EPA 600/R-17/205 | November 2017 | www.epa.gov/ord Post-Closure Performance of Liner Systems at RCRA Subtitle C Landfills Final Report Office of Research and Development National Risk Management Research Laboratory Land and Materials Management Division [This page intentionally left blank.] EPA/600/R-17/205 November 2017 Post-Closure Performance of Liner Systems at RCRA Subtitle C Landfills Final Report Materials Management Branch Land and Materials Management Division National Risk Management Research Laboratory Office of Research and Development Cincinnati, OH iii Foreword The US Environmental Protection Agency (US EPA) is charged by Congress with protecting the Nation’s land, air, and water resources. Under the 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, US EPA’s research program is providing data and technical support for solving environmental problems today and building the scientific 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 (NRMRL) is the Agency’s center for investigating technological and management approaches for preventing and reducing risks from pollution that threaten human health and the environment. The focus of the Laboratory’s research program is on methods and their cost-effectiveness for preventing and controlling pollution of air, land, water, and subsurface resources; protecting water quality in public water systems; remediating contaminated sites, sediments, and ground water; preventing and controlling indoor air pollution; and restoring ecosystems. NRMRL collaborates with public and private sector partners to foster technologies that reduce the cost of compliance and 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 US EPA’s Office of Research and Development to assist the user community and to link researchers with their clients. Cynthia Sonich-Mullin, Director National Risk Management Research Laboratory EPA/600/R-17/205 November 2017 Executive Summary Generation, transportation, treatment, storage, and disposal of hazardous waste are regulated under the Resource Conservation and Recovery Act of 1976 (RCRA), an act of Congress that gives the U.S. Environmental Protection Agency (EPA) authority to control hazardous waste from the “cradle-to-grave.” Specifically, Subtitle C of RCRA pertains to management of hazardous waste.0F1 This document is specifically focused on the long-term performance of landfill containment facilities (the “grave” in the above analogy) at RCRA Subtitle C facilities. Landfills are used for the environmentally protective disposal of hazardous waste, regulation of which is codified at 40 CFR Part 264, “Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities,” as published in various editions of the Federal Register since 1980. Sections of the regulation of relevance to this document are provided under Subpart N – Landfills (40 CFR §264.300 through .317) and Subpart G – Closure and Post-Closure (40 CFR §264.110 through .120). Post-closure care (PCC) requirements for Subtitle C landfills involve monitoring and maintaining the waste containment systems for a presumptive period of 30 years (per 40 CFR §264.117), or an extended or reduced period based on the demonstration that such adjustment is necessary or sufficient, respectively, for the protection of human health and the environment. Hazardous waste landfills have been permitted under RCRA Subtitle C since 1984, over 30 years ago, thus an increasing number of facilities around the country are approaching the end of their presumptive 30-year PCC period. Stakeholders requested the EPA to provide guidance on how and when it may be appropriate to make such certifications or other decisions regarding the ongoing status of their site. For its part, in 2016 EPA issued “Guidelines for Evaluating the Post-Closure Care Period for Hazardous Waste Disposal Facilities under Subtitle C of RCRA.” The aim of the study is to facilitate the discussion and decision-making processes by illustrating what data are needed, highlighting categories of useful data that are typically lacking, and recommending techniques and tools to complement the EPA’s “Guidelines for Evaluating the Post-Closure Care Period for Hazardous Waste Disposal Facilities under Subtitle C of RCRA”. The study investigates the field performance of engineered double-liner systems based on data from 9 Subtitle C landfills sites that have completed several years of PCC. It is noted that the document is not intended to address policy issues (such as how 1 Subtitle D of RCRA sets forth a framework for the management of non-hazardous solid wastes; however, management of non-hazardous solid waste is only of passing interest in this document. v EPA/600/R-17/205 November 2017 landfills may be managed, controlled, or regulated after PCC has ended) or to provide generic answers to defining conditions for ending PCC. Furthermore, also provides a follow-up for a broader EPA study published in 2002 entitled “Assessment and Recommendations for Improving the Performance of Waste Containment Systems.” The 2002 study reported on the performance of active and closed hazardous and non-hazardous waste landfill units around the country using data collected in the 1980s and 1990s. In updating that study, EPA is specifically interested in supplementing the previous dataset with a further 10–15 years of performance data from closed Subtitle C landfill units. Overall, the nine landfills yielded 45 individual double-lined closed units ranging in size from 1.4 to 11 acres, although most units were less than 5 acres in area. The oldest units in the study have been closed for over 29 years, while the newest are only 6 years into a PCC program. The thickness of waste in place above the liner ranged from 40 feet to 110 feet (average 70 to 80 feet). Amongst the 45 case study units, 11 different liner system designs and a further 11 different cover system designs are represented. These are combined into 13 unique containment system design configurations featuring commonality through the entire thickness of the unit from the top of the cover to the bottom of the liner. The discussion is interested in addressing the five broad research questions presented next. 1. How much leachate is generated in closed Subtitle C landfills and what are the effects of site location (climatic region), cover system design, or waste type on leachate generation rates? In general, field data showed a decline in leachate flow from the LCRS and LDS. In all cases, placement of cover led to a reduction in the LCRS flow rate, including where only 12 inches of intermediate cover soil had been placed. Rainfall has an effect on leachate generation, with higher LCRS flows recorded at the four wet sites and very low or negligible flows recorded at three dry sites. The incidence of precipitation as rainfall versus snowfall does not appear to affect leachate generation at the wet sites. An increasing trend in leachate generation was observed at some sites for a duration of time and was attributable to known operation and maintenance (O&M) issues affecting cover system performance. Erosion damage to cover systems was identified as a key issue affecting landfill performance in the post-closure period, with higher costs and effort associated with repairs needed during initial years of PCC before cover vegetation is fully established and the cover stabilized. Breaches in the cover system, particularly in the early years of PCC, could result in relatively long-term setbacks in terms of returning LCRS flow rates to expected levels once the cover is repaired. Routine cover inspection is essential for vi EPA/600/R-17/205 November 2017 identifying issues related to erosion damage, water ponding on the cover system, or other issues, as this facilitates timely maintenance and repair to reduce leachate flow volumes. Data from this study suggest the rate at which LCRS flow rate declines post-closure may be three to five times slower than reported in 2002 study or approximately an order of magnitude decrease in flow every 15–20 years. However, more field studies, preferably under a random selection procedure, are needed to validate this finding before recommendations for adjusting current industry projections and accruals for leachate management can be made. Furthermore, the rate of decrease in the leachate generation correlates with the maximum leachate generation at closure. In another word, cells that were wetter and had higher leachate flow at the time of closure continued to have relatively high flow well into their PCC period. This emphasizes the importance of good storm water control during the period of landfill operation and