vvEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: ?487.oi(83)
- " > ^ -~
TITLE: Landfills and Land Disposal Standards
APPROVAL DATE: 12-5-33
EFFECTIVE DATE: - 12-5-831
ORIGINATING OFFICE: office o
0 FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
OS WER OS WER OS WER
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PARTS 264 AND 265 SUBPART N - LANDFILL DOC: 9437.01(33)
Key Words: Landfill
Regulations: 40 CFR 264, Subparc N
Subject: Landfills and Land Disposal Standards
Addressee: Paul D. Duggar, P.E., AMI Engineering, 1015 Louisiana,
P.O. Box L539, Little Rock, Arkansas 72203
Originator: John H.' Skinner, Director, Office of Solid Waste
Source Doc: #9487.01(83)
Date: 12-5-83;
Summary:
The major problem with landfills is the lack of proper use of state-of-
the-art technology in the design, construction, and operation of the facilities.
EPA is considering a quality control program to cover these problems. In Julyr
1982, EPA issued some standards, to protect both surface and ground water through
performance and design requirements. Both above and below—ground landfills are
permitted if they meet the required objectives for protection of human health
and the environment.
It is not clear that there are substantial advantages in above-ground
landfills as compared to landfills of other elevations relative to the ground
surface. There are certain unique problems that are encountered in above-ground
landfills, e.g. steeper side slopes thus increasing the chance of erosion of
the final cover. In addition, such a landfill would not necessarily be isolated
from ground water and if the liner was breached, contaminants could reach the
ground water and such a failure might not be detected by the presence of leachate
on the ground surface.
Leachate collection and removal in above-ground landfills solely by gravity
is somewhat of an advantage. However, alternative methods such as pumps are
reliable for leachate removal. As far as land "reuse advantages^ ifis not clear
that above-ground landfills are an advantage. Re-vegetation and landscaping
techniques are equally available for landfills of different elevations. Further,
recreation areas would not be limited by the elevation of the land surfaces,
but rather by their slope.
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9^87.01 (83)
DEC 5 1983
Mr. Paul D. Cuggar. ?.£.
AMI Engineering
1015 Louisiana
P.O. Box 1539
Little Rock, Arkansas 72203
Doar Mr. Duggar:
Mr. Thonas has ashed n\<» to respond to your November 3,
l'?32> letter and the paper you enclosed entitled "Hazardous
Wast" Landfill Design."
We agree that the main problem with landfills is not the
inadequacy of current technology to prevent or minimize migra-
tion of hazardous wastes, but rather the lac* of proper use of
state-of-the-art technology in the design/ construction, and
operation of these facilities. In an effort: to reduce failures
at land disposal facilities, the Agency is considering a quality
assurance and quality control program covering a 1.1 ^««pects of
facility design, construction, operation, and maintenance as
part of the permit orocess.
>
On July 26, 198?, F?A issued land disposal standards (copy
enclosed) that ve believe protect both surface and ground water
through serf crmar.ce and desicrn recrui rements. In your paper,
.you suggest the concept of an above-ground landfill for safer
/disposal of hazardous waste. Our. regulations do not discourage
above-ground landfills." Above and below-ground landfills are
permitted if they zteet the required objectives for protection
of human health and the environnent.
It is not clear that there are substantial advantages in
above-ground landfills as compared to landfills of other eleva-
tions relative to the ground surface. In fact/ as with any
design, there are certain unique problems that are encountered.
For example, an above-ground landfill is likely to have st-ecer
side slopes than other designs, thus, increasing the problem
of erosion of the final landfill cover.
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