compaction and shredding issues  involves a landfill in  central Florida that shreds
waste in a tub grinder prior to waste  emplacement.  With waste material  in this shredded form, the
dozers only need to cross the landfill twice to achieve the  desired  compaction in the active landfill cell.
The shredding costs approximately $7 per ton; however, the improved  compaction achieved with
shredded material may decrease the ability of liquids to penetrate the waste mass. Other Workshop
participants noted that a tub grinder is a manual, batch feed process,  and that for larger waste quanti-
ties, a continuous feed machine that breaks open garbage bags and shreds the waste material may be
faster and more cost-effective.

In addition, data from the United States and the United Kingdom indicate that pre-composting waste
prior  to  disposal may significantly increase emissions of HAPs and VOCs.  One hypothesis  for this is
the difference in operating temperatures between a conventional municipal solid waste landfill (70 to 80°F) and a
bioreactor landfill (150 to  160°F).
These discussions raised the following questions regarding current compaction and waste shredding
activities for bioreactor landfill operation:
•       Is initial compaction necessary?

•       Is shredding economically and technically possible?

•       Should current equipment be replaced with dozers that have shredding tines that break open
        plastic bags and other materials during initial waste emplacement and compaction?

•       Do dry and wet landfills  require different compaction for optimum performance?

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•       Will shredding or composting provide desirable performance improvements?

Workshop participants believed that the shredding and compaction issues ultimately will be deter-
mined either by regulation or by economics.

3.4.3 DAILY COVER
Daily cover materials should be selected to avoid creation of low permeability layers within the landfill
cell.  For example, silt and clay can become barriers to leachate drainage and recirculation, while foams,
slurries, sludges, or reusable tarps  (among other techniques) will provide the benefits of daily cover
without preventing infiltration and drainage.   .

3.4.4 FIRES
Active landfill gas  collection systems are a common source  of fires.   Other fire initiators include drill-
ing and lightning strikes.  Potential fire hazards during drilling are easily controlled through safe work
practices (no smoking around the  drilling hole) and use  of spark preventing equipment. Note that
surface fires are much easier to control and eliminate than underground fires.  Landfill fires also  pose a
hazard because they may generate and emit dioxins and furans.

Fire prevention at composting facilities relies on controlling the waste mass temperature. RCRA Subtitle D landfills
commonly see temperatures of 140 to l60°F up to 190°F. For fire prevention in composting operations, interven-
tion is needed in the 170 to 180°F range.  Some Workshop participants noted that a whole range of indicators
(e.g., carbon sources, oxygen sources, heat) may need to be considered.

Aerobic bioreactor landfills rely on high temperatures as well as the addition of oxygen to sustain the
bioreaction. For such operations, good moisture and oxygen control enable control of the waste mass
temperature and fire potential.  Participants noted that achieving uniform moisture levels at the landfill
cell slopes and perimeter can be critical in that they provide an outside buffer.   Adding  moisture to the
waste mass appears to be a simple,  straightforward fire  hazard prevention method; however, this over-
looks the tremendous moisture variation encountered within a landfill and the difficulties created for
gas removal with too much moisture present.

3.4.5 CONTROL OF MUD ON VEHICLES

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Some Workshop participants anticipated that there would be increased incidence of mud on vehicles and operating
equipment as a.result of increased liquids use in bioreactor landfills.  This situation was anticipated to require
increases in the number and frequency of vehicle wheel wash stations, resulting in increased wastewater volumes
generated over those encountered in conventional operations. Other Workshop participants noted that the impacts
of liquid application at the surface of bioreactor landfills would not differ significantly from conventional landfill
operations at a site with heavy rainfall.

3.4.6  NITRIFICATION AND ODOR  CONTROL
A facultative landfill bioreactor may be useful to control nitrogen cycling and may contribute to the
control  of ammonia — a common odor problem in landfill leachate.  Waste Management, Inc. (WMI),
is conducting studies of such bioreactors.   The described operational technique involves treatment of
ammonia-containing leachate by  nitrification. The nitrate-enriched leachate will then be introduced to
the facultative bioreactor cell, as defined and presented by the speaker, where the nitrate is consumed by facultative
bacteria.  This approach is expected to reduce the buildup of ammonia in the leachate and is also likely to reduce
the production of methane. The research will also assess the nitrogen dynamics in the landfill associated with the
nitrate addition.

Other studies have shown that the addition of nitrate-enhanced liquids will  enhance performance of a
bioreactor landfill.  However, these studies also  demonstrated that this practice also reduced methane
production  to nearly zero,  but methanogenesis returned in about 30  to 45  days. So while temporary
reductions may be seen, the process does not seem to be entirely shut down.

There are laboratory studies currently underway to examine  the ability of different materials to remove
ammonia from leachate.  Materials being tested include wood chips, stable refuse, chipped rubber, and
plastic trickling filter media.  Results to date indicate that  wood chips and stable refuse offer better
ammonia removal than rubber or plastic.

3.4.7  TRAINING
Bioreactor  landfills are a different mode of landfill operation than previously experienced by  solid
waste industry practitioners.  Workshop  participants anticipated that difficulties might be encountered
in changing  work habits to conduct  the necessary operating practices for  proper  bioreactor
performance, and noted that this needs to be considered whenever such changes are contemplated.

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There were also a number of suggestions to add certification and training requirements for landfill operators with
responsibility for gas collection systems or other active-type landfill operations as is done for wastewater treatment
plant operators to help address risks/hazards of these operations.
3.5   MONITORING
Monitoring, in this discussion, includes the acquisition of information on landfill liner performance to assess the
potential for failure, acquisition of information to determine compliance with applicable standards for emissions
or other releases, and the acquisition of information to assess the status of waste mass decomposition. Current
demonstration projects typically involve significant amounts of instrumentation to assess leak detection, hydraulic
head, emissions, and other factors of interest. Such monitoring systems may not prove cost-effective in full-scale
application. In addition, such approaches may require supervisory control and data acquisition (SCADA) systems
to maintain the instrumentation, and to collect and manage the data.

Leak detection can involve detection systems placed between liners in a  double liner system to assess
performance of the upper liner (Section 3-5.1) or groundwater monitoring in the vicinity of the landfill
to detect  releases  (Section 3.5.2).  Section 3-5-3 addresses air  and gas monitoring, and Section 3.5.4
summarizes solids monitoring.

3.5.1  LEAK DETECTION SYSTEMS
Monitoring the leak detection zone is useful in determining landfill conditions  and whether the upper
liner is leaking.  Experience to date indicates that there will be an increase of flow in the leak detection
zone between the upper and lower liners if a problem develops in  the landfill or with the upper liner.
Specific suggestions regarding leak detection system design and operation include the  following:
•       Use of sensor-based approaches such as electrical conductivity or pressure measurement with
        sensors installed at the same time as the liner.

•       Include design flexibility in the regulations since legal and financial liability for liner failure rests
        with the design engineers, not the regulatory agencies.

•       Focus on quality assurance during construction and leak detection inspections of the liner after
        construction, since construction is the phase with the highest probability for liner  damage to
        occur. Examples include using an electronic system to look for leaks after seaming or emplacement of a

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       protective cover prior to waste emplacement as that enables repairs to be completed less expensively than
       after waste emplacement.

Workshop participants also noted that increases in leakage between liners can occur from increased
head on the liner, such as may occur as a result of a major rainfall event.  These types of problems have
been adequately addressed in the past by changing landfill operations and cleaning  out the leachate
collection system to reduce the hydraulic head within the landfill.  Such methods must be integrated
into the operational mode of  the landfill to be successful; this is especially true for bioreactor landfills,
where there is an increased potential for fouling  of these systems from increased biomass.
3.5.2 GROUNDWATER MONITORING
EPA has developed a probabilistic method for estimating monitoring point density for containment
system leak detection. Of particular interest is finding leaks through slurry walls that, like landfill liners,
provide a barrier to contaminant releases.  One approach is to look for a signature event such as
pressure head changes across the barrier, which may be applicable  to bioreactor landfills.  Key to this
approach is the ability to quantify the amount of leakage occurring.  This can be  accomplished through
hydraulic head monitoring, water  quality monitoring, geophysical methods, or  groundwater monitor-
ing. All of these methods build on well-established knowledge of fluid flow and measuring the flux
across a plane of water.

Nomographs were developed that scaled the groundwater monitoring grid size and evaluated the prob-
ability for missing a leak, which requires knowledge of the site geology.  With  this information,  it is
possible to estimate the dimensions of the smallest hydraulic signature detectable for a given monitor-
ing point spacing  and a specified  level of confidence, enabling data quality objectives (DQOs) to be
established. However, all of this information needs to be determined before the liner is installed.

Some Workshop participants noted that slurry walls have been overlooked in their  potential applica-
tion to landfill  sites. Slurry walls are much more advanced now, with the ability to combine geomembranes
with low permeability materials to  create very strong containment systems.  However, many issues
have been raised  regarding the ability of slurry walls to provide the containment anticipated.  This can
be  a significant issue for bioreactor landfills where good containment is important.

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Some Workshop participants suggested the use of double liner systems with leak detection between the two liners
.in lieu of groundwater monitoring.  Reasons for this suggestion include:
•       Leak detection systems are more likely to identify a problem before contaminants are released
        into the environment

•       The economics of such a system might be more favorable  than groundwater monitoring.

Other approaches offered by Workshop participants include the following:
•       Consider both an acceptable leachate leakage rate (number of gallons/day/acre) and the ground-
        water flux beneath the site - large groundwater fluxes will offset leakage from the liner if
        specific concentration limits must be met

•       Require groundwater monitoring only after leakage exceeds some trigger level with groundwater monitor-
        ing wells drilled very close to the actual landfill rather than 150 feet away as can currently occur

•       Monitor hydraulic head over the upper liner in double-lined systems in addition to having leak
        detection between the liners; an increase in the hydraulic head will be seen as  an increase of
        liquid in the leak detection system

•       Consider introducing inward gradients to  induce leachate flow back into the secondary system
        as long as the head  differential is appropriately managed.

Workshop participants noted that a leaking liner with significant waste  quantities present  (e.g., 30 to 50
feet of waste on top) generally cannot be fixed, and environmental risks attributable to  any such leak-
age must be evaluated.

Some Workshop participants indicated that groundwater flux  can  be measured, but also noted that
there is a preference to regulate based on a drinking water standard or to use concentration-based
limits for surface water discharge.  Other Workshop participants noted that because groundwater re-
gimes change seasonally and for other reasons, some type of groundwater monitoring  will be neces-
sary regardless of whether a bioreactor landfill has a single or double liner.   In addition,  the presence of
monitoring wells demonstrates that landfill activities are being monitored.
Other Workshop participants proposed that the real goal is to prevent the release of contaminants
rather than to document through monitoring where contaminants went and who was affected.  Many

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felt that monitoring should be conducted for reasons that make sense; otherwise, it involves expenditure of re-
sources for no environmental benefit.

EPA  representatives at the Workshop noted that the RCRA statute requires groundwater monitoring
and that previous litigation has established that the total absence of monitoring will never be an acceptable option.
However, a different type of groundwater monitoring that meets minimum statutory requirements may be an
acceptable option. For example, RCRA Subtitle C regulations  allow hazardous waste tanks to operate without
groundwater monitoring as long as they have double containment systems with leak detection, among other re-
quirements. This precedent opens an opportunity to consider similar changes to groundwater monitoring require-
ments for bioreactor landfills.

Suggestions regarding the conduct of groundwater monitoring include the following:
•       Knowledge  of the site-specific  hydrogeology is important in properly siting a groundwater
        monitoring network.

•       Flexibility is necessary in requiring groundwater monitoring because there are  instances where
        groundwater cannot be found to be  monitored.  While some precedent for this  appears to exist
        in many state programs, actual experience indicates that such waivers are difficult to obtain.

•       Examine  the plume chasing strategies used at Superfund sites to see if these approaches might
        apply  to  the bioreactor landfill situation under RCRA.

•       Consider using BOD and conductivity as initial  monitoring parameters, and if changes are
        detected, VOC monitoring would begin.

Some  Workshop participants felt that  groundwater problems  seemed to largely be  associated with
older  sites  without liners while modern, lined, Subtitle D landfills seem to have little groundwater
contamination problem.

3.5.3 AIR AND GAS  MONITORING
An overall monitoring  goal for landfill gas is to  ensure long- and short-term protection of the environ-
ment.  The  air emissions regulations discussed  in Section 2.3 focus on a surrogate (non-methane or-
ganic  contaminants) that is  representative  or indicative of landfill gas and  the pollutants it contains.


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 Landfill emissions vary diurnally with barometric pressure, seasonally, or by the amount/height of the waste mass.
 Workshop participants suggested that there may need to be a strategy for how to extrapolate from one site to
 another and between different years of operation in order to My understand the air emissions at bioreactor
 landfills.

 Some approaches identified  as potentially useful to landfill emission monitoring include:

 •      Avoid reliance on ambient monitoring because it can be expensive and may not be reliable  for
        measuring emissions.

 •      Apply pressure gradients within the landfill to make the  landfill gas move in the desired manner
        rather than relying on atmospheric pressure at a landfill surface.

 •      Flux measurements rely on concentration measurements (e.g., light detection and ranging [IJDAR] infrared
        absorption) and velocity measurements in the atmosphere (typically using a micrometeorological tech-
        nique).  However, wind velocity can vary significantly across the surface of a landfill and wind speed
        variations cause variations in air pressure, which in turn affect the flux rate.

 •      Mass flux in time and space is the primary parameter of interest so monitoring may ultimately
        involve  measuring concentrations with some as-yet-unidentified technique  and translation of
        the measurements into mass  flux (e.g., quarterly monitoring at spot points  with measurement
        data ultimately converted to flux values).

 •      The permeability of the landfill cover will vary across the areal surface resulting in variable  gas
        releases across the surface.  Such variation  can result in (1) hot spots that can skew monitoring
        results,  and (2) a high probability of  underestimating the flux.

 •      The need  to  address  or distinguish between the  anaerobic and aerobic conditions that will  be
        encountered at the landfill surface and  within the waste mass depending  on the type of bioreactor
        operation.

 •      Methane is only one  of possibly many constituents of landfill gas to be of concern,  therefore
        it is  necessary to identify the specific constituents of interest.

One Workshop  participant recommended that EPA slightly modify the existing rulemaking for land-
fills (drawing on .industry experience in determining what to address) rather than issuing new rules
specific to bioreactor landfills. This was proposed because of the belief that  the solid waste industry
already has some  good experience with landfill gas generation and control, and there is an established
regulatory framework already in place. EPA representatives indicated that this approach is how EPA currently plans
  _	!'W..-.;,!:	  ^_ *	, I, <:] ,
  CHAPTER THREE

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to proceed in the MACT regulation. In general, the MACT rule will refer to the same NSPS requirements used for
conventional landfills, but may require implementing them sooner for bioreactor sites.  For example, beginning
gas monitoring/control soon after leachate recirculation commences may be required in the final MACT regulation.


Workshop participants also identified some newly emerging monitoring methods that may have poten-
tial application to landfill gas emission monitoring, including the following:

•      The Department of Energy (DOE) has developed a camera that operates by remote control
       with 360 degree panning to detect gas and the relative volume generated; this  is one idea to
       collect the necessary data. EPA is interested in evaluating this further with DOE for potential
       application to Superfund and other sites

•      Open-path Fourier Transform InfraRed (FTIR)  spectroscopy has been applied to wastes sites
       for several years. European and Superfund investigators have used a single beam measurement
       with dispersion modeling to estimate the fugitive emissions from these sources.  EPA's Air
       Pollution Prevention and Control Division initially extended the open-path method  to include
       measured vertical gradients to improve resolution of emission estimates.  Recently  segmented
       horizontal baseline measurements have defined the horizontal as well as vertical gradients which
       allows an emission flux to be measured when combined with wind field data.  Fugitive emis-
       sion measurements  are being conducted at a bioreactor site in Kentucky evaluating both the
       vertical and horizontal  plane for helping to measure landfill gas emissions.  Open-path FTIR is
       also routinely used at Superfund sites to  help identify what pollutants are being emitted.

3.5.4 SOLIDS MONITORING

Solids monitoring was  proposed in the Workshop as a possible method for determining the level  of
stabilization of the waste mass (i.e., the  completeness  of the bioreaction).  However, Workshop  par-
ticipants noted that it is possible to have a large quantity of material that is  not in a biodegradable state
within the landfill environment.  One Workshop  participant noted  that the procedures for  analysis  of
cellulose and lignin  could  affect estimates of the degradable waste fraction because these analysis
procedures may render the nondegradable material more available or more responsive than might
actually  be encountered in the landfill.

Measurement  of cellulose and  volatile solids for comparison has  been  proposed as a potential method
to assess waste mass stability and completion  of the bioreaction.  However, the results of some studies
suggest that the ratio of cellulose  to volatile solids can be affected by inert waste streams placed in the
landfill  (e.g.,  sand).  This  consideration led to  proposals to  consider other parameters such  as the


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 cellulose:lignin ratio.

 Workshop participants generally considered solids monitoring to be expensive.  If multiple sampling is
 necessary, then the total cost per waste volume becomes quite expensive for waste with tipping fees
 that are generally inexpensive. Also, the analyses take a significant amount of time,  and increases in
 these  sampling and analysis requirements are speculated to result in additional laboratory capacity
 needs.

 To demonstrate this issue and the complicated nature of the sampling and analysis process, the follow-
 ing example of solids sampling and analysis was  provided:
 •      Auger into  the waste with a 3-foot  bucket auger and remove  in 10-foot increments

 •      Deposit material on plastic placed in an area isolated from the drilling  operations

 •      Continue piling removed material until the 10-foot increment is obtained

 •      Mix the material manually,  then quarter it until a 10- to 20-pound sample is obtained

 •      Place the sample into a bag, package it in a drum or box, then ship it to the laboratory

 •      Obtain  preliminary pH estimates in  the field by putting some of the sample  in water to form a
        slurry, then use a field meter to  measure the pH.

The laboratory then shreds the material (if not already done in the field),  dries the material in ovens
 (takes  about  3 days), mixes the dried material, grinds it in a special mill to a fine powder (takes about 1
hour)  until it resembles pastry flour, then removes  lignin with  acid to obtain a liquid that can be
analyzed by high pressure liquid chromatography (HPLC).

This approach is very labor intensive  and the analysis  can run several hundred dollars per sample if a
laboratory is already set up to do this.  Costs are higher if a laboratory must invest in purchasing the
special equipment  required.  Workshop participants were  not aware of any commercial laboratory
analysis available; one instance was cited in Wisconsin, but all of the  steps up through processing the
material in the special mill had to be performed prior to sending the  sample to the laboratory for  analysis.
Another question raised in these discussions was how much solids monitoring will be needed and how much
monitoring will be enough. One Workshop participant suggested that such sampling and analysis be deferred until
                  g«ggrjBB3;i^K5C5B8^JSjBJBiB|H|


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after settlement has occurred to verify how much biodegradable material is left. Others noted (hat the sampling
process is very destructive and costly, and therefore may not be beneficial.
3.6    PERFORMANCE MEASURES AND PERFORMANCE OPTIMIZATION
The Workshop included a number of discussions of the factors that affect bioreactor landfill perfor-
mance and how  to monitor or control them.  In particular, bioreactor landfills have certain attributes
that distinguish them from conventional municipal solid waste landfills as noted in Sections 3.1 and 3.2.
Such attributes may serve to identify appropriate parameters for optimizing bioreactor landfill performance.

Another approach to optimize performance involves staggered landfill cell sizing and design.  For
example, a cell size could be  20-feet thick and of sufficient dimension for 1 year's worth of waste.  The
next cell is built  while this waste is stabilizing and perhaps a third cell is built after waste is emplaced in
the second cell.  The  next step would be to reuse the space in the first cell generated from waste
decomposition.
The need to achieve optimal performance of bioreactor landfills was also discussed.  Key questions
raised in this discussion include the following:
•      What is the benefit of less than optimum bioreactor performance, since it results in a landfill
       that is a hybrid of both dry tomb and bioreactor landfills?

•      Will post-closure  care be any shorter than for conventional landfills if the waste mass is not
       fully degraded?

•      How are  these decisions influenced by other factors such as a co-located  energy recovery
       project that depends on optimum gas generation to be economically viable?

If optimal bioreactor landfill performance is desirable, then there are a number of operational factors
that can  be or may need  to be manipulated or controlled to assure optimum performance or to aug-
ment  the bioreaction process.  Most Workshop participants considered uniform moisture distribution
within the waste mass  as  the most important factor for optimum bioreactor operation, and also  noted
that this  is not easily achieved. In addition, internal drainage (open drainage) through the waste mass

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 is necessary to achieve uniform moisture  distribution.
 Other factors considered by Workshop participants in optimizing bioreactor landfill performance in-
 clude the following:

 •      What is the ideal compaction goal?  Should it be a goal such as 1,800 to 1,900 pounds per cubic
        yard or less rigorous or none at all?

 •      Does waste preprocessing provide any additional benefits (for example, can it improve lignin
        breakdown, promote gas generation for energy recovery projects, promote  rapid HAP/VOC
        removal from the waste mass)?

 •      Does waste heterogeneity provides any additional benefits?

 •      Can heterogeneity be achieved through  shredding or presorting waste materials?

 •      What is the impact of increased biosolids volume as  a result of biosolids addition or generation
        in the bioreactor because of their low permeability (e.g., creating blockages or preferential flow
        paths within the waste mass when  open flow is better for the bioreaction)?

 •      Are nutrients or other materials needed  to augment  microbial action  (e.g., additional nitrogen,
        phosphate, etc.)?

 •      If there is insufficient liquid, is it better  to apply liquids uniformly or  to stabilize one particular
        portion of the waste mass fully?   The choice will  depend on the desired end goal (energy
        recovery  might work best  by incremental bioreaction  of the waste  mass, while  driving the
        reaction to completion may work best with uniform distribution) .

 •      Can both  anaerobic and  aerobic processes be used together (by injecting air into one area and
        injecting leachate into another, but never into the same area)?

 •      How do moisture needs  depend on site  conditions and how do they change as stabilization of
        the waste mass  proceeds?

Workshop participants also noted that it might be necessary to  develop a methodology for measuring
bioreaction efficiency and to  develop quantitative methods to  measure waste  transformation in the
landfill.

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3.7    CLOSURE AND POST-CLOSURE
Given uncertainties noted previously in achieving uniform decomposition throughout large waste masses,
Workshop participants raised concerns about the potential to continue generating methane gas even after
stabilization of the waste mass is achieved.  Some noted that even small quantities generated over a long time
period might be considered unacceptable, while others expected the associated risks to be minimal.

Some Workshop participants suggested that closure times in the regulations may need to be modified
to reflect actual state and landfill operator experience.  State personnel noted that the  180 days allowed
for closure by regulation is not usually a sufficient amount of time  and that the regulations already
allow for an alternative closure schedule to be set as part of the closure plan process.

Inherent in all of the discussions was how to define closure for a bioreactor landfill.  Questions
included the following:

•       Does closure begin when the  cell is full of waste as is done for conventional landfills, or when
        stabilization of the waste mass is achieved?

•       Is closure conducted incrementally (cell-by-cell in a "rolling closure" manner)  or conducted  for
        the entire landfill  at one time?

•       What will be done with any excess leachate or liquid in  the bioreactor landfill cell?

Some Workshop participants noted that existing regulatory methods may already address issues such as
incremental or  "rolling" closure, but were generally opposed to making such an approach an upfront
permit  condition.
3.8    BENEFITS
Recovered landfill space, the generation of large quantities of landfill gas, and decreasing the length of
time for the environmental liability of the waste are probably the three most significant benefits of
bioreactor landfills.

Landfill space is  recovered  through:
•       Volume reduction  and  increased waste  density achieved  by solids and gas loss  from
        decomposition of the waste mass

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•       Rapid settlement of the waste mass.

During the landfill operational period, recovered landfill space may allow placement of more waste
tonnage into the same amount of permitted landfill volume.  This reuse of landfill space can signifi-
cantly  increase disposal revenues and significantly increase landfill life.

The significant increase in total gas available seen within a relatively short time period (the landfill
operating period plus 5 to 10 years  after bioreaction initiation) provides for  entrepreneurial opportuni-
ties.  One is to maximize landfill gas capture for energy projects;  however, a cost off-set is installation
of the  gas collection system,  and there are significant economy of scale  considerations that indicate
this may not be viable for sm'all- or medium-sized landfills.  Related benefits include greatly reduced
greenhouse gas emissions and the  potential for fossil fuel emission offsets. When the final cover is
applied, both gas generation and the moisture content of the waste mass  drop dramatically.  These
reductions can significantly affect gas flow to support energy projects and continued bioreactor function.

Other  potential benefits of this enhanced  landfill performance include, but are not limited to, the
following:
•       Reuse of the land may be possible  much  earlier after installation of the  final cover than with
        conventional municipal solid waste landfills

•       A shorter life cycle that may realize significant reductions in operations, maintenance, and
        monitoring costs

•       Treatment of leachate constituents  through recirculation

•       Leachate recirculation can eliminate transport, treatment, and disposal costs but this may be
        offset by the costs associated with  leachate collection, management, and reinjection (benefit
        may be positive but economics may not be proven)

•       Beneficial reuse of other waste streams (e.g., biosolids) that may otherwise be land applied, and
        reduction of their constituents within the bioreaction

•       Production of a humus-like material that has potential for use as landfill cover as well as other
        non-landfill uses

•       Reductions in long-term risk to the environment and human health.


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A number of economic and cost-benefit life cycle analyses of bioreactor landfills are being conducted
by EPA and private industry.  These are presented in Sections 4.1 and 4.2, respectively.  Section 4.3
summarizes economic considerations identified in the course of Workshop discussions.

4.1   ECONOMIC ANALYSES CONDUCTED BY  EPA OSW

EPA OSW has been  evaluating the costs and benefits  of bioreactor landfills.  The basis of this analysis
involves the volumes and estimated components of municipal solid waste.   In 1998, there were about
158 million tons of municipal solid waste and construction and demolition  (C&D) debris waste placed
in municipal solid  waste landfills.  Over half of this waste  (84 million tons) was organic with the
following estimated composition:
•      Paper - 37.8%
•      Food - 16.6%
•      Yard trimmings - 11.7%
       Wood - 8.6%.

This analysis did not consider plastics and textiles in the waste volume as was noted in the Section 3.1
waste composition  discussions.  Approximately 83  percent  of the organic waste is estimated to be
amenable to decomposition.

Also of note for this economic analysis is that 84 million tons of municipal solid waste generate  6
million tons of methane and take up 85 million cubic yards of landfill space.

In evaluating the  economics of bioreactor landfills,   EPA OSW is examining the following concerns:
•      Do  bioreactor landfills pose a disincentive  to recycling, reuse, and other options for waste
       material that may be used in the bioreaction process (i.e., will bioreactors preferentially increase
       the waste  volume that is land disposed)?

•      Are  there other viable alternatives to manage organic wastestreams, such as composting, so
       that these wastes can be diverted from land disposal and stabilized  in a much smaller amount
       of time than would occur in a bioreactor?
Section 4.1.1 provides an overview of this economic analysis. Section 4.1.2 presents the preliminary
findings.

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4.1.1  ECONOMIC STUDY OVERVIEW

Data needs for this and other related economic analyses include the following:

•       Costs of bioreactor landfill design, construction, and operation

•       Cost data to compare the effectiveness of bioreactor landfills against composting of organic
        materials and against conventional landfills for inorganic materials.

For purposes of this Workshop, presentations of this economic analysis focused on the comparison of
bioreactor landfills with composting of organic matter.

This EPA study considers the following additional costs realized by bioreactor landfills over conven-
tional municipal solid waste landfills:

•       Construction costs associated with the installation of enhanced leachate recirculation devices
        and landfill gas collection systems

•       Operating costs resulting from increased leachate recirculation, gas generation, permitting fees,
        and equipment/manpower needs.

Note that the cost per ton estimates  used in this economic analysis represent the  cost to the local
municipality and assume separate collection of materials diverted for composting or other action.
These costs were derived from an EPA guidebook published several years ago with estimates  of  the
cost per ton to institute grass recycling and similar programs.


Potential benefits of bioreactor landfills being considered in this economic analysis include the following:

•       Reduced leachate treatment/disposal costs
•       Saved landfill space
•       Extended landfill life
•       Deferral of new  cell construction
•       Post-closure savings from fewer monitoring and financial assurance requirements
•       More efficient gas collection with potential for revenues from energy production.
Final cost-benefit criteria for this analysis currently focus on:

•      Avoided methane emissions, including revenues from  energy production and greenhouse gas
       credits for avoided emissions
  >M	'ji- 	p	«1
  CHAPTER FOUR

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•       Landfill space saved, such as additional capacity and quantities of organics diverted from landfills

•       Changes in waste management costs, such as comparisons of additional operating  costs against
        savings and incremental costs of diversion  against disposal.

Uncertainties affecting the economic analysis  include the following:

•       How does leachate recirculation affect waste densities, settling, and compaction?

•       How much more capacity is actually obtained with bioreactors vs. traditional landfills and what
        Is the value of the "saved" space?

•       How much additional methane is generated and how much can reasonably be captured?

4.1.2  PRELIMINARY RESULTS

Preliminary results of EPA's economic research and analysis for the comparison of bioreactor landfills
and organic composting indicate that:

•       Bioreactor landfills may offer improved performance and cost savings over conventional land-
        fills

•       Organic diversion has the potential to save significantly more landfill space than bioreactor
        landfills

•       Improved diversion of organic material could  more significantly reduce waste management
        costs than the  use of bioreactor landfills

•       25.6 million cubic yards of  landfill space may be saved based on an assumption  that 13%
        additional capacity is generated  by bioreactor landfill operations and consideration of different
        density factors for different wastes in the landfill

•       Avoided methane and other gas emissions  (through energy recovery or other gas collection/
        utilization projects) have the potential to be considered "avoided  greenhouse gas emissions"
        for purposes of economic analyses

•       Savings from bioreactor methane are  longer-term than those achieved by organics diversion,
        which tend to be short-term based on greenhouse gas emission credits.
This economic analysis does not currently address gases other than methane (such as CO ). EPA also anticipates

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looking at the economics of transportation and other factors in combination with the end results of waste manage-
ment.

4.2    MODELED ECONOMICS OF LANDFILL BIOREACTORS BY PRIVATE INDUSTRY
 Waste Management Incorporated (WMI) is working on a variety of bioreactors and is investigating the Me cycle
economics of these landfills as compared to more conventional municipal solid waste landfills. WMI is developing
a cost model that draws on theoretical data obtained in the United States and Europe to assess the financial
investment and returns on investment for various types of landfills to identify the most cost-effective approaches,
and to identify the factors that drive the economics of bioreactor landfill implementation and operation.

The economic analysis considers two broad categories: new construction  of bioreactor landfills and
retrofit of existing landfills to  become bioreactors.  The analysis also considers 10 landfill types:
•       Aerobic, retrofit landfill
•       Anaerobic, retrofit landfill
•       Facultative, retrofit landfill
•       Hybrid  aerobic/anaerobic retrofit
•       Aerobic, new construction landfill
•       Anaerobic, new construction  landfill
•       Facultative, new construction landfill
•       Hybrid  aerobic/anaerobic, new construction landfill
•       Base case, conventional municipal solid  waste landfill.

The economic  model considers all construction costs as well as  those associated with operations,
capping, closing, etc. to determine the investment required.  The model also considers all investments
necessaiy such  as legal, permitting, and other cost factors.

The following  sections provide an overview of the economic model  and the initial results  of the
economic analysis.  Section 4.2.1 summarizes general background information  on assumptions used  in
the economic model.  Section  4.2.2 presents preliminary findings and conclusions regarding bioreactor
landfill functions, cost drivers, and  overall economics.
4.2.1  ECONOMIC MODEL ASSUMPTIONS
The different landfill types were compared to a "base"  landfill with the following features:

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•       140 acres with 10-acre cells and 800 cubic yards of waste in place
•       Operates 275 days per year
•       2,500 tons per day of municipal, construction and demolition (C&D), solidification, and spe-
        cial wastes.

New landfills were similar to the "base" landfill in these features.  However, the retrofit landfills in-
volved 30-acre plots.

The  economic model considers the use of other clear liquid waste streams in addition to leachate.
These included clear  aqueous waste streams from lettuce processing, soft drink manufacturing washdown,
bakeries, etc., that had high BOD and low solids. Biosolids  that could be added in liquid form were
also  considered and  are  of particular interest because they are readily available and may be relatively
economical to use depending on fees and taxes.

Uncertainty presently exists regarding how leachate and other liquids will be added to the landfill waste
mass. For example, there are days when workers may not be on  site to conduct liquid  addition (e.g.,
Sundays), and there are also considerations of whether to add liquids on days when it rains or snows.

Assumptions used for gas generation and management in the economic model include the following:
•       Aerobic reactors have no recoverable methane (although actual experience is  that there are
        some methane emissions

•       Facultative bioreactors will produce methane at 1.5 times the rate of Subtitle D landfills

•       Anaerobic and hybrid bioreactors produce methane at 2  times the rate of Subtitle D landfills
        and produce it very quickly.
Also, in its current form, the economic model does not assume any differences in post-closure care
between the nine types of landfills.
4.2.2 PRELIMINARY FINDINGS
Data from the economic analyses have been compiled into tabular form to facilitate comparison of the
different landfill scenarios considered in the analysis.  Comparisons of all landfill scenarios to the base

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case determined the following for bioreactor operations:
•      Gain in landfill space of 15 to 30 percent.

•      Increased density of waste mass.

•      Increased landfill life.

•      Reduced regulatory and permitting costs over "base" landfill case.

•      Significant revenues from gas generation.

•      A gas collection  system is more expensive to retrofit into an existing landfill (this model as-
       sumed no gas collection system for an aerobic landfill).

•      Odor control systems that counteract the  odor rather than mask it may be necessary.  Such
       systems are not expensive to install, but are expensive to operate and can drive the economic
       model.

•      Some substantial increases in investment with some offsets.  For example, new construction
       costs may be more advantageous than retrofitting.

•      Ammonia removal  may also  be necessary.

The largest changes in estimated costs for various types  of bioreactors  were found for the following
factors:
•      Aeration of mass or leachate
•      In-situ performance monitoring instrumentation (temperature)
•      Reduced leachate disposal
•      Health and safety (if liquid used rather than caked biosolids)
•      Odor control (significant cost per day)
•      Dozer operation
•      Increased water  truck usage
•      Decreased new construction.
WMI examined the factors that drive this economic model based  on experience gained at its Metro and
Live Oak facilities. These factors include, but are not limited to, the following:
•      15% gain in airspace for retrofit with 30% gain in new landfills

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•      Increased manpower for gas technicians  (retrofit)

•      Increased manpower for daily operations  (e.g., new landfill requires an additional dozer opera-
       tor and additional technicians to place pipe/monitor).

Potential bioreactor landfill benefits identified from these  analyses include the following:

•      Reduced post-closure period

•      Reduced heavy equipment usage because there is less need for waste compaction

•      Decreased air emissions

•      Reuse of old landfill airspace on a  full-scale basis —  a very critical factor from the perspective
       of private  industry.


Potential risks associated with bioreactor landfills include  the following:

•      Changes in design and construction to make wider cells allowing for flatter filling lifts, which
       involve stability and safety issues

•      Changes in  slope construction from 3:1 to as much as 4:1, which would result in a net loss of
       airspace and may preclude future reuse of the air space for waste addition

•      Personnel  hazards from more operating equipment, which increases the opportunity for acci-
       dents

•      Odor problems.
The following conclusions were offered regarding the results of the economic analyses:

•      Airspace recovery drives the economic model because that is the key selling factor to those
       who run landfills.

•      Addition of biosolids may be an important factor and may be  especially important to new
       construction bioreactors.
•      Bioreactors do not appear to be viable in dry areas without large water sources.

•      Installation of a gas collection  system is less expensive for  bioreactor landfills if done  at the
       time waste is first placed in a new landfill.  Even delays of only 2 years can render this economi-

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        cally nonviable.

•       Much of the early work on bioreactors involves retrofit of existing landfills because this is
        easier than building a new landfill.  Efficiencies  and ease of applying these techniques to new
        landfill cells  may be significantly more beneficial than retrofitting.

•       Retrofitted landfills are easier to operate because of the lack of traffic for new waste  and the
        absence of interferences  from the work force that may be encountered at an active landfill.

•       Aerobic landfills need to be better defined.  Experience to  date suggests  that retrofit  aerobic
        bioreactors are really anoxic and do not actually have aerobic kinetics.

Based on recovered air space alone, bioreactors appear to make economic sense.   However, retrofitting
existing landfills for bioreactor  operations may not be economically viable.   Additional research is
needed to determine if this economic model is correct, since many of the assumptions are not yet
proven at large scale.

4.3    DECISION SUPPORT TOOLS FOR ESTIMATING  LANDFILL GAS EMISSIONS

There are existing tools that may either be directly applicable or potentially modified to predict landfill
gas emissions associated with the operation of landfills as a bioreactor. A tool that has been used to calculate the
tradeoffs in environmental burdens is the municipal solid waste decision support tool (MSW-DST). This tool was
developed through a cooperative agreement (CR823052) between EPA and the Research Triangle  Institute. The
methodology incorporates a life-cycle evaluation of the full range of multi-media and multi pollutant tradeoffs in
addition to providing the full costs of a solid waste system.  All the waste management activities are modeled
including collection, transportation, recycling/composting, and treatment (e.g.,  landfilling and combustion).  For
those materials that are potentially recoverable and displace virgin resources and/or conserve fossil fuels, offsets
are calculated for each of the recoverable materials in municipal solid waste (e.g., aluminum cans, steel cans,
corrugated containers, newsprint). This tool took over 6 years to develop and has undergone rigorous stakeholder
and program peer review from international experts. The result is a credible, state of the art tool for evaluating
different strategies for integrated waste management.
One of the options as part of the landfill process model is operating the landfill as a bioreactor. The defaults are
based on expert opinion but there  is no long term data to confirm  if these are accurate. Data resulting from
ongoing field studies will help to determine if these defaults need to be modified.

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For more information regarding the MSW-DST, refer to the project website at: www.rti.org/units/ese/p2/lca.cfmtlife.
This website provides  a brochure and a PowerPoint™ presentation of the decision support tool, and will be
updated to provide additional outputs and information on the availability of the decision support tool and life-cycle
inventory database. The research team is also preparing a series of peer-reviewed journal articles to highlight the
different aspects and uses of this tool and to summarize findings from case studies in different communities where
this life-cycle tool has been applied.

EPA is seeking the following information to help more reliably quantify the potential burdens and/or
benefits associated with  bioreactors:
•       Long-term bioreactor landfill operating data from  operating facilities and/or demonstration
        projects

•       Long-term data to develop or validate model inputs for anaerobic, aerobic or hybrid bioreactors

•       Data to evaluate  different options in use for landfill gas collection and control including timing
        of installation, length of time in place,  type of material for  cover to minimize  fugitive
        emissions, etc.

•       Types  of operating data  needed to  support permitting and/or  enforcement.

The EPA also  has available a tool (i.e.,  Landfill  Gas Emission Model1, or LandGEM) that is used to
develop state and national emission inventories, and determine applicability to CAA regulations.  The model is
based on a first-order decomposition rate equation.  However it is based on conventional landfilling practices and
would need modification to reflect bioreactor operations.
 In addition to the above needs, data are also needed on:
 •      The potential for fugitive landfill gas emissions as compared to conventional landfilling
practice
        Efficiency of existing methods for  detecting landfill gas fires and/or  landfill gas collection/
        control failures
 1  (Thornloe, S.A., A. Reisdorph, M. Laur, R. Pelt, R.L Bass, and C. Burklin, The U.S. Environmental Protection
 Agency's Landfill Gas Emissions Model (LandGEM), Sardinia '99, Seventh International Waste Management and
 Landfill Symposium, Published in Proceedings, Volume IV, Pages 11-18,  October 4-8,1999-)




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        Information regarding contingency plans for landfill fires.
 4.4   ECONOMIC ASPECTS IDENTIFIED BY WORKSHOP  PARTICIPANTS
 Throughout Workshop discussions, participants provided a number of suggestions regarding factors
 to  consider in economic and cost-benefit evaluations of bioreactor landfills.  Many of these sugges-
 tions are presented throughout other sections  of this  document in the context of those particular
 discussions.  To briefly summarize, economic and cost-benefit considerations  include, but are not
 limited to,  the following:

 •      leachate transport, treatment, and disposal costs will be reduced by recirculation of this waste
        stream in the landfill. Off-setting costs include those associated with leachate recirculation
        system installation and operation.

 •      Increased disposal revenues from use of additional landfill capacity realized from the rapid
        settlement of the waste mass seen in bioreactor operations.  During the landfill operational
        period, this allows placement of more waste tonnage into the same amount of permitted
        landfill volume.

 •      Significant increases in landfill operating life realized from the rapid settlement of the waste
        mass seen in bioreactor operations.

 •      Potential for gas recovery projects  to use the large quantities of methane generated by bioreactor
        landfills. Economics may vary based on landfill size (smaller may be disadvantageous) and
        whether greenhouse gas credits can be sold. Cost off-sets also exist for installation  and opera-
        tion of the gas collection and management system as well as investments associated with waste
        preprocessing  (e.g., shredding)  that may be necessary for  optimum gas generation.

 •      No energy project potential  exists for aerobic bioreactors because they do not produce such
        significant quantities  of methane as are found in anaerobic bioreactors.

 •      Decreased municipality cost to treat and land apply biosolids from POTWs that are instead used for liquid
        addition in bioreactor landfills. Off-setting costs include increased transport requirements to move a
        larger waste volume of liquid waste to the landfill.

 •      Revenues from recovery and reuse of the humus-like substance resulting from bioreaction.

Workshop participants all agreed  that any  economic or financial analysis must address specific goals to

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be achieved.  These may be airspace recovery, leachate management cost reduction, methane gas recovery, or
others. Thus, the outcome of the economic or financial analyses will vary and may be difficult to compare because
the financial benefit depends on the goals.

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This section summarizes ongoing research as well as research needs and data gaps to be filled to
support potentially broader use and regulation of bioreactor landfills. Section 5.1 provides an overview
of current research directions within the EPA Office of Research and  Development (ORD) regarding
bioreactor landfills.  Section 5.2 summarizes research needs and data gaps for bioreactor design, opera-
tion, and monitoring identified by Workshop participants.

5.1    EPA OFFICE OF RESEARCH AND DEVELOPMENT BIOREACTOR LANDFILL RESEARCH
        DIRECTIONS

Although research on bioreactor landfills and containment systems in general is a relatively small effort
from a funding perspective, there are a number of activities underway  or planned to be conducted by
EPA.  Related research activities include the following:

ORD/National Bisk Management Research  Laboratory  (NRMRI.)
•       Containment
        -     Hydrologic models
        -     Alternative covers
              Superfund Innovative Technology Evaluation (SITE) Program project on  asphalt ad-
              ditives
              Slope stability .and leachate interaction impacts on geotextiles
        -     Long-term performance of containment  systems

•       Bioreactors
        -     Monitoring requirements
              Reactor  design
              Field evaluations (ORD and OSW have developed a Cooperative Research and Devel-
              opment  Agreement (CRADA) with WMI to conduct a detailed evaluation of the de-
              sign and monitoring of landfill bioreactors)
              Model for estimating hie cycle environmental burdens, which also evaluates capital and
              operating costs

•       Landfill  Emissions
        -     Air issues, characterization, and controls  for landfills
              Field tests to characterize municipal solid waste landfill air emissions and to evaluate
              options  for controlling landfill gas  emissions through synthetic covers  and other ap-
              proaches to minimize environmental burdens
              Data to  develop and/or verify default values in life-cycle inventory decision support
              tool for characterizing long-term environmental burdens and/or benefits; however,
               data over many decades may be needed.

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 National Center for Environmental Research  CNCP.R)-Supported Research
 •      Science to Achieve Results (STAR)  Grants Program - centralizes much of the research fund-
        ing within ORD,  and involves competitive, peer-reviewed,  extramural investigator-initiated re-
        search grants for innovative solutions to environmental problems.  Solicitations are held four
        times a year in specific topic areas.  The STAR Program has funded proposed projects that
        cover a wide range of research priorities. Additional information may be found on their website
        at www.epa.gov/ncerqa.

 •      Hazardous Substance Research Centers - fund different groups of universities.  One proposal
        (not  yet finalized) addresses bioreactors.

 •      Small Business Innovative Research Program - helps fund small  business ideas.  This is  a
        potential avenue for bioreactor research.

 •      University of New Orleans - has a small amount  of funding from EPA dedicated to landfill
        research

 excellence and Leadership (XL) Program
 •      A national pilot program allowing state/local governments,  businesses, and Federal facilities to
        work with EPA in developing innovative strategies to test better or more cost-effective ways to
        achieve environmental and public health protection

 •      Bioreactor projects under this program include:
        -       Yolo County,  California
        -       Buncombe  County, North Carolina
        -       Maplewood and King George County Landfills, Virginia
        -       Anne Arundel County, Maryland

 •       Additional  information can be obtained from the EPA Office of Reinvention or  the  EPA
        website at www.epa.gov/ProjectXL.


5.2    LANDFILL BIOREACTOR RESEARCH NEEDS AND  DATA GAPS
       The history of bioreactor research involves in the U.S. the following timeline of events:

       1970s - laboratory- and pilot-scale studies showed that bioreactors worked at small scale

       1980s - first generation full-scale application in Delaware and California

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•      Early-mid 1990s - second generation of full-scale applications, yet uncertainties remain about
       how to design and operate them

•      Late 1990s/2000 - tremendous  growth in interest in implementing this technology with at-
       tempts being made to address how to do this at  full scale, how to regulate it,  and how to
       determine the economics issues.

The following  sections  summarize research needs, data gaps in bioreactor landfill understanding, and
other suggestions identified by Workshop participants throughout the Workshop discussions.   These
suggestions are organized by topic areas  consisting of bioreactor landfill design (Section 5.2.1), opera-
tion and performance  (Section 5.2.2), and monitoring (Section 5.2.3).  Section 5.2.4 addresses life-
cycle, cost-benefit, impact, and economic analysis suggestions.  Section 5.2.5 presents general sugges-
tions for research focuses, information sources, and education.  Data needs and Workshop participant
recommendations pertaining to regulations  and  regulatory development activities are addressed in
Sections 2 and 6 of this document.

5.2.1  DESIGN
Workshop participants expressed  many different views on  the definition of a bioreactor landfill:
•       Base the definition on the end product?
•       Include leachate recirculation in the definition?

Others suggested considering bioreactor landfills as simply an  alternative operating/management ap-
proach to conventional municipal solid waste landfills.

Criteria may be needed in circumstances where it is or is not appropriate to use bioreactor landfills.  For
example, some Workshop participants suggested that the use of bioreactors in arid environments may
not be appropriate.  Some Workshop participants also suggested that identifying all of the criteria that
need to  be considered may be difficult because the bioreaction process can be so site-specific.

Questions were also raised regarding the performance of aerobic bioreactor landfills.  Of specific note
was whether aerobic landfills would be  capable of achieving the performance that anaerobic landfills
are considered capable of achieving..

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 Currently there is only very general knowledge of the activities and roles of microbial populations in
 the bioreaction process.  Better understanding of that process may lead to techniques  to monitor or
 control the reaction as is done for other types of fermentation processes.  This may require the develop-
 ment of culturing techniques or adapting modern molecular techniques to obtain the necessary data.

 Data  needs pertinent to bioreactor landfill design include the following:
 •      Techniques  to  measure head on a liner and whether there are more efficient  options than
        installing large numbers  of sensors

 •      Whether single liners or unlined landfills are appropriate for bioreactor landfill operations

 •      Whether sufficient information is already available regarding waste properties and actual bioreactor
        landfill operating conditions to use existing tools for predicting landfill stability and failure

 •      Methods or  techniques to assure slope stability

 •      Timing and  placement of temporary  covers

 •      Appropriate  materials for temporary and final covers

 •      Whether materials exist or can be developed that will  let water into  the landfill yet keep gas
        from being emitted  to the atmosphere.

The performance  benchmark for bioreactor landfills expressed throughout many of the Workshop
sessions is the RCRA Subtitle D municipal solid waste landfill.  Some Workshop participants raised the
following  questions  regarding the use of this benchmark:
 •      Is the RCRA Subtitle D landfill the appropriate benchmark?

 •      Is more research  on Subtitle D needed in parallel with bioreactors to enable comparison?

 •      What are the appropriate performance questions  to address in demonstration projects:
               Are bioreactors superior or environmentally preferable to the RCRA Subtitle D land-
               fills?
               Can bioreactor landfills be shown to be safe and controllable  (i.e., protective of human
               health  and the environment)?
Note that  the  CAA regulations only require demonstration of "similar" not  "superior" performance.
"Superior" is  only required in the XL  Program.

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5.2.2 OPERATION
A major question raised by Workshop participants was whether the bioreaction can be stopped once it
is started.  Many believed that it cannot be stopped at all or that it cannot be quickly "shut off" (like a
valve). Therefore, the ability to  control the reaction was identified as an operational research area.

Other significant questions arose as to how to define  when the bioreaction is "done" or how and when
to stop the reaction so closure or post-closure care can begin.  Workshop participants noted the follow-
ing  potential areas requiring research to make those determinations:
•      Gas generation
•      Settlement
•      Waste mass reduction.
Table 5-1 presents research needs and data gaps identified by Workshop participants for the following
operational considerations: waste emplacement, settlement, leachate collection system performance,
controls for internal landfill environment to promote optimum performance, liquid recirculation, and
gas management.

In addition, Workshop participants noted the important need to develop  complete material balances
and estimates  of water consumption to support better understanding of the bioreactor landfills.  Quan-
tification of the water balance involves the following at a minimum: incoming waste moisture, prefer-
ential flow paths through  waste, difficulties in achieving even moisture  distribution, runoff, evapo-
transpiration,  infiltration, waste field capacity, and average waste flow.

5.2.3  MONITORING

Workshop participants identified the following research needs or data gaps for monitoring landfill
bioreactors:
•       Consider research in the early 1990s regarding the disappearance  of oxygen (air) and changes
        in  helium  to determine respirometry

•       Type(s) of monitoring  instrumentation needed (requires  integration  of waste  engineers,
        geotechnical personnel, and biochemical personnel to address)

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TABLE 5-1.   RESEARCH NEEDS AND DATA GAPS FOR BIOREACTOR LANDFILL
                 OPERATIONS
                  WASTE EMPLACEMENT
            SETTLEMENT
          Whether to compact the waste at the time of
          emplacement or let the waste mass and
          overburden do that
          Methods to compact waste and prevent side seeps
          without preventing moisture migration
   How to define volume loss
   Collect data on characteristics of old or
   decomposed waste (such as shear strength) to
   address potential  stability issues
             LEACHATE COLLECTION SYSTEM
                      PERFORMANCE
       LIQUID RECIRCULATION
          Methods for in-situ measurements of pore
          pressure
          Criteria to define performance
          Methods to monitor performance
          Whether the absence of leachate means that
          no leachate is being generated or that there
          is a failure in the collection system
          Methods to prevent plugging of the collection
          system
   Methods to recirculate liquids to acheve a
   uniformly wet landfill
   Methods to control how moisture moves
   through a landfill
   Determining how much water is necessary
   considering cover, preferential channels, and
   waste hetereogeneity effects on moisture
   content
   Whether to use other types of liquids
   (nonindigenous liquids) to supplement
   nutrients/moisture, dispose of other liquid
   waste streams, compensate for insufficient
   waste volumes, and/or to avoid concentration
   of inorganic contaminants
   Methods to measure  moisture level
             CONTROL OF INTERNAL LANDFILL
        ENVIRONMENT FOR OPTIMUM PERFORMANCE
GAS GENERATION AND MANAGEMENT
          Whether pH or moisture content control are
          necessary
          Whether shredding or other waste
          pre-processing techniques enhance performance
          Methods to assure uniform flow of liquid
          and gas with consideration of new geosynthetic
          materials, strip drains, etc.
          Whether moisture distribution is more
          appropriately expressed in terms of thermo
          dynamic activitiy  and matrix potential (for
          thriving of microbial populations) or more
          traditional weight fraction?
          How waste  permeability changes vertically
          within the landfill
          Identifying  key factors optimizing this environ-
          ment and the appropriate indicator  methods
          Appropriate goals or performance levels and
          operating conditions that will achieve these as
          quickly as possible
  More efficient/economical methods for gas
  capture and use
  More efficient/economical methods to avoid or
  control odors
  Whether to recycle methane to aerobic parts of
  the landfill as an energy source for the microbes
  Consider establishing different criteria for explo-
  sion hazards and greenhouse gas emissions, for
  example:
  -explosion     done=measurements show X% of
                lower explosive limit after Y years
  -greenhouse    done=measurements show X% of
                lower explosive limit after Y years
  Acquire emissions data for bioreactor landfills
  Determine appropriate default values for meth-
  ane generation rate and potential under bioreactor
  landfill operations
  i.	•*;<	»1f': Jll S'&J	11 SB
  CHAPTER	FIVE.^;

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                                                                                      '»»„#*- <•'
•      Methods to package instrumentation to track and display data in a useful way

•      The number of groundwater monitoring wells needed

•      Parameters, values, or other measures that can be used to define the end of the post-closure
       monitoring period

•      Improved, more accurate measurement methods for landfill gases.

5.2.4 LIFE-CYCLE
A number of Workshop participants suggested that the bioreactor landfill contributes to sustaining the
landfill life-cycle.  Europeans have a concept of a sustainable landfill with the following features:
outputs do no  harm, outputs represent no long- or short-term risks,  hazard  at post-closure is not
passed on to future generations, and use of landfill is unimpaired.  Workshop participants noted that
the ability to apply such an approach requires the following questions to be  addressed:
•      When is the decomposition completed?

•      When is waste within a landfill stabilized?

•      How much degradation is needed before the waste and landfill pose little risk?

•      What kind of cap  or other operating issues are required to control fires, metals, etc. so that
       such a landfill can pose little risk?

Some Workshop participants  consider sustainability to involve complete  reaction and stabilization of a
bioreactor that  is eventually dug up, reclaimed, and landfllled again. Such a  scenario does not require
post-closure  care.

Benefit, impact, and  economic analysis  research needs, data gaps, and suggestions from Workshop
participants include  the following:
•      Approach a bioreactor landfill as a closed treatment system and evaluate the benefits as com-
       pared to traditional management methods involving open treatment systems (e.g., land applica-
       tion of biosolids)

•      Post-closure long-term usage options include reuse of the space generated to emplace more
       waste or use for recreation

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 •       Develop a better definition of bioreactor benefits

 •       Acceptability of continuing to generate small quantities of landfill gas after the post-closure
        period

 •       Develop improved models with defaults reflecting bioreactor operations and  emissions

 •       Consider that waste generation continues to rise when  conducting alternatives analysis

 •       Economic viability of recovering the gases produced in  large quantities early in the bioreactor
        process.

 •       Define economic impacts by weighing benefits (such as enhanced gas production, recovered
        space, reduced environmental impacts, reduced post-closure care) and costs

 •       Whether bioreactor landfills are economically more viable for some waste streams and how the
        cost per ton  may vary; for example, some wastes may be more expensive to treat in a bioreactor
        landfill than others (e.g., food/organic matter are easiest, and paper/wood  is  easier than
        metals)

 •       Need to identify the  point at which gas monitoring is more expensive  than installing and oper-
        ating a gas extraction system

 •       Cost-effectiveness of opening  up an alternative cover to check waste mass  degradation or to
        mine landfill materials.

5.2.5  GENERAL SUGGESTIONS

A number of general  suggestions for research topics, data needs, or other aspects of evaluating bioreactor
landfills for broader use and application arose throughout the  course of Workshop presentations  and
discussions.  These included the following:

Research
 •       Commitments to long-term research are important.   For example, landfill research was active
        20 years ago, then declined significantly, and is now  increasing

 •       Consider focusing research on aerobic environments since this type of landfill  may accomplish
        in 1 to 2  years what an anaerobic  bioreactor landfill  accomplishes in 5 to 10 years

 •       Consider what Europe and Japan are doing  on a  larger scale to avoid duplication  of effort
  CHAPTER, :FKE:;:


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 •       Develop interfaces with European and Japanese researchers to share information

 •       Research community needs to collaborate in some manner to leverage the available funding to
        its best use

 •       EPA needs to prioritize and focus its research efforts and research priorities so that private
        industry can focus its research activities to avoid duplication of effort

 •       Private industry research initiatives encompass gas rates, sampling, mass collection, and leachate
        collection, among others

 •       Identify  additional funding sources for the background research and testing identified in the
        Workshop since the collection of such data may be valuable but is also very expensive

Information  Sources
 •       There are many 40-  to 60-year-old landfills throughout the United States that  might help an-
        swer some of the questions raised in this Workshop

 •       California has both wet and dry landfills that might be able to support some of the proposed
        research studies

•       Consider a formal or informal ongoing dialogue between EPA, academia, regulators, and the solid waste
        industry, preferably over the long-term, for further information exchange in addition to  the state-by-state
        dialogue already underway

•       The Wisconsin  Department of Natural Resources will soon publish a report regarding the
        Metro bioreactor  landfill activities

•       Re-examine research  conducted 10 to 20 years ago  to see if it has value to current efforts

•       With current research plans, much more will be known about bioreactor landfills over the next
        3 years
Education
•      Bioreactor landfills involve more sophisticated operations than conventional municipal solid
       waste landfills, so education programs may be necessary for the companies and individuals
       considering this alternative to better understand both the basic operations and the ramifica-
       tions and risks because of the potential for massive failures

•      Consider educating solid waste industry and the  public about the differences between wet
       landfills and bioreactor landfills

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Develop some design and operations training for air emissions aspect of bioreactor landfills

Modify existing training for new air regulations to spend more time on wet landfills  and to
address landfill fires.

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Workshop sessions covered a wide range of technical, regulatory, and economic discussions pertaining
to the definition, design, operation,  closure, and overall implementation of bioreactor landfills.  Sec-
tion 6.1 presents the EPA perspectives identified during the Workshop pertaining to areas of potential
regulatory areas of focus.  Section 6.2 presents the suggestions offered to EPA by Workshop partici-
pants to consider in developing regulations  for bioreactor landfills.

6.1   EPA PERSPECTIVES

EPA is focusing is on what changes can be made to existing  landfill criteria to enable the use of
bioreactor landfills,  especially  requirements that ensure such systems are  protective of human health
and the environment.  Bioreactor landfills do involve different operations as compared to conventional
municipal solid waste landfills.

Issues EPA identified from Workshop discussions for consideration in developing or modifying regu-
lations include the following:
•      What is the timing of regulatory change — while several small, full-scale projects are under-
       way, bioreactor closure has  not yet been accomplished.  Should work on regulatory changes
       begin now or when more information from these projects is available?

•      Will states view Federal regulatory Subtitle D changes that support/foster bioreactor operation
       in the near term as creating pressure to develop  and issue more bioreactor landfill permits than
       they are comfortable doing?

•      Should waste be shredded?

•      If moisture is not applied uniformly to waste in the bioreactor landfill,  does  this impact the
       need to provide monitoring long-term or in perpetuity, which may  be longer than the 30-year
       post-closure  period under RCRA Subtitle C regulations?  This issue  is of particular  note in the
       SBREFA comments received to date on the  RCRA  Subtitle D requirements (as described in
       Section 2.1).

•      What is the appropriate timing  of final cover installation to ensure its integrity?

•      Should EPA specify certain design standards?

•      Should EPA specify control mechanisms and their performance?


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•       Rather than specifying design standards and/or control mechanisms, should EPA develop tech-
        nical guidance for state personnel; for example, a series of factors to consider such as monitor-
        ing for moisture or temperature and when to  install such components?

•       What special regulatory provisions, if any, are appropriate only to existing landfills or only to
        new landfills?

EPA representatives believe that the existing Subtitle D regulations provide sufficient flexibility for
states to approve alternative materials  for daily cover, and State representatives  noted that authority
already exists to approve alternative liners as well.   However, allowing the addition  of liquids  to a
landfill  for the bioreaction to work properly would involve a major regulatory change.

One option identified for the short-term is the potential use of research, development, and demonstra-
tion (RD&D)  permits  under RCRA Subtitle C regulations, pending  development  of regulations.  This
option received  a significant positive response by many Workshop participants.

Many Workshop attendees felt that bioreactor landfills were not yet  ready for any type of prescriptive
regulation and that flexibility, such as that offered by RD&D permits, may be most appropriate at this
time to  enable private industry to develop a better understanding of how to best design and  operate
such facilities.

6.2    WORKSHOP  PARTICIPANT SUGGESTIONS
Other regulatory changes proposed by Workshop participants included the following:
•      Adapt the regulatory framework already in existence to include bioreactor landfills

•      Approve full-scale bioreactor use with basic performance parameters

•      Include "or equivalent" with any prescriptive requirements such as those for liners to provide
       necessary flexibility

•      Use testing and monitoring in lieu of prescriptive requirements; for example, requiring testing
       at the end of the waste stabilization period to determine  if waste stabilization has attained the
       necessary level

•      Draw on other regulatory experiences that involved flexibility in developing site-specific stanWorkshop

-------
dards; for example, the development of a standard for cyanide to identify when it was "inert" in waste
material from gold mining operations, thus enabling the material to be left in place without capping

Allow flexibility to use single composite liners, mixed composite liners, and double liner sys-
tems with an interliner detection system

Include regulatory flexibility regarding temporary and final cover selection to avoid a bathtub
effect of letting liquid in from the top and precluding its release from the landfill base

Consider viewing alternative final covers as a partial or incremental closure approach since
these covers seem to be a variation of temporary covers

Consider the range  of landfills that may be encountered since cover requirements may vary
depending on the landfill type (e.g., dry tomb vs. bioreactor vs. landfill types in between the
two)

If a double liner requirement is imposed for bioreactor landfills, then more liberal operating
requirements/flexibility should also be included  (trade-offs between prescriptive requirements
and  flexibility)

Establish criteria for clean closure

Establish a threshold for gas monitoring (trigger level requiring  action if it is exceeded) and an
analytical method that an operator can use to show whether this threshold is  exceeded.

Include regulatory flexibility to allow for new processes in the future that may focus on achiev-
ing other goals

Include emergency cleanup provisions (for hurricanes, tornadoes, etc.) — Federal actions may
take place under Federal Emergency Management Agency (FEMA) emergency rules  and some
states already have such emergency provisions;  however, many states  already feel the regula-
tions offer sufficient flexibility

Address  solid waste  management in a way that is not a  burden to future generations to main-
tain  caps and leachate  collection systems or to continue groundwater monitoring

RCRA Subtitle D authorizes  the  Director of a state agency to authorize variations so the states
may be the place where regulatory change to RCRA stardards is needed


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        Workshop participants regularly noted throughout the Workshop presentations and discussions that not
        every solution will fit every landfill. This is the basis for many suggestions regarding the need for flexibility
        in regulations for bioreactor landfills.

Regulatory agency representatives raised the question as to whether there should be minimum pre-
scriptive regulatory criteria for bioreactors and what such criteria might involve.  Many workshop
participants (industry and state regulatory personnel)  expressed a preference for performance stan-
dards rather than prescriptive requirements because prescriptive standards can quickly become techno-
logically out-of-date and often do not provide regulatory personnel with the flexibility to approve new
technologies and techniques as they develop. Another  argument in favor of performance measures is
that they may help regulatory agency personnel to interpret information and data provided by  landfill
owners/operators.  State regulatory personnel noted that for performance-based standards to be suc-
cessful, there needs to  be a foundation of guidance and technical input from industry, consultants,
researchers, and other  knowledgeable personnel.  Others raised concerns about potential misuse of
performance-based standards, which is one reason prescriptive requirements are often put in  place.
Workshop participants anticipated that ultimately there will be a combination of performance-based
and prescriptive requirements.
Other regulatory issues raised by Workshop participants included the following:
•      Life cycle bioreactor landfill economics are strongly influenced by whether or not energy is
       recovered, and this is largely due to the credits received for lack of fossil fuel emissions from
       use  of the gas generated at the landfill.  This is difficult for EPA to  address since it has no
       statutory basis to regulate methane.

•      Nitrogen oxide (NOx) emissions from the bioreactor landfill and from leachate management/
       recirculation may be a concern,  and  may affect the ability to conduct such activities in
       nonattainment areas.

•      Verify the inputs for existing EPA models that evaluate environmental  burdens and also  deter-
       mine the need for new  landfill gas  models for different types of bioreactors.

•      Revise existing EPA models  for gas emissions and other aspects to reflect bioreactor landfill
       operations properly.

•      Develop a white paper  on health risks  and safety  issues associated with liquids addition and
       resulting vectors and odors  to  obtain uniform acceptance within the  regulatory community.
  tmmaam

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•      Develop a working policy on the use of biosolids as  the liquid supplement to  a bioreactor
       landfill as well as the potential differential settlement aspects of biosolids use as a cover.

•      Conduct additional testing and monitoring to understand the bioreactor landfill better, which
       in turn will support development of performance-based standards.

•      Potential need for more staff at the state level to address permitting and implementation of
       bioreactor landfills.

Many Workshop participants felt that it was premature to have nationwide regulatory changes but that
more technical guidance was needed.  Examples include:

•      Add a chapter to existing landfill guidance document or develop a new guidance manual to
       address bioreactor landfills

•      Provide guidance on developing the context  for large-scale air issues  to facilitate issue resolu-
       tion with local regulatory agencies

•      Additional training for regulatory agency decisionmakers to enable broader problem  solving in
       lieu of heavy reliance on prescriptive rules and interpretations

•      Consider additional training  or guidance for state regulatory personnel to enhance understand-
       ing of these nontraditional practices.


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The Workshop presentations involved two days of interactive and wide-ranging discussions on bioreactor
landfill design, operation, monitoring, economics, benefits, risks, and regulatory strategies.  Through-
out these discussions, there arose a number of common themes:

•      Bioreactors need to be evaluated to determine their potential environmental burdens and/or
       benefits for the  wide range of bioreactor types under consideration. Data over the long term
       (several decades) are needed for all pathways including air, ecosystems, water, and land.

•      Bioreactors may not be suitable for some geographic areas or some types of landfills.

•      Large quantities of aqueous liquids are needed to sustain/optimize the biofeaction process,
       therefore  supplemental liquids may be necessary since the bioreactor landfill  may not generate
       sufficient leachate  quantities for good bioreactor  performance.

•      Consider  both methane recovery and reuse of decomposed materials in the landfill.

•      Recovered airspace is of great economic interest  to solid waste  management firms.

•      Concerns exist  about the physical stability of wet waste within the landfill and the stability of
       the waste mass  if new waste is placed on top of old, decomposed waste.

•      Need to set specific goals for research programs, financial analyses, regulations, and perfor-
       mance.

•      RD&D  permit approach is very promising and is of great interest.

•      Not every solution will fit every landfill, therefore state programs need  regulatory flexibility
       and landfill owners/operators want regulatory flexibility.

•      Performance-based measures were generally preferred over prescriptive requirements.

•      Actively seek out the bioreactor landfill experience and research in Europe and Japan.

•      EPA needs to set research priorities so that private industry can focus its research and avoid
        duplication of  effort.

•       Education programs are needed to help the regulators, solid waste industry, and public under-
        stand these types of landfills,  their benefits, their risks, and what is needed for proper opera-
        tion/performance.
                                                     ^^^•^-^^^^--^W!^^^^--^^^-^^

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In a summary session, Workshop participants identified the following general research areas:

•      Integrated waste management trade-off analyses (i.e., evaluate different management strate-
        gies for the same waste stream throughout the entire waste stream life-cycle)

•      Understand biodegradation in landfills  by microorganisms

•      "Completeness"  of degradation - when/how to stop

•      Functionality:
        -      stability of slopes
        -      water in/gas out materials
        -      moisture distribution
        -      instrumentation
        -      liner design for containment/monitoring
        -      post-closure and long-term usage

•      Volume loss and settlement

•      Hydraulic conductivity vs. waste depth and degradation status

•       Ultimate fate and shutdown

•       Sustainability via reclamation

•       Monitoring needs

•       Landfill gas emissions  targets and methods

•       Environmental burdens/benefits for the wide range of bioreactor types under consideration

•       Long-term burden/benefit data for all pathways including air, ecosystems, water, and land

•       Data for inputs to models used to develop state emission inventories  and to determine'  appli-
        cable regulatory requirements

•       General bioreactor guidance/support

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International collaboration
Educational outreach
Bioreactor optimization measures
Known existing performance baseline





Application limitations — only for Superfund sites? Unsuitable for arid regions?
Waste preprocessing
Designer/operator training.


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               AGENDA
                FOR
USEPA WORKSHOP ON LANDFILL BIOREACTORS

-------

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                          US EPA Workshop on Landfill Bioreactors
                           Hilton Crystal City Hotel, Arlington, VA
                                      September 6 - 7, 2000
                                             Agenda

Purpose and Scope: To assess the state-of-the practice of landfill bioreactors and to identify research needs.
Wednesday, September 6, 2000
9:00 AM -9: 10 AM
9: 10 AM -9:35 AM
9:35 AM - 9:55 AM
9:55 AM -10:1 5 AM
Welcome and Introductions - John Martin, ORD/NRMRL
US EPA Office of Solid Waste - History and Need - Robert Dellinger
US EPA Office of Water - Overview of the Landfills Effluent Limitations Guidelines -
Ebner
Michael
US EPA Office of Air Quality Planning and Standards - MSW Landfill Clean Air Act
Regulations and Bioreactor Operation Air Pollution Concerns - Michele Laur
  10:15 AM-10:30 AM   BREAK
 10:30 AM-11:00 AM
US EPA Office of Research and Development - Research Directions - Fran Kremer
 11:00 AM-11:45 AM
State Regulatory Perspectives - Robert Phaneuf, New York State Dept. of Environmental
Conservation and Richard Watson, Delaware Solid Waste Authority	
  11:45 AM-1:00 PM
 LUNCH
                      Session: Theory/Expected Benefits
                      Moderator: David Carson, US EPA
  1:OOPM-2:OOPM
Theory/Expected Benefits and Types of Bioreactor Operational Techniques: Anaerobic and
Semi-Aerobic - John Pacey, EMCON	
 2:00 PM-2:10PM
Economics Introduction - Scott Palmer, US EPA
 2:10 PM - 2:30 PM
Modeled Economics of Landfill Bioreactors - Gary Hater, Waste Management, Inc.
  2:30 PM - 2:45 PM
 BREAK
                      Session: Case Studies - Performance
                      Moderator: David Carson, US EPA
  2:45 PM - 3:10 PM
Sandtown, DE - Richard Watson, Delaware Solid Waste Authority
  3:10 PM - 3:35 PM
New River, FL - Debra Reinhart, University of Central Florida
  3:35 PM - 4:00 PM
Yolo County, CA (EPA Project XL) - Ramin Yazdani, Yolo County Dept. of Public Works
  4:00 PM - 4:25 PM
Worcester Co., MD - Ken Kilmer, EA Engineering Science & Technology
  4:25 PM - 4:50 PM
Louisville, KY - Roger Green and Gary Hater, Waste Management, Inc.
  4:50 PM-5:15 PM
Williamson Co., TN - Mark Hudgins, Environmental Control Systems, Inc. and Jo House, Civil
and Environmental Consultants
  5:15 PM
ADJOURN
                                                A-l

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Thursday, September 7, 2000
  8:00 AM-8:10 AM
Opening Comments - John Martin, US EPA
                       Session: Design and Operational Issues
                       Topics: Where/When to Employ, Design Options, including facultative, anaerobic / aerobic
                       sequential designs, Operation
                       Discussion leaders listed below; discussion open to all
  8:10AM-9:30 AM
Discussion Leaders: Debfa Reinhart, University of Central Florida and John Pacey, EMCON
  9:30 AM-9:45 AM
 BREAK
                       Session: Monitoring Goals
                       Moderators: Wendy Davis-Hoover, US EPA and Bill Mahaffey, Pelorus EnBiotech Corp.
                       Topics: What, When and Where do we need to monitor, What are the best methods
                       Discussion leaders listed below; discussion open to all	
  9:45 AM-10:30 AM
Air/Gas - Discussion Leaders: Susan Thorneloe and Michele Laur, US EPA
  10:30 AM-11:15 AM
Groundwater/Leachate - Discussion Leaders: John Wilson and Michael Ebner, US EPA
  11:15 AM- 12:00 PM
Physical Stability - Discussion Leaders: Robert Koerner, Geosynthetic Research Institute
and Gregory Richardson, G. N. Richardson & Associates, Inc.	
  12:00 PM - 1:00 PM    LUNCH
                       Session: Monitoring Goals continued
                       Moderators: Wendy Davis-Hoover, US EPA and Bill Mahaffey, Pelorus EnBiotech Corp.
                       Discussion leaders listed below; discussion open to all
 1:00 PM -1:30 PM
Volume / Solids Degradation - Discussion Leaders: John Novak, Virginia Tech and Morton
Barlaz, NC State University	
 1:30PM-2:OOPM
Microbial Aspects of Refuse Decomposition - Discussion Leaders: Don Crawford, University
of Idaho and Mary DeFlaun, Envirogen, Inc.	
                      Session: Research Needs, Identification of Data Gaps for New Facilities and Retrofits,
                      Remediation
                      Topics: Monitoring, Operational design, e.g. water loading rates, stability, and Operational
                      changes at facilities
                      Discussion leaders listed below; discussion open to all
 2:00 PM-3:15 PM
Discussion Leaders: David Carson, US EPA and Debra Reinhart, University of Central
Florida
  3:15 PM-3:30 PM
BREAK
                      Session: Discussion on Landfill Regulations
                      Topics: Regulations and Rule changes Needed Operate Bioreactors
                      Discussion leaders listed below; discussion open to all
 3:30 PM - 4:30 PM
Discussion Leaders: Robert Dellinger and Dwight Hlustick, US EPA
  4:30 PM - 5:00 PM    Wrap-Up Session - John Martin, US EPA
                                                  A-2

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WORKSHOP ATTENDEE LIST

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                       U.S. ERA'S WORKSHOP ON LANDFILL BIOREACTORS
                                           September 6-7,2000
                                            Arlington, Virginia
                                        LIST OF ATTENDEES
Mark D. Ankeny
 PHONE: 505-822-9400
 FAX:   505-822-8877
 E-mail:   mankeny@dbstephens.com
                                       Daniel B. Stephens & Associates
                                       6020 Academy NE, Suite 100
                                       Albuquerque               MM
                  87109
Mike Apgar
 PHONE: 302-739-3689
 FAX:    302-739-5060
 E-mail:   mapgar@state.de.us
                                       DE DNREC / DAWM
                                       89 Kings Hwy
                                       Dover
DE
19901
Don Augenstein
 PHONE: 650-856-2850
 FAX:    650-856-2850
 E-mail:   iemdon@aol.com
                                       IEM, Inc. (Yolo County, CA Bioreactor Project—co-sponsor and
                                       consultant)
                                       4277 Pomona Ave.
                                       Palo Alto                  CA               94306
Janet Bader, Ph.D.
 PHONE: 580-436-8551

 FAX:    580-436-8703
 E-mail:   bader.janet@epa.gov
                                       USEPANRMRL
                                       Subsurface Protection & Remediation Division, Robert S. Kerr Environmental
                                       Research Center, 919 Kerr Research Drive
                                       Ada                      OK               74820
John Baker
 PHONE: 630-572-8679
 FAX:    630-218-1569
 E-mail:   jbakerl@wm.com
                                       Waste Management, Inc.
                                       720 Butterfield Rd.
                                       Lombard                  IL
                  60148
Morton Barlaz
 PHONE: 919-515-7676
 FAX:    919-515-7908
 E-mail:   barlaz@eos.ncsu.edu
                                       NC State University
                                       Civil Engineering Department, Campus Box 7908, Mann Hall
                                       Raleigh                   NC               27695-7908
Ben Blaney
 PHONE: 513-569-7852
 FAX:
 E-mail:   blaney.ben@epa.gov
                                       US EPA ORD NRMRL
                                       235,26 West Martin Luther King Drive
                                       Cincinnati                 OH
                  45268
Dirk R. Brunner
 PHONE: 207-775-5401 x3524
 FAX:    207-772-4262
 E-mail:   dbrunner@harding.com
                                       Harding Lawson ESE, a MACTEC Company
                                       PO Box 7050, 511 Congress Street
                                       Portland                  ME               04112-7050
                                                 B-l

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                        U.S. ERA'S WORKSHOP ON LANDFILL BIOREACTORS
                                           September 6-7,2000
                                            Arlington, Virginia
                                        LIST OF ATTENDEES
Lewis Bumpus
 PHONE:  615-790-0742
 FAX:    615-791-6968
 E-mail:   lewisb@williamson-tn.org
Williamson County
5750 Pinewood Rd.
Franklin
TN
37064
Kerry Callahan
 PHONE: 202-624-7884
 FAX:   202-624-7875
 E-mail:   swmkerry@sso.org
ASTSWMO
444 North Capitol Street, N.W., Suite 315
Washington                DC
                  20001
David Carson
 PHONE: 513-569-7527
 FAX:
 E-mail:  carson.david@epa.gov
US EPA ORD NRMRL
CHL, 26 West Martin Luther King Drive
Cincinnati                 OH
                  45268
Don L. Crawford
 PHONE: 208-885-6001
 FAX:   208-885-6518
 E-mail:   donc@uidaho.edu
University of Idaho
Dept. of Microbiology, Molecular Biology, and Biochemistry
Moscow                  ID                 83844-3052
David E. Daniel
 PHONE: 217-333-1497

 FAX:    217-265-0318
 E-mail:  dedaniel@uiuc.edu
University of Illinois
Department of Civil and Environmental Engineering, 1114 Newmark
Laboratory, MC-250
Urbana                   IL                61801
Wendy J. Davis-Hoover, Ph,D.
 PHONE: 513-569-7206

 FAX:   513-569-7879
 E-mail:   davis-hoover.wendy@epa.gov
US EPA ORD NRMRL
Remediation and Containment Branch, Land Remediation and Pollution Control
Division, 5995 Center Hill Ave
Cincinnati                 OH                45224
Mary F. DeFIaun, Ph.D.
 PHONE: 609-936-9300 x!50
 FAX:   609-936-9221
 E-mail:   deflaun@envirogen.com
Envirogen, Inc.
Princeton Research Center, 4100 Quakerbridge Road
Lawrenceville              NJ                08648
Christopher Dege
 PHONE: 703-308-2392
 FAX:   703-308-8686
 E-mail:   dege.chris@epa.gov
US EPA Office of Solid Waste
(5306W), 1200 Pennsylvania Ave., NW
Washington                DC
                  20460
                                                 B-2

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                       U.S. EPA's WORKSHOP ON LANDFILL B1OREACTORS
                                          September 6-7,2000
                                           Arlington, Virginia
                                        LIST OF ATTENDEES
Robert Dellinger
 PHONE: 703-308-8254
 FAX:
 E-mail:   dellinger.robert@epa.gov
USEPAOSWER
5306W, Ariel Rios Building, 1200 Pennsylvania Avenue, N. W.
Washington                DC               20460
Robert DeMarco
 PHONE: 410-222-6108
 FAX:    410-222-6105
 E-mail:   bob_demarco@hotmail.com
Anne Arundel County Department of Public Works
389 Bums Crossing Rd.
Severn                    MD               21144
Jane Denne
 PHONE: 702-798-2655
 FAX:
 E-mail:   denne.jane@epa.gov
USEPANERL                 •      	•- -  .
Environmental Sciences Division/ORD, P. O. Box 93478
Las Vegas                 NV                89193-3478
Raymond J. Dever, P.E., D.E.E.
 PHONE:  813-621-0080
 FAX:     813-623-6757
 E-mail:    rdever@scsengineers.com
SCS Engineers
3012 US Highway 301 North, Suite 700
Tampa                    FL
33619
Michael Ebner
 PHONE: 202-260-5397
 FAX:    202-260-7185
 E-mail:   ebner.michael@epa.gov
US.EPA Office of Water
1200 Pennsyvania Ave,, NW, MC 4303
Washington                DC
20460
Lisa Enderle
 PHONE: 703-676-7857
 FAX:    703-676-7945
 E-mail:   enderlel@saic.com
SAIC
1710 SAIC Drive, T3-3-1
McLean                   VA
22102
Felix Flechas
 PHONE: 303-312-6014
 FAX:    303-312-6044
 E-mail:   flechas.felix@epa.gov
US EPA Region 8
999 18th Street, Suite 500
Denver                   CO
80202
Roger Green
 PHONE: 513-641-5500 ext. 18
 FAX:    513-482-7967
 E-mail:   rgreen2@wm.com
Waste Management, Inc.
5701 Este Avenue
Cincinnati                 OH
45232
                                                B-3

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                       U.S. EPA's WORKSHOP ON LANDFILL BIOREACTORS
                                           September 6-7,2000
                                           Arlington, Virginia
                                        LIST OF ATTENDEES
Robert P. Grefe, P.E.
 PHONE: 608-266-2178

 FAX:    608-267-2768
 E-mail:   grefer@dnr.state.wi.us
Wisconsin Department of Natural Resources
Technical Support Section, Bureau of Waste Management, 101 South Webster
Street, Box 7921
Madison                  WI               53707-7921
Gary R. Hater
 PHONE:
 FAX:
 E-mail:   ghater@wm.com
Waste Management, Inc.
5701 Este Avenue
Cincinnati
OH
45232
Lynnann Hitchens
 PHONE: 513-569-7672

 FAX:   513-569-7585
 E-mail:   hitchens.lynnann@epa.gov
US EPA ORD NRMRL
Technology Transfer and Support Division, MS G75,26 West Martin Luther
King Drive
Cincinnati                 OH               45268
Dwight Hlustick
 PHONE: 703-308-8647
 FAX:
 E-mail:   hlustick.dwight@epa.gov
US EPA OSWER
5306W, Ariel Rios Building, 1200 Pennsylvania Avenue, N. W.
Washington                DC               20460
Virginia Hodge
 PHONE: '703-318-4621
 FAX:    703-736-0826
 E-mail:   hodgev@saic.com
SAIC
11251 Roger Bacon Drive
Reston
VA
20190
Sylvia Horwitz
 PHONE: 202-564-5511
 FAX:
 E-mail:   horwitz.sylvia@epa.gov
US EPA
2366A, Ariel Rios Building, 1200 Pennsylvania Avenue, N. W.
Washington                DC               20460
Michael F. Houlihan, P.E.
 PHONE: 410-384-333
 FAX:    410-381-4499
 E-mail:   MHoulihan@geosyntec.com
GeoSyntec Consultants
10015 Old Columbia Road, Suite A-200
Columbia                 MD
                  21046
Jo House
 PHONE: 615-333-7797
 FAX:   615-333-7751
 E-mail:   jhouse@cecinc.com
Civil and Environmental Consultants
624 Grassmere Park Drive, Suite 21
Nashville                  TN
                  37211
                                                 B-4

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                       U.S. EPA's WORKSHOP ON LANDFILL BIOREACTORS
                                           September 6-7,2000
                                            Arlington, Virginia
                                        LIST OF ATTENDEES
Charles B. Rowland
  PHONE:  215-814-2645
  FAX:    215-814-2601
  E-mail:    Howland.Charles@epamail.epa.gov
US EPA Region III
1650 Arch Street
Philadelphia
PA
19107
Mark Hudgins
 PHONE:  803-643-1755
 FAX:    803-643-1756
 E-mail:    markh@aerobiclandfill.com
Environmental Control Systems, Inc.
1120 Edgefield Highway
Aiken                    SC
                  29801
William Johnson P.E.
 PHONE: 770-952-8861
 FAX:
 E-mail:   BJohnson@arcadis-us.com
Arcadis Gerahty & Miller
2849 Paces Ferry Road, Suite 400
Atlanta                   GA
                  30339
Barnes Johnson
 PHONE: 703-308-8881
 FAX:
 E-mail:   johnson.barnes@epa.gov
US EPA
5307W, Ariel Rios Building, 1200 Pennsylvania Avenue, N. W.
Washington                DC               20460
Dr. Rathi Kavanaugh
 PHONE: 513-569-7458
 FAX:    513-569-7879
 E-mail:   kavanaugh.rathi@epa.gov
University of Cincinnati at EPA
Department of Civil and Environmental Engineering, 5995 Center Hill Ave.
Cincinnati                 OH               45224
Kenneth W. Kilmer
 PHONE: 410-584-7000
 FAX:    410-527-1068
 E-mail:   kwk@eaest.com
EA Engineering Science & Technology
11019 McCormickRd.
Hunt Valley               MD
                 21031
Robert M. Koerner, PhD, PE
 PHONE: 610-522-8440
 FAX:    610-522-8441
 E-mail:   robert.koerner@coe.drexel.edu
Drexel University & Geosynthetic Research Institute
475 Kedron Ave.
Folsom                   PA                19033
Dr. Fran Kremer
 PHONE: 513-569-7346
 FAX:
 E-mail:   kremer.fran@epa.gov
US EPA ORD NRMRL
481,26 West Martin Luther King Drive
Cincinnati                 OH
                 45268
                                                B-5

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                       U.S. EPA's WORKSHOP ON LANDFILL BIOREACTORS
                                          September 6-7,2000
                                           Arlington, Virginia
                                        LIST OF ATTENDEES
Michele Laur
 PHONE: 919-541-5256
 FAX:    919-541-0246
 E-mail:   laur.michele@epa.gov
US EPA OAQPS
MD-13
Research Triangle Park
NC
27711
Eugene Lee
 PHONE: 703-308-7270
 FAX:    703-308-8686
 E-mail:   lee.eugene@epa.gov
USEPAOSW
5306W, Ariel Rios Building, 1200 Pennsylvania Avenue, N. W.
Washington               DC               20460
Steven Levy
 PHONE: 703-308-7267
 FAX:    703-308-8686
 E-mail:   levy.steve@epa.gov
US EPA OSW
5306W, Ariel Rios Building, 1200 Pennsylvania Avenue, N. W.
Washington               DC               20460
Kelly L.Madalinski

 PHONE: 703-603-9901
 FAX:    703-603-9135
 E-mail:   madalinski.kelly@epa.gov
US EPA Technology Innovation Office, Office of Solid Waste and
Emergency Response
1200 Pennsylvania Avenue, NW (5102G)
Washington                DC               20460
William R. Mahaffey, Ph.D.
PHONE: 303-670-2875
FAX: 303-670-5139
E-mail: mahafrwr@worldnet.att.net
Pelorus EnBiotech Corp.
3528 Evergreen Parkway
Evergreen CO
80439 .
Stephen Mangion
 PHONE: 617-918-1452.
 FAX:    617-918-1291
 E-mail:   Mangion.Steve@epamail.epa.gov
US EPA
OSRR (HBS), One Congress Street
Boston
MA
02114
Alina Martin
 PHONE: 703-318-4678
 FAX:    703-736-0826
 E-mail:   martinali@saic.com
SAIC
11251 Roger Bacon Drive
Reston
VA
20190
John F. Martin
 PHONE: 513-569-7758
 FAX:
 E-mail:   martin.johnf@epa.gov
US EPA ORD NRMRL
CHL, 26 West Martin Luther King Drive
Cincinnati
OH
45268
                                                B-6

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                       U.S. EPA's WORKSHOP ON LANDFILL BIOREACTORS
                                           September 6 - 7,2000
                                            Arlington, Virginia
                                        LIST OF ATTENDEES
Karen Masbruch
 PHONE: 520-791-5414
 FAX:    520-791-5417
 E-mail:   kmasbrul@ci.tucson.az.us
Cityof Tucson   .•.„.;                     •  -._.:>   '   ..••;''.,••:'
Office of Environmental Management, Public Works Building, 201 .North Stone
Tucson         • ,         AZ               85726-7210
Andrea McLaughlin
 PHONE: 202-452-7717
 FAX:    202-452-5046
 E-mail:   andrea_mclaughlin@blm.gov
BLM
1849 C Street, NW, Mail Stop 504LS
Washington                DC
                  20240
Chris Menen
 PHONE: 215-814-2786
 FAX:
 E-mail:   Menen.Chris@epamail.epa.gov
US EPA Region HI
1650 Arch Street
Philadelphia
PA
19107
Steve Menoff
 PHONE: 630-505-9450
 FAX:    630-505-9454
 E-mail:   smenoff@emconinc.com
Emcon
603 East Diehl Road, Suite 123
Naperville                 IL
                  60563
John Novak
 PHONE: 540-231-6132
 FAX:   540-231-7916
 E-mail:   jtnov@vt.edu
Virginia Tech
419NewEngrBldg
Blacksburg
VA
24061
John Pacey
 PHONE:  650-375-1522
 FAX:    650-915-0763
 E-mail:    jpacey@emconinc.com
EMCON
400 South El Camino Real, Suite 1200
San Mateo                 CA
                  94402
Scott Palmer
 PHONE:  703-308-8621
 FAX:
 E-mail:   palmer.scott@epa.gov
US EPA Office of Solid Waste
5307W, Ariel Rios Building, 1200 Pennsylvania Avenue, N. W.
Washington               DC               20460
Robert Phaneuf         •   •
 PHONE:  518-402-8694
 FAX:
 E-mail:   rjphaneu@gw.dec.state.ny.us
New York State Dept. of Environmental Conservation (NY DEC)
625 Broadway, 9 th Floor
Albany                   NY                12233-7258
                                                  B-7

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                       U.S. ERA'S WORKSHOP ON LANDFILL BlOREACTORS
                                           September 6- 7,2000
                                           Arlington, Virginia
                                        LIST OF ATTENDEES
Dr. John H. Piggott
 PHONE: 804-698-4228
 FAX:   804-698-4234
 E-mail:   jhpiggott@deq.state.va.us
                              VA Department of Environmental Quality
                              629 East Main Street
                              Richmond                VA
23219
Debra R. Reinhart
 PHONE: 407-823-2315
 FAX:   407-823-5483
 E-mail:   reinhart@'mail.ucf.edu
                              University of Central Florida
                              College of Engineering and Computer Science, PO Box 162993
                              Orlando                  FL               32816-2993
Edward Repa
 PHONE: 202-364-3773
 FAX:   202-364-3792
 E-mail:   erepa@envasns.org
                              NSWMA
                              4301 Connecticut Ave., NW, Suite 300
                              Washington               DC
20008
Gregory Richardson
 PHONE: 919-828-0577
 FAX:   919-828-3899
 E-mail:   greg@gnra.com
                              G. N. Richardson & Associates, Inc.
                              425 N. Boylan Avenue
                              Raleigh                   NC
27603
Charles W. Ritchie, P. E.
 PHONE: 502-564-2225x204
 FAX:    502-564-4049
 E-mail:   Charles.Ritchie@mail.state.ky.us
                              Kentucky DEP
                              Solid Waste Branch, Division of Waste Management, 14 Reilly Road
                              Frankfort                  KY               40601-1190
Susan Schock
 PHONE: 513-569-7551
 FAX:    513-487-2513
 E-mail:   schock.sue@epa.gov
                              USEPA-Cinn NRMRL/TTSD/TTB
                              26 W. Martin Luther King Drive
                              Cincinnati                 OH
45268
Ken Skahn
 PHONE: 703-603-8801
 FAX:
 E-mail:
                              US EPA Superfund Program
                              5202G, US EPA Headquarters, Ariel Rios Building, 1200 Pennsylvania Ave,
                              NW
                              Washington               DC               20460
skahn.ken@epa.gov
Ed Skernolis
 PHONE: 202-639-1213
 FAX:    202-628-0400
 E-mail:   eskernolis@wm.com
                              Waste Management, Inc.
                              601 Pennsylvania Ave., North Building, Suite 300, NW
                              Washington               DC               20004
                                                B-8

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                        U.S. EPA's WORKSHOP ON LANDFILL BIOREACTORS
                                           September 6-7,2000
                                            Arlington, Virginia
                                        LIST OF ATTENDEES
Dr. David Slomczynski
  PHONE:  513-487-2861
  FAX:    513-487-7879
  E-mail:   slomczynski.david@epa.gov
University of Cincinnati at EPA
Dept. of Civil and Environmental Engineering, 5995 Center Hill
Cincinnati                 OH               45224
Susan Thorneloe
 PHONE:  919-541-2709
 FAX:    919-541-7885
 E-mail:   thorneloe.susan@epa.gov
US EPA Office of Research & Development
86 TW Alexander Drive (MD-63)
Research Triangle Park       NC               27711
W. Gregory Vogt
 PHONE: 703-471-6150
 FAX:   703-471-6676
 E-mail:   gvogt@scseng.com
SCS Engineers
11260 Roger Bacon Drive
Reston
VA
20190
Sherri L. Walker
 PHONE:  202-260-4295
 FAX:    202-260-3125
 E-mail:    walker.sherri@epa.gov
US EPA Office of Policy, Economics, and Innovation
(1802), 1200 Pennsylvania Avenue, N.W.
Washington                DC               20460
Scott Walker
 PHONE: 916-341-6319
 FAX:   916-319-7469
 E-mail:   swalker@ciwmbxa.gov
California Integrated Waste Management Board
1001 I Street, P.O. Box 4025
Sacramento                CA                95812
Rick Watson
 PHONE: 302-739-5361
 FAX:    302-739-4287
 E-mail:   rpw@dswa.com
Delaware Solid Waste Authority
1128 S. Bradford St., P.O. Box 455
Dover                    DE
                  19903
Richard Willey
 PHONE: 617-918-1266
 FAX:    617-918-1291
 E-mail:   willey.dick@epa.gov
US EPA Region 1
1 Congress Street, Suite 1100, MS HBS
Boston                   MA
                  02114-2023
John Wilson
 PHONE: 580-436-8534
 FAX:    580-436-8703
 E-mail:   wilson.johnt@epa.gov
US EPA ORD NRMRL
R.S. Kerr Environmetal Research Center, Box 1198
Ada                     OK
                  74820
                                                 B-9

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                      U.S. EPA's WORKSHOP ON LANDFILL BIOREACTORS
                                        September 6-7,2000
                                         Arlington, Virginia
                                     LIST OF ATTENDEES
Ramin Yazdani
 PHONE: 530-666-8848
 FAX:    530-666-8728
 E-mail:   ryazdani@dcn.davis.ca.us
Yolo County (CA) Planning and Public Works Department
292 West Beamer Street
Woodland                CA               95695
Kathy E. Young
 PHONE: 713-394-2234
 FAX:    713-394-2171
 E-mail:   kathy.young@wm.com
Waste Management, Inc.
4001 Fannin, Suite 4000
Houston                 TX
77002
                                             B-10

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         CASE STUDIES
              OF
BIOREACTOR LANDFILL PERFORMANCE

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                                    APPENDIX C

          CASE STUDIES OF BIOREACTOR LANDFILL PERFORMANCE
       Six case studies of bioreactor landfill research and demonstration projects were presented in
the Workshop by state government, local government, academia, and private industry:

•      Sandtown, Delaware - Delaware Solid Waste Authority (DSWA)

•      Florida Bioreactor Landfill Demonstration Project, New River Regional Landfill -University
       of Central Florida

•      Environmental Protection Agency (EPA) excellence and Leadership (XL) project - Yolo
       County, California

•      Worcester County, Maryland - EA Engineering Science & Technology

•      Outer Loop Landfill Bioreactor Studies, Louisville, Kentucky - Waste Management, Inc.
       (WMI) and the EPA

•      Williamson County, Tennessee - Environmental  Control Systems, Inc., and Civil and
       Environmental Consultants.

The following sections briefly describe these case study presentations.

C.1    SANDTOWN, DELAWARE - DELAWARE SOLID WASTE AUTHORITY

       The DSWA conducted a Test Cell Program in association with the EPA. This program began
in 1987 and tested a number of different liners and landfill systems. Site conditions throughout
Delaware consist of high groundwater and sandy soils so locally available cover materials have high
permeability.

       Two double-lined test cells were constructed and filled with household waste; four different
liners were tested. Flumes were constructed for stormwater control and measurement. Groundwater
monitoring wells were also installed.

       Test Cell 1 was constructed and operated as a wet cell. A leachate recycling field was
installed over the first waste lift.  The drainage layer consisted of 2 feet of sand. Recirculation lines
connected to a storage tank system.

       Test Cell 2 was a dry cell.   A geotextile was used for the drainage layer.  Two collection
system types were installed: with and without piping. Results found that the use of piping was
preferable.
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       There were concerns about hydraulic head buildup on the liner system. However, they were
unable to measure the hydraulic head, so it was believed to not exceed more than 1 foot.

       The goals of this study were to compare dry and wet landfills (i.e., typical landfill  and
bioreactor), and to conduct a full-scale test of a bioreactor landfill. The following aspects were
monitored and compared:

•      Leachate generation rates - more leachate was generated during dry cell operation than in the
       wet cell. This was possibly the result of permeability differences in the daily cover. After
       the final cover was installed on both cells, leachate generation rates became very similar, but
       the decomposition rate in the wet cell ended up being twice that experienced in the dry cell.

•      Leachate characteristics - leachate from both cells was very similar during the operational
       period.  Chemical oxygen demand (COD) was greater than 10,000 mg/L in the first year.
       After the final cover was installed 5 to 6 years later, COD significantly decreased to 500 to
       700 mg/L in the wet landfill,  and to approximately 200 mg/L in the dry  cell.

•      Moisture levels in the test cells - this proved difficult to measure. Lysimeters were installed
       in the waste and in the wells,  but the data obtained may be questionable. This points to the
       need for a reliable technique to measure moisture level.

•      Landfill gas generation rates - the sandy nature of the cover materials made it difficult to
       measure gas generation rates as well as was desired.  However, results indicated that gas
       generation in the wet cell was about an order of magnitude higher than in the dry cell.

•      Landfill gas characteristics were very similar between the two cells with methane consisting
       of about 50 percent of the gas.

•      Leachate recirculation system performance - limited data were available because such a
       small  leachfield was  used (50 feet by 50 feet) on top of the cell. These tests relied on
       horizontal rather than vertical liquid addition.

•      Liner performance - four types  of liners were studied. These liners were tested before and
       after use in the test cells. No significant deterioration of any kind was found.

•      Capping system performance - first a soil cap was tried, then a partial cap was placed on top,
       and finally side slopes were capped with polyethylene. Only a few inches of settlement were
       seen. However, the scale of the test was not large enough to draw conclusions from the data.

       The test included a simulated cap failure on the dry test cell. Once leachate characteristics
demonstrated decreased COD, an area of the cap was opened and several thousand gallons of water
were added over a few weeks.  Leachate changes were monitored during and after water addition.
The study found that the added water took about 45 days to reach the collection system, at which
time the leachate COD increased to about 30,000 mg/L. This result indicated that a real concern for
future performance of a landfill includes re-initiation of the bioreaction process following cap failure.
                                          C-2

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       Types of alternative daily covers tested included tarps and spray foam.

       The final soil cover had a permeability of IxlO"4 cm/sec. After placement, there was a
significant amount of leachate generated; in some cases, more leachate was generated than could be
used for recirculation.

       Other cover types tested included:

•      Astroturf placed over used carpet with tires used to hold down the material resulted in a
       slight, insignificant reduction in leachate production. Significant side slope penetration by
       liquids was experienced with this approach.

•      Polypropylene (black) was laid on the side slopes and reduced leachate generation by an
       order of magnitude.

       Late in the study, the test cells were opened and the waste excavated to determine the results
of decomposition. The organic decomposed material represented more than 50% of the waste mass
(by weight) in the wet cell, while the same material was less than 50% of the waste mass (by weight)
in the dry cell.

       Landfill mining was also examined in another study.  The leachate collection system in
another wet landfill (built in 1980) experienced a decline in leachate removal requiring excavation
into the cell to determine the nature of the problem and make repairs. This landfill had a polyvinyl
chloride  (PVC) liner  and  the leachate collection system consisted of septic pipe wrapped with
geotextile. Upon excavation, it was determined that the septic pipe was crushed by the weight of the
landfill waste and the  geotextile had severe biofouling.

       Upon excavation, the waste mass was found to be very moist in some areas and dry in others,
but no gushing liquid was encountered. A crude vertical recirculation system was found within the
waste mass that contributed to the moisture differences encountered.

       Waste material was screened upon excavation. The fines were used for daily cover.
Instances were encountered where waste within plastic bags showed no decomposition whatsoever
 (e.g., 10 year old green grass). This finding indicated that leachate was not distributed within the
 landfill as well as was desired.

       The decomposed waste resembled soil or compost.  The nondecomposed material was
 contaminated by leachate and was therefore unsuitable for recycling or other reuse.

       Test program conclusions included the following:

 •      If properly designed and constructed, bioreactor landfills are attractive alternatives to
       conventional landfills

 •      Use of tarps or foam for daily cover is promising
                                           C-3

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 •      Use of polypropylene for capping and liner is promising

 •      Geonets are preferable for leachate collection systems

 •      Trammeling is the preferred processing method for landfill mining

 •      The most useful recycled product mined from the landfills is daily cover, which has high
       costs but may be appropriate for certain applications.

 C.2   FLORIDA  BIOREACTOR LANDFILL  DEMONSTRATION PROJECT, NEW
       RIVER, FLORIDA - UNIVERSITY OF CENTRAL FLORIDA

       The Florida Bioreactor Landfill Demonstration Project has the following objectives:
•      Demonstrate full-scale use of bioreactor technology
•      Evaluate aerobic bioreactor technology
•      Compare aerobic and anaerobic processes
•      Control and measure all inputs and outputs.

The Florida Department of Environmental Protection is the primary funding source for this project.

       The landfill for this demonstration consists of the following:

•      Three cells with a composite liner

•      Leachate collection in one cell consists of sloped geomembranes; no piping is used

•      Recirculation of leachate and air in two of the cells

•      Leachate/air injection conducted through well clusters on 50 foot spacings and drilled to
       various depths

•      Permeable daily cover (10"s cm/sec).

       This is a retrofit because 75 feet of waste are already in place. Wells will be installed into
the existing waste mass using direct push technology as well as a new version of air-driven rotary
drill. This latter technique drilled very rapidly, but it was harder to take samples.

       Gas will be collected from the leachate collection system and from beneath the landfill cap
using positive displacement blowers to create a vacuum.  Trenches will be placed below the cap to
assist with gas collection. Collected gas will be brought to a flare and burned.
                                         C-4

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       This study will measure the following:

•      Leachate quantity and quality
•      Landfill gas quantity and quality
•      Waste properties
•      Settlement.

       Instrumentation will be placed to measure:

•      Head on liner (using 128 pressure transducers outside the waste area)
•      Leachate flow
•      Landfill temperature
•      Moisture content (through measured resistance).

       Upon receipt of the final permit (estimated to be December 2000), construction should begin
with recirculation beginning in 2001.  A large quantity of liquid will be added, followed by addition
of sufficient water over time to sustain the reaction. Groundwater and possibly stormwater runoff
will be used to supplement leachate for water addition as insufficient leachate is anticipated to be
generated. However, the State of Florida has put a ceiling on the amount of water allowed to be
added.

C.3   EPA PROJECT XL - YOLO COUNTY, CALIFORNIA

       Yolo County has a bioreactor landfill demonstration project under the EPA Project XL. This
project involves a 725-acre landfill with a 25-million cubic yard capacity, a single composite liner
system, leachate collection and removal, gas collection (with a co-located 2-megawatt power plant),
and a 15-acre storage pond for water/leachate. The landfill opened in 1975 and closure is anticipated
in 2021.

       Previous research at this site addressed the following objectives:

•      Demonstrate that water addition  can substantially accelerate waste decomposition and
       landfill gas generation

•      Monitor biological conditions in the landfill

•      Estimate the potential for landfill life extension

•      Better understand moisture movement in the landfill

•      Assess performance of shredded tires as drainage material

•      Provide data to EPA and the private sector
                                          C-5

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       The landfill cells used in this early research had the following characteristics:

       Two test cells (control and enhanced)
       Double composite liner with leak detection
       Compacted clay sidewalls
       Manholes to collect leachate
       Vertical gas collection system.
       Instrumentation was installed on 20- to 30-foot centers during waste mass emplacement.
Clay levees are placed around the cells to isolate the gas collection and leachate systems from the
rest of the landfill.

       The cover consists of shredded tires placed on top of a geotextile layer with a clay layer over
the tires. This technique creates a gas collection zone beneath the clay cover.

       Approximately 470,000 gallons of water were added in a manner similar to drip irrigation
over a two-year period.  Injection points were on 20-foot centers and were each surrounded by
shredded tires.
       Waste samples were obtained by coring. Results indicated that good moisture distribution
was achieved. However, the bottom portions of the landfill cells were generally found to be drier,
which indicated that more water could have been added.

       Gas generation was higher over time in the wet cell.  Within one year, substantial decreases
were seen in COD, total dissolved solids (TDS), and biological oxygen demand (BOD).

       Findings from these earlier studies indicated that:

•      Addition of water does promote the bioreaction resulting in accelerated decomposition and
       methane recovery

•      Significant settlement and leachate chemistry improvement can be seen after a short time
       (within 6 months)

•      Shredded tires perform well in support of landfill gas transfer and leachate injection.

       Under EPA Project XL, Yolo County will be conducting a full-scale demonstration that
builds on efforts conducted over the past 5 years involving many different funding sources.  This
demonstration project has the following goals:
•      Accelerate waste decomposition
•      Accelerate methane production and improve energy recovery
•      Verify improvement in leachate quality
•      Verify hydraulic head on the liner
•      Look at both aerobic and anaerobic conditions
                                          C-6

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•      Look at post-closure implications.

       For this demonstration, groundwater will be used to supplement the leachate used to increase
the moisture content of the waste mass. The liquid application rate will be about the same as for
previous efforts - approximately 10 gallons per minute on a 100-foot by 100-foot area. This is
roughly 13 million gallons of water for 400 tons of waste.

       The daily cover will consist of shredded green waste and a tarp rather than soil.

       The measurement system is quite extensive involving over 320 monitoring points in each
landfill cell.  A supervisory control and data acquisition (SCADA) system will be installed to
manage the instrumentation and the data collection. Such an extensive instrumentation system is
necessary to obtain the desired research data and to address concerns raised by regulatory agencies
(such as potential head on liner).  This can be very expensive - for example, 10 acres cost about $2
million to construct.

        Yolo County hopes to demonstrate the following in this project:

 •       Extended use of current site and reduced need for a new site
        Amount of gas that can actually be recovered for economical energy use
 •       Landfill mining opportunities and landfill cell reuse
 •       Improved leachate quality and reduced risk of groundwater contamination
 •       More rapid biodegradation and earlier stabilization of the waste.

 The methane generation is  a particular issue for this site. The production of electricity using the
 methane generated by the landfill results in higher NOx emissions. This is a concern because the
 landfill is located in a nonattainment area for air emissions regulation and control.

        Federal approval to begin water addition is anticipated to occur in November 2000 with cover
 system installation completed by February 2001 and liquid and air injection beginning April 2001.
 Data collection and reporting is expected to continue from July 2000 to July 2004.

 C.4    WORCESTER  COUNTY,  MARYLAND - EA  ENGINEERING SCIENCE  &
        TECHNOLOGY

        This demonstration project has been ongoing for about 9 years at an operating county landfill
 that receives approximately 300 tons per day of municipal solid waste. Recirculation began once
 the first lift of waste was emplaced and has continued throughout the life of the landfill.

        Such bioreactor landfills represent solid waste treatment rather than disposal, and involve
 the following:

 •      Long-term risk reduction
 •      Leachate treatment through recirculation
 •      Maximization of airspace through accelerated decomposition
                                            C-7

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  •      Long-term risk reduction through source treatment
  •      Closure and post-closure cost savings.

  In addition, landfill mining in conjunction with the above can offer significant benefits.

         This location receives 41 inches of rain a year so there is no lack of liquid. The landfill
  consists of four cells, each about 17 acres with a400,000-gallon aboveground storage tank to support
  recirculation through vertical recharge wells placed on 150-foot centers. This approach to liquid
  injection was selected  to keep these activities out of the way of daily operations.  Leachate was
  recirculated without any additional treatment or modification.

        Data collected between January 1991 and July  1997 showed the following:

        BOD dropped briefly after liquid addition, then peaked, then sharply declined to achieve
        baseline levels in about 18 months

 •      New waste addition resulted in BOD variation (increases)

 •      Fatty acid production increased and caused the pH to rise

 •      pH changes significantly reduced the metal-carrying capacity of the leachate with iron and
        chromium no longer coming out into solution

 •      Chlorinated volatile organic compounds (VOCs) significantly declined from 17 times the
        maximum contaminant level (MCL) to below the levels specified in the Safe Drinking Water
        Act, becoming nondetectable after about 3 years

 •      Certain gasoline constituents did not disappear and had variable but consistent presence,
        possibly from household hazardous waste and equipment operation in the landfill cell.

        These data indicate the following measures of the process rate for bioreaction completion:

 •       From BOD data - reaction completed in 4 years
 •       From the generation of insoluble metal complexes - reaction completed in 3 years
        From the chlorinated VOCs reaching baseline levels - reaction completed in 3 years.

       This project involved constant recirculation resulting in approximately two-thirds of the
leachate generated over 8 years being recirculated. In western and southwestern United States areas,
possibly all leachate can be recirculated.

       Quantification of the overall water balance was conducted including consideration of the
following:

•      All incoming waste moisture
•      Preferential flow  paths through the waste
                                          C-8

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       Difficulties achieving even moisture distribution
       Runoff
       Evapotranspiration
       Infiltration
       Waste field capacity
       Average waste receipt.

The water balance indicated the potential for 100 percent recycle of the leachate.

       This recirculation process has been operated since 1990. Recently, the feasibility of landfill
mining was examined and the utility of the remaining materials was evaluated for on-site and off-site
uses.  This investigation was conducted using a rotary trommel with 1-inch holes.  The material
removed resembled soil fines and represented approximately 75% of the material removed except
in the top 25 feet of the waste mass. Little degradation was encountered in that zone and is believed
to be due to uneven waste wetting.

       The humus-like material recovered in this excavation appeared suitable for use as a landfill
cover and nonlandfill uses might be possible. The reclaimed material had hazardous constituents
present at two to three orders of magnitude below the levels that would trigger classification of the
material as a hazardous waste. The reclaimed material met all human health risk-based limits for
industrial use, and met all requirements for residential reuse except for arsenic limits.

       A life cycle cost analysis was also developed. The scenario used in this analysis was to build
one cell to hold unusable residuals from material recovered out of six original cells. All undegraded
materials would go back into an active landfill cell.  No caps are used because each cell keeps getting
reworked. This analysis estimated a landfill life of 50 to 60 years.

       Key conclusions drawn from this study are:

•      There is potential for long-term savings in reduced monitoring

•      Significant reduction of long-term risk to the environment

•      Offsite  use of recovered, decomposed material can double the landfill site life if properly
       operated.
 C.5   OUTER LOOP LANDFILL BIOREACTOR STUDIES, LOUISVILLE, KENTUCKY
       -WMIANDEPA

       WMI has been evaluating landfill bioreactor technology at sites across the United States.
 WMI and EPA have developed a Cooperative Research and Development Agreement (CRADA) for
 joint bioreactor landfill research. Bioreactor research studies planned for the Outer Loop Landfill
 are anticipated to be among the first studies under this agreement.
                                           C-9

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        Over the next 2 years, WMI will be looking at aerobic, anaerobic, and facultative bioreactor
 landfills as compared to conventional municipal solid waste landfills.  This research effort is
 anticipated to be large enough and long enough to evaluate the economic and operational issues,
 especially the health and safety aspects of bioreactor operations.  This effort involves statistically
 based studies to generate credible data.

        The waste area at the Outer Loop Landfill is 400 acres. Each test and control cell involves
 about 6 acres.

        The operation of an aerobic-anaerobic landfill bioreactor will  cause rapid biological
 decomposition of easily degradable waste in the aerobic stage.  This bioreactor landfill will be
 constructed during waste placement and will have separate, dedicated leachate and gas collection
 systems.

        The objectives of the aerobic-anaerobic bioreactor study are to:

 •       Evaluate waste stabilization enhancement resulting from sequential establishment of aerobic
        and anaerobic conditions relative to waste stabilization in the control cells

 •       Demonstrate the feasibility  of implementing this technique in a commercially  viable
        operating scale.

        The facultative landfill bioreactor study intends to demonstrate control of nitrogen cycling
 in the landfill. Ammonia-containing leachate will be treated external to the landfill by nitrification
 to convert the ammonia to nitrate. The treated leachate will be introduced to a landfill cell where
 the nitrate will be used by facultative bacteria. This approach is expected to reduce the buildup of
 ammonia in the leachate, but may also reduce methane production.  Trenches will be used for liquid
 infiltration and there will be separate leachate and gas collection systems.

       The objectives of the facultative bioreactor study are to:

 •      Evaluate stabilization enhancement resulting from nitrate-enriched leachate application
 •      Assess commercial viability of the operation.

       Both studies will include replicate sampling and analysis. The studies will characterize:

•      Landfill gas and emissions
•      Leachate head on liner
•      Leachate production rates
       Waste temperature (daily)
       Waste settlement (quarterly)
       Volatile solids (annual)
       Biochemical methane potential (annual)
       Moisture content (annual)
       Waste density (annual)
                                           C-10

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C.6
pH (annual).

Critical measures will be:

Continuous gas production rates
CO2, CH4, O2, and balance concentrations (daily).

Noncritical measures include:
      ^

Nonmethane organic compounds (NMOCs) (quarterly)
Hazardous air pollutants (HAPs) (quarterly)
Surface emissions (twice per quarter)
Cellulose:lignin ratio (annually)
Carbon:nitrogen ratio (annually).
Project startup is anticipated for October 2000.

WILLIAMSON  COUNTY,  TENNESSEE - ENVIRONMENTAL  CONTROL
SYSTEMS, INC., AND CIVIL AND ENVIRONMENTAL CONSULTANTS
       The Williamson County landfill has a 6-acre footprint, a waste depth of approximately 40
feet, and nearly 70,000 tons of solid waste. This landfill is located in a rural site without access to
a publicly owned treatment works (POTW). The cell shape resembles  a truncated pyramid with
steep slopes and is lined with Subtitle D composite liner and an underdrain leachate, collection
system. Current head on the landfill liner averages less than one inch. The landfill cover consists
of 12 to 24 inches of highly compacted cover soil and 6 to 24 inches of mulch.

       The waste  mass had the following characteristics (based on initial characterization and
sampling data):
       29.7 percent average in-situ moisture content
       71 °F average temperature
       Average oxygen content of the gases ranging from 6 percent to 11.9 percent by volume
       Estimated biodegradable organic fraction of 6,900 tons
       15:1 carbon to nitrogen ratio.

       The objectives of this study include evaluation of the following: <

       Changes in waste characteristics following operation of the bioreactor
       Effectiveness of proposed air and leachate delivery systems
       Overall trend in leachate quality and quantity
       Variations in methane gas production
       Overall economic costs versus benefits
       Site water balance
       Impacts of bioreactor operation on stability of waste fill.
                                         C-ll

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       Lysimeters, tensiometers, and other instrumentation were installed to collect the data needed
to develop a full site water balance. The estimated water balance indicated that 3.8 million gallons
of water were needed to achieve a 40% moisture content; this represents approximately 54 gallons
of water per cubic yard of waste. There is an on-site weather station including a data logger to
continuously collect weather data, which can be compared with water level studies.

       Liquid is added at 30 gallons per minute. Wells (over 200 with over 190 thermocouples) were
placed on a 50-foot grid and nested at 10, 20, and 30 feet. Because this was a retrofit to an existing
landfill, a 10-foot safety factor was included in the drilling operations to avoid penetrating the lower
liner. Water sources include leachate from the landfill and storm water.  Other water sources may
be necessary to obtain sufficient quantities.

       The liquids are aerated in an aboveground mixing tank prior to circulation in the landfill via
an aboveground pipe network.

       Air is added to the waste mass. When blowers are operating, three readings of CO2,02, and
methane are taken weekly from each of 12 monitoring wells.

       Waste cellulose:lignin ratio readings are taken quarterly. Biochemical Methane Potential
(BMP) testing is currently underway to further examine the biodegradation process.

       Other measurements include:

•      Quarterly sampling of solid waste and leachate
•      Nutrient content within the waste (with supplemental nutrients added as necessary)
•      Air injection amounts and and leachate quantities injected and collected;
•      Weekly inspection of leachate head on liner.

       The initial theoretical water balance calculations indicate that biological processes, especially
in zones that become aerobic,  should biochemically produce a significant amount of the water to
help support the bioreaction process. Data collected from lysimeters during heavy rainfall events
indicated that infiltration is slope dependent. Good saturation was found in flat areas—the greater
the slope, the less inflow.

       The following geotechnical research is planned using data collected from this landfill:

•      Whether failure planes are created in the waste mass from injection of so much liquid?
•      What is the settlement rate?
•      Temporal and spatial changes in head on liner.

There are also plans to conduct slope stability analysis and to use this data to develop estimates of
waste mass strength.
                                          C-12

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&EPA
       United States
       Environmental Protection
       Agency

       National Risk Management
         Research Laboratory
       Cincinnati, OH 45268

       Official Business
       Penalfy for Private Use
       $300
Please make all necessary changes on the below label,
detach or copy, and return to the address in the upper
left-hand corner.

If you do not wish to receive these reports CHECK HEREEU;
detach, or copy this cover, and return to the address in the
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PRESORTED STANDARD
 POSTAGE & FEES PAID
        EPA
   PERMIT No. G-35
       EPA/625/R-01/012
       January 2002

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