Post-Closure Care Terms – RCRA Subtitle D

June 10, 2019

The EPA Resource Conservation and Recovery Act (RCRA) requires landfill operators to maintain post-closure care for 30 years, though states will adjust the term according to when they determine ending this care will not threaten human health or the environment. Industry stakeholders say it’s not enough guidance because it does not provide how states should assess for impact on human health or the environment, nor how to determine when to transition from active post-closure care to custodial care. Regulators tend to default to an extension of terms. Again data collection plays a significant role in determining the post-closure care term.

“The whole purpose of the post-closure care term is to provide enough time for landfills to become stable. One way to assess is by determining if functional stability has been achieved, which entails looking at performance metrics like leachate management, settlement, landfill gas control, and groundwater monitoring,” says Bob Gardner, of SCS Engineers.

Looking at these metrics, once it’s determined that functional stability has been achieved, these active systems may be able to be turned off, with only passive controls like cover remaining in place.

Monitoring may be done less frequently or not at all. “EPA acknowledges that back in the 1980s, it did not know how systems, primarily liner systems, would perform under new Subtitle D rules. But based on monitoring of these systems over the past 25 years, we know that they perform well to prevent migration of contaminants to groundwater,” says Gardner.

Read the Waste360 article Stakeholders Call for More Certain Landfill Post-closure Care Terms

Investigate why over 600 landfills use SCS eTools® to track, report, and store important data.

 

 

 

 

Posted by Diane Samuels at 6:00 am
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