The Qualifications of a RCRA Subtitle D Landfill

Many of us have the luxury of not having to think about waste. At most, we put trash in designated receptacles—it’s very much a throw away and forget endeavor. And yet, our country today enjoys a far cleaner environment than what you would’ve seen between the 1950s and 1980s. What changed? Regulations. Two, to be specific: The Solid Waste Disposal Act as well as the Resource Conservation and Recovery Act. These acts enacted a series of regulations that now mandate the treatment of waste, defining everything from how we store waste to how we eventually close landfills to minimize future infiltration to the waste mass and collect gases produced by the landfill.

For contractors interested in breaking into the waste disposal industry, understanding how to design a landfill closure system that meets each qualification for a compliant cap is one route toward winning a competitive bid. Read on to learn the history of RCRA Subtitle D landfill compliance, why it has become the benchmark for many landfill closure projects, and how partnering with the right manufacturer can set you on the right path.

A brief history of waste

America at the turn of 20th century, following the second industrial revolution, began catering to the modern consumer. It was a boom triggered by techniques like assembly line manufacturing practices implemented at Ford Motors and elsewhere. Assembly lines massively increased industrial output and surged a demand for raw goods like coal and steel. While the new manufacturing boom went on to change the tide of World War II, its byproducts also contributed to acid rains and smog across the country.

By the 1950s, the pollution was so widespread that sources of freshwater were no longer safe for drinking or swimming. Landfills but more realistically “dumps” that were operated prior to regulations, built with little oversight, began obstructing the landscape, spoiling the land and the water while becoming vectors for disease. By the 1960s, landfills were known for being safe habitats for rats, flies, mosquitoes, and other vermin and were susceptible to fires that would go onto cause extensive damage to surrounding areas (1).

The initial effort to curb waste in America manifested as the Solid Waste Disposal Act (SWDA) in 1965. While the changes did bring about immediate benefits over the next few decades, manufacturing began evolving to include pharmaceuticals and other compounds with potentially dangerous side effects at higher concentrations. These new threats led to the Resource Conservation and Recovery Act (RCRA) in 2001. RCRA has become the driving force behind modern waste disposal practices in the United States.

RCRA at a glance (2)

• Manages 2.5 billion tons of solid, industrial, and hazardous waste
• Oversees 6,600 facilities with over 20,000 process units in the full permitting universe
• Works to address more than 3,700 existing contaminated facilities needing cleanup, and reviewing as many as 2,000 possible facilities
• Provides $97.3 million in grant funding to help states implement authorized hazardous waste programs
• Provides incentives and opportunities to reduce or avoid greenhouse gas emissions through material and land management practices.

Maintaining and capping a RCRA Subtitle-D compliant landfill

RCRA establishes the framework for a national system of solid waste control. Subtitle D of RCRA regulates the disposal of non-hazardous solid waste and bans open waste dumping. RCRA also sets the minimum federal criteria for the operation of municipal waste and industrial waste landfills, including design criteria, location restrictions, financial assurance, corrective action (cleanup), and closure requirements. States are deeply involved with the enforcement of RCRA Subtitle D, implementing regulations and sometimes creating even more stringent requirements compared to subtitle D. In the absence of an approved state program, the federal requirements must be met by waste facilities.

By the early 2000s, the Environmental Protection Agency (EPA) created a robust set of protocols for conducting compliance and packaged it into a management practice and reviewer checklist with seven categories: general, storage/collection, recycling, non-municipal solid landfill site, thermal processing facilities, and disposal of refuse from outside the United States.

Meeting and exceeding Subtitle D Landfill regulations with AGRU

According to Subtitle D, municipal solid waste landfills are subject to specific final cover design requirements outlined in regulation 40 CFR 258.60(a) and 258.60(b). According to these rules, the final cover system should be designed to minimize infiltration and erosion by meeting several criteria (3).

First, the cover system should have a permeability less than or equal to the permeability of any bottom liner system or natural subsoils present, or a permeability no greater then 1 x 10-5 cm/s, whichever is less. It should minimize infiltrations through the closed MSWLF by use of an infiltration layer that contains a minimum 18 in. of earthen material. Finally, erosion of the final cover should be minimized through the use of an erosion layer that contains a minimum 6 in. of earthen material that is capable of sustaining native plant growth.