DRAFT
UCD - DOE National Superfund LEHR Site Remediation Issues

Submitted by

G. Fred Lee, PhD, MSPH, DEE
Technical Advisor, DSCSOC
G. Fred Lee & Associates

August 1995

Synopsis

Introduction

The regulatory agencies - US EPA, Cal EPA Department of Toxic Substances Control (DTSC), Central Valley Regional Water Quality Control Board (CVRWQCB) - and the responsible parties - University of California, Davis (UCD) and the Department of Energy (DOE) - will soon be formulating the UCD - DOE LEHR national Superfund Site remediation approaches and objectives. Because of the great importance of these issues to the public that has been impacted by the UCD - DOE past waste disposal practices at the LEHR site, the public, as represented by the Davis South Campus Superfund Oversight Committee (DSCSOC), will be an active participant in determining the adequacy of the site investigation, appropriateness of various approaches that are proposed for site remediation and in establishing the site remediation objectives. This report summarizes a number of issues that the public (DSCSOC), regulatory agencies, and UCD - DOE need to consider in developing an overall approach for LEHR Superfund site remediation.

Background

The mismanagement of hazardous and otherwise deleterious wastes at the LEHR site by UCD and DOE has had a significant adverse impact on the interests of a number of nearby neighbors -property owners. Past waste disposal practices at the LEHR site have significantly contaminated the soils and groundwaters at the site, represent a significant threat to off-site migration of hazardous and deleterious chemicals and have caused this site to be placed on the national Superfund list. This, in turn, has caused the US EPA - DOE to initiate a site investigation and remediation program. While this program was to be conducted under the classical US EPA Superfund RI/FS (remedial investigation feasibility study) approach, it has been decided by DOE, apparently with the concurrence of the US EPA and the state regulatory agencies, that an accelerated remediation program would be followed where remediation approaches and objectives are to be tentatively defined based on limited site investigation. This approach ("Phase III" approach) would then be implemented, where only the data needed to evaluate the feasibility and implementability of the initially selected remediation programs would be collected.

In the spring of 1995, without public participation, UCD - DOE, US EPA, DTSC and CVRWQCB developed a draft "Phase III" site investigation and remediation plan which is supposed to serve as a guide for the development of the LEHR site remediation program. This Phase III plan is to replace the RI/FS that was developed by DOE, US EPA and others in the fall of 1994. The RI/FS plan called for a detailed investigation of each of the waste management units (landfills, disposal pits/trenches, septic tanks and leach fields, cesspools, dry wells, etc.) at the LEHR site to determine the amount and types of waste constituents present in the waste management units and the extent to which waste-derived constituents have migrated from the waste management units through the soils, groundwaters and air of the region.

The so-called draft Phase III plan is in some undefined way to reduce the amount of investigation of the waste components within each of the waste management units and the migration of waste-derived components and their transformation products to the environment. While it is possible to remediate an area where wastes have been deposited without fully determining the characteristics of the waste-derived constituents that remain in the disposal area, it is not possible to develop a remediation program that will properly protect public health and the environment from the waste-derived constituents that have already migrated from the waste disposal area without a detailed investigation of the extent and characteristics of the migration.

Of particular concern is the contamination of the unsaturated and saturated parts of the aquifer system hydraulically connected to each of the waste management units. It will only be through the detailed types of investigations that were called for in the RI/FS in September 1994 that it will be possible to determine the hazard, extent and degree of aquifer and groundwater pollution that has occurred at the LEHR site. Without this information, it will not be possible to develop technically-valid, cost-effective approaches for polluted groundwater remediation that will protect public health and the other interests of those who now, or at any time in the future, own or use properties within the sphere of influence of the polluted groundwaters under the LEHR site.

At this time, it is not clear to the author (Dr. Lee) that there can be any significant difference in the Phase III investigations from those originally proposed in the RI/FS plan of September 1994 with respect to soil and groundwater pollution. This is an area that will need to be discussed at the RPM meetings.

Overall Objectives of LEHR Site Remediation

The overall objective of LEHR site remediation has to be the control of off-site migration of hazardous and/or deleterious chemical constituents and radionuclides that have been deposited at the LEHR site as wastes. An adjacent property owner should, after remediation, be able to use with confidence his/her properties at the property line in any manner that would be appropriate that could be done if UCD - DOE had properly managed the wastes that were deposited at the LEHR site. After remediation, there should no longer be a threat to the public health and welfare at the LEHR site adjacent property line from LEHR site deposited wastes. The public should have sufficient confidence in the remediation approach that has been conducted at the LEHR site so that they can feel free to use the properties at the LEHR site property line without fear of adverse impacts for as long as any residual wastes remain at the LEHR site.

It will be impossible to totally remove all waste-derived constituents from the LEHR site. LEHR site wastes, even after plausible remediation programs have been conducted, will always be a threat to public health, the environment and the interests of those who own or use properties near the LEHR site. The magnitude of this threat, however, can range from the current undefined level, where hazardous and deleterious constituents are now migrating toward adjacent properties and may have already polluted the groundwaters and the environment on or under adjacent properties, to providing very high degrees of waste-constituent containment with the associated required monitoring to ensure that there is little possibility of continued or future LEHR site waste-derived constituents causing harm or impairing the interests of those who own or use properties adjacent to or near the LEHR site.

Overall LEHR Site Remediation Performance Standard

It is highly disturbing to the author (Dr. Lee) that, in several previously developed DOE documents for the LEHR site investigation, including the March-April 1995 Phase III draft document, only a 30-year post-closure period after waste management unit remediation monitoring and maintenance is proposed to be practiced at the site. This 30-year post-closure maintenance and monitoring period that has been mentioned in DOE LEHR site documents is an apparent outgrowth of the RCRA 30-year post-closure care period for hazardous and so-called non-hazardous (municipal) solid waste landfills. Many of the hazardous or deleterious chemicals present as wastes at the LEHR site will be a threat to public health, groundwater resources, the environment and the interests of the adjacent property owners for as long as the wastes remain at the site. Any on-site management of wastes will obviously require ad infinitum post-closure monitoring and maintenance.

Further, any waste residues left at the site could, through the CERCLA periodic five-year review requirement, be subject to further investigation and remediation as new information is developed on the hazards that chemical constituents represent to public health and the environment. Lee and Jones-Lee (1994a) have discussed why it can never be assumed that the remediation of a Superfund site has rendered the site safe for unrestricted use in perpetuity unless all anthropogenic waste-derived constituents are removed from the site.

Lee and Jones-Lee (1992, 1993, 1994b) have discussed the significant error that was made by Congress and the US EPA in establishing RCRA with respect to the 30-year post-closure care mandated minimum. While many assume, as apparently DOE has done in the LEHR site investigation and remediation that all that is needed is 30 years of post-closure maintenance and care, a review of RCRA will show that:

"Prior to the time that the post-closure care period is due to expire, the Regional Administrator may extend the post-closure care period if he finds that the extended period is necessary to protect human health and the environment (e.g., leachate or groundwater monitoring results indicate a potential for migration of waste at levels which may be harmful to human health and the environment)."

There can be no question that since many of the wastes at the LEHR site will be a threat forever that the post-closure care period will need to be forever if public health, groundwater resource and environmental protection is to be achieved. Future US EPA regional administrators will find it necessary to extend the post-closure care period beyond the minimum 30-year period specified in RCRA.

The California Department of Health Services Title 22, Article 23 devoted to "Closure and Post-Closure for Interim Status and Permitted Facilities, 67211. Closure Performance Standard" states:

"The owner or operator shall close the facility in a manner that:

(a) Minimizes the need for further maintenance.

(b) Controls, minimizes or eliminates, to the extent necessary to protect human health and the environment, post-closure escape of hazardous waste, hazardous waste constituents, leachate, contaminated rainfall or waste decomposition products to the ground or surface waters or to the atmosphere."

Further, 67217 of Article 23 devoted to "Post-Closure Care and Use of Property" states:

"(a) This section pertains to facilities where hazardous waste will remain after closure. Additional requirements for such facilities are cited in Title 23 of the California Administrative Code.

(b) (1) Post-closure care shall continue for 30 years after the date of completing closure and shall consist of at least the following:

* * *

(B) Prior to the time that the post-closure care period is due to expire, the Department may extend the post-closure care period for permitted facilities if the Department finds that the extended period is necessary to protect human health and the environment (e.g., environmental monitoring results indicate a potential for migration of waste at levels which may be harmful to human health and the environment."

Further, the Water Resources Control Board Title 23, Chapter 15 mandates for all landfills including hazardous waste landfills (Class I), in Article 8, Section 2580(a), that:

"Classified waste management units shall be closed according to an approved closure and post-closure maintenance plan which provides for continued compliance with the applicable standards for waste containment and precipitation and drainage controls in Article 4 of the subchapter, and the monitoring program requirements in Article 5 of this subchapter, throughout the closure and post-closure maintenance period. The post-closure maintenance period shall extend as long as the wastes pose a threat to water quality."

There can be no legitimate issue that any remediation of the waste management units and contaminated soils and groundwaters associated with the LEHR site that does not completely remove all waste-derived constituents from the site and any areas that have been contaminated by site-associated wastes will require monitoring and maintenance of the residual wastes and contaminated soils for as long as they represent a threat which for many non-degradable constituents will be forever.

It is the author's recommendation to the DSCSOC that the only acceptable remediation approaches for the LEHR site be those that provide a very high degree of assurance that the remediation will, in fact, protect public health, groundwater resources, the environment and the interests of those who own or use properties near the site in perpetuity.

The author strongly recommends that the public oppose any stop-gap approaches such as the construction of RCRA landfills, slurry walls and covering of existing landfill units that will not provide for true protection of public health, groundwater resources and the environment for as long as the wastes, both hazardous and "non-hazardous" - deleterious, are present at the site.

It appears from the author's (Dr. Lee's) preliminary review of the draft Phase III document that DOE, UCD and the regulatory agencies responsible for developing this document have not properly considered the regulations that govern LEHR site remediation. This is readily apparent in the section of the Phase III document devoted to LEHR cost estimates for various alternatives for site remediation. Those costs associated with leaving residual wastes at the site significantly underestimate the true cost of this approach in failing to consider the in-perpetuity costs associated with monitoring and maintenance of any waste containment systems that are developed for on-site waste management.

It is totally inappropriate to compare the costs of removal and off-site transport and management of hazardous wastes with on-site management, as has been done, where only a 30-year post-closure care and maintenance period is considered. The true costs of on-site management will be far greater than the cost estimate in the draft Phase III document. It may, in fact, be cheaper for UCD and DOE to completely remove all waste constituents from the LEHR site for disposal at some other location where these wastes could be managed with other similar wastes in a more technically-valid, cost-effective manner than will be possible at the LEHR site. This is an issue that needs to be thoroughly reviewed in connection with developing remediation approaches for the LEHR site.

On-Site Landfills

One of the approaches that has been mentioned in several DOE documents for LEHR site remediation is the construction of an on-site RCRA landfill where the wastes from various waste management units such as the dog-pen structures and contaminated soils and various waste disposal pits, trenches, cesspools, septic tanks, etc. would be excavated from their current location and placed in an on-site RCRA landfill. It is presumed, although not specified in the documents provided, that this landfill would either be a Subtitle D landfill for so-called non-hazardous waste or a Subtitle C landfill for hazardous waste.

It is important to understand, as discussed by Jones-Lee and Lee (1993) and Lee and Jones (1981) that the US EPA classification of a waste as non-hazardous versus hazardous is highly arbitrary and has little to no technical merit. This classification approach, which is now based on the TCLP test, allows large amounts of highly hazardous substances to be placed in a Subtitle D landfill as a "non-hazardous" waste. It is now becoming widely recognized that Subtitle D landfills require the same degree of containment and post-closure monitoring and maintenance as Subtitle C landfills. Further, there are now about half a dozen states in the US that require the same degree of containment of so-called non-hazardous as hazardous waste. At this time, however, California is not one of these.

California, through Title 22, Article 29 devoted to "Landfills at Both Interim Status and Permitted Facilities. 67401. Design and Operating Requirements for Landfills at Permitted Facilities," requires that:

"(a) A landfill (except for an existing portion of a landfill) shall have:

(1) A liner that is designed, constructed and installed to prevent any migration of wastes out of the landfill to the adjacent subsurface soil or ground water or surface water at any time during the active life (including the closure period) and during the post-closure care period of the landfill. The liner shall include material that prevents wastes from passing into the liner during the active life of the facility.

* * *

(f) The landfill shall be designed, constructed, operated and maintained to enable the facility to meet the closure and post-closure requirements of Section 67409."

Title 23, Chapter 15, Section 2532 devoted to "Class I. Waste Management Units for Hazardous Waste" states further that:

"(a) Class I disposal units shall be located where natural geologic features provide optimum conditions for isolation of wastes from waters of the state.

(b) Geologic Setting (1)

New and existing Class I units shall be immediately underlain by natural geologic materials which have a permeability of not more than 1 x 10-7 cm/sec, and which are of sufficient thickness to prevent vertical movement of fluid, including waste and leachate, from waste management units to waters of the state as long as wastes in such units pose a threat to water quality. Class I units shall not be located where areas of primary (porous) or secondary (rock opening) permeability greater than 1 x 10-7 cm/sec could impair the competence of natural geologic materials to act as a barrier to vertical fluid movement."

Since the UCD LEHR site does not have natural waste containment permeabilities of less than 1 x 10-7 cm/sec, the construction of a Class I landfill would be difficult to achieve that would, in fact, protect groundwater quality for as long as the wastes are a threat. +++

Further, Chapter 15, formerly Subchapter 15, Article 1, Section 2510 (b)(1&2), which is applicable to all waste management units, states that:

"Unless otherwise specified, alternatives to construction or prescriptive standards contained in this subchapter may be considered. Alternatives shall only be approved where the discharger demonstrates that:

(1) The construction or prescriptive standard is not feasible as provided in subsection (c) of this section, and

(2) There is a specific engineered alternative that

(A) is consistent with the performance goal addressed by the particular construction or prescriptive standard, and

(B) affords equivalent protection against water quality impairment."

Article 4 of Chapter 15, in Section 2540(c), states:

"Class III landfills shall have containment structures which are capable of preventing degradation of waters of the state as a result of waste discharges to the landfills if site characteristics are inadequate."

Further, Article 5 of Chapter 15, Section 2550(a) states:

"The siting, design, construction, and operation standards contained elsewhere in this subchapter and in Title 22 of this code are intended to prevent adverse impacts on water quality."

It is clear that the construction of either the RCRA Subtitle D or Subtitle C landfill (Water Resources Control Board Class III and Class I landfills, respectively) must conform to the overall performance standard set forth in the regulations of, for Class III landfills, preventing the impairment of the beneficial uses of groundwaters under the landfill. For hazardous waste landfills, the containment structures must prevent any release of constituents from the landfill for as long as the wastes in the landfill represent a threat.

It is important to note that the California Porter-Cologne Act prohibits the contamination of the unsaturated - vadose zone by waste-derived constituents for as long as the wastes represent a threat, which are a threat to groundwater pollution. Therefore, any landfill that is constructed at the LEHR site for waste containment must be able to contain the waste-associated constituents from pollution of the vadose zone immediately under the landfill to a sufficient extent so as to be a threat to groundwater pollution for as long as the wastes in the landfill represent a threat. With few exceptions, the wastes at the LEHR site will be a threat effectively forever. Therefore, any on-site landfill for waste containment must be designed, constructed, operated and closed in such a manner as to provide a very high reliability of achieving the performance standard set forth in Title 22 and Title 23 of the state of California regulations.

Enclosed is a write-up that the author has recently developed that discusses the problems with currently permitted lined landfills for both so-called non-hazardous and hazardous wastes and, most importantly, recommends an approach that can, if reliably implemented, provide for public health, groundwater and environmental protection from the wastes for as long as the wastes represent a threat. The characteristics of any landfills that are constructed at the LEHR site should be the following:

The landfill should be lined with a double-composite liner where it is understood that the lower composite liner is a leak detection system for upper composite liner. If at any time in the future leakage occurs through the upper composite liner in the leak detection system between the two liners at a rate which if the lower composite liner were not present could pollute groundwaters under the landfill, i.e. a couple of gallons per acre per day, then the upper composite liner and landfill containment system will have be considered as having failed, and the landfill will have to be exhumed by DOE - UCD.

In addition to vertical groundwater monitoring wells spaced a no more than 50 feet apart at the point of compliance for the landfill which are nested in two sets to sample HSU-1 at just below the typical lower-most water table, mid-depth and near the bottom and HSU-2 at just below the beginning of HSU-2, mid-depth and near the bottom. It is understood that the 50-foot spacing at the point of compliance still may not detect leakage through the double composite liner system that could render the groundwaters unusable for domestic water supply purposes. It is, therefore, essential that the leak detection system associated with a double composite liner be used as a primary mechanism for determination of landfill containment system failure. The groundwater monitoring is a back-up system to that system.

The landfill should be covered with a leak detectable cover that is operated and maintained as long as the landfill exists.

A dedicated trust fund of sufficient magnitude shall be developed to provide for repairs and remediation under plausible worst-case scenario failure of the landfill containment system. This dedicated trust fund shall be of sufficient magnitude to also provide the monitoring and maintenance of this system in perpetuity. If at any time in the future insufficient funds are available, the adequacy of the funding needed shall be reviewed every five years, where at any time in the future it is found that there may not be adequate funds to meet these conditions, then additional funding will have to be provided by UCD and DOE.

Justification for adopting this approach for landfilling of any wastes that are left at the LEHR site stems from current state of California Department of Health Services Title 22 and state of California Water Resources Control Board Title 23, Chapter 15 regulations which explicitly require that groundwaters be protected from pollution by landfill for as long as the wastes are a threat.

Closure of UCD Campus Landfills

refer to paper

Slurry Walls

One of the proposed "containment" approaches that has been mentioned for the waste management units at the LEHR site is the construction of a slurry wall. Basically, a slurry wall consists of a trench in which a mixture of clay and other materials, depending on the type, is constructed down to some depth. This slurry wall would have a lower permeability than the natural strata of the area and thereby would impede the transport of waste-derived components in any lateral movement of the groundwater. There are a number of issues about the potential use of slurry walls that has to be resolved, however. First, for a slurry wall to be effective at the LEHR site it will have to be keyed into the low permeability clay layers which are down around 130 or so feet below the surface. Many slurry walls fail because of the interconnection with the low permeability layers at the base of the slurry wall are difficult to achieve and maintain.

A second factor to consider is that slurry walls themselves are not especially low permeability. They typically have permeabilities in the order of 10-6 cm/sec. Further, slurry walls are subject to a number of problems, such as desiccation cracking in the upper part of the wall near the water table.

Another fact to consider is that waste-derived constituents may move down through the low compacted clay layer below HSU-2 and pollute the lower aquifer. Since it would not be possible to construct a slurry wall in the second aquifer, there is always the potential for waste-derived constituents left in the disposal areas to move downward behind the slurry wall into the second aquifer and then laterally in that aquifer to production wells of the region.

Even if it could be certain that the vertical movement of the waste-derived constituents below HSU-2 through the clay layer would not occur, which is virtually impossible to prove, then it is possible to key the slurry wall into the clay layer below HSU-2 in such a way as there is no leakage at the point of keying, there is still the finite permeability of the slurry wall that has to be addressed. The wastes behind the slurry wall will always be a threat. Therefore, even under diffusion control situations there will be transport through the slurry wall. Dr. D. Gray, University of Michigan Civil Engineering Dept., has published several papers on this topic, pointing out that there can be significant fickian (SP?) diffusion of slurry walls against hydraulic gradients which eventually can lead to pollution beyond the slurry wall.

Overall, it does not appear that a slurry wall is a viable option for waste containment at the LEHR site. While it might slow down for a period of time the movement of wastes laterally through the slurry wall, it would not necessarily develop a situation that would be protective of public health and the environment for as long as the wastes are a threat. This performance standard has to be achieved if public health, the groundwater resources and the environment are, in fact, to be protected from further pollution at the LEHR site.

INSERT ABOVE: Several years ago I had the opportunity to become highly familiar with slurry walls through the work that I was doing in review of the potential for the LA County Sanitation Districts' Puente Hills Landfill proposed expansion to pollute the groundwaters in the San Gabriel Basin. The Puente Hills Landfill is constructed in a series of canyons where the LA County Sanitation Districts and the Regional Boards [plural?] have been constructing slurry walls across the mouths of the canyons in an attempt to prevent subsurface groundwater flow containing leachate from leaving the landfill area and entering the aquifer system of the San Gabriel Valley. The LA County Sanitation Districts and the Regional Board have found that previously constructed slurry walls have failed to prevent migration of leachate through them. The problem here is not leachate passing around the slurry wall, but leachate actually passing through the slurry wall. In an attempt to continue to use this landfill and especially to expand its operations, the LA County Sanitation Districts proposed to construct additional slurry walls downgradient of the existing failed slurry wall systems. As part of my review of this matter, I contacted several internationally recognized experts on slurry walls. Further, through the work that I did as Director of the Site Assessment and Remediation Division of the Hazardous Waste Research Center at the New Jersey Institute of Technology, I had a number of projects in my division devoted to slurry wall effectiveness that were conducted by investigators at several other universities. It became clear from my review of recent literature as well as the work that was done in the 1980's within my division of the Hazardous Waste Research Center that slurry walls cannot be relied on to prevent lateral migration of hazardous waste-derived constituents. The issues of concern are summarized below.

INSERT: One of the problems with using slurry walls is that the leakage through the walls to the greatest extent will be in areas of higher permeability. These areas, however, may not extend for long distances in the slurry walls. This means that there can be a number of fingers of polluted water passed through the slurry wall. Monitoring for these fingers is virtually impossible to do with a high degree of reliability.

Capping of Existing Landfills

There is discussion in the various DOE documents concerning possible remediation approaches which include the capping of existing landfills and waste management units. The basic premise of this approach is that if the moisture entering the landfill can be prohibited, then it would be possible to stop leachate generation and transport out of the landfill into the underlying aquifer. There are discussions in the Phase III document that rather than using a RCRA cap on the existing landfills, a less expensive could be used. While the properties of the less expensive cap are not defined, they certainly could be less effective in preventing moisture from entering the landfill, generating leachate which could then be a continuing a source of groundwater pollution beneath the landfill and laterally from it. Until recently all approaches for capping landfills only reduce the rate at which leachate is generated within the landfill. While it is possible to construct a landfill cover using flexible membrane liners which will be water tight at the time of construction, over time the FML will develop cracks, tears, holes which will allow moisture to enter the landfill while the original design break (???). One of the severe problems associated with the design of RCRA landfill covers is that the low permeability layer which is the key layer for preventing moisture from entering the landfill is buried below several feet of topsoil and a drainage layer. Therefore, visual inspection of the cover does not reveal the areas where moisture can enter the landfill and generate leachate. It is my recommendation that any capping of landfills be done with leak detectable covers and that a dedicated trust fund of sufficient magnitude to operate and maintain that cover in perpetuity be developed by DOE - UCD to ensure that at no time in the future will a situation develop where the leak detectable cover cannot be operated and adequately maintained. Failure to adopt this approach can readily lead to an inappropriate approach for waste containment, since, at best, it only postpones when further groundwater pollution occurs. The public who own or use properties near the LEHR site as well as those within the sphere of influence of it are entitled to this degree of protection.

INSERT ABOVE: About two years ago the first of what are now several commercially available leak detectable covers was introduced to the market. There are two firms that the author is aware of that have such covers for landfills that appear to provide high degrees of prevention of moisture into the landfill for as long as the wastes represent a threat. The key to successful operation of such covers is obviously the ability to reliably operate the leak detection system and when leaks are found, promptly replace the cover. (end of insert).

Lined Landfills for Waste Containment

One of the possible remediation approaches for the LEHR site is the construction of a RCRA landfill for containment of waste-derived constituents and contaminated soils that are currently located within and near waste disposal areas. The author, Dr. Lee, has been involved with landfill pollution of groundwaters and research on landfill liners' ability to prevent pollution beginning in the mid-1960's. In the early 1970's he initiated research in cooperation with the US EPA national groundwater research laboratory in ..... Oklahoma on the impact of organics on clay liners that were used for landfills and disposal pits - lagoons. He and his graduate students first demonstrated in the mid-1970's that the concentrated organic solutions could impact the integrity of plastic layers that serve as landfill liners, causing them to desiccate, crack and fail to provide even minimal protection against leakage of leachate produced in the landfill through the liner system into the underlying groundwater system. In the 1980's he became active with support by Gundle Lining, Inc. in evaluating the ability of HDPE liners to prevent leachate migration through them. In the early 1980's he became highly involved in reviewing the US EPA then-proposed Subtitle C landfills as a reliable location for managing hazardous wastes. He has continued to be active in that area through this time. He has also been active in evaluating the US EPA Subtitle D landfills to prevent pollution by municipal landfill leachate for as long as the wastes in the landfill represent a threat.

Dr. Lee has published extensively on hazardous and so-called non-hazardous waste landfills' ability to protect public health, groundwater resources and the environment from hazardous and deleterious chemicals associated with the wastes for as long as the wastes represent a threat. Appended to this statement is a list of Dr. Lee's recent papers and reports on this topic.

Dr. Lee has been an invited lecturer for the American Chemical Society on landfill issues for about 10 years. Further, he has presented one- and two-day short-courses on landfill issues through the National Groundwater Association, the American Society of Civil Engineers, the National Water Resources Association and University of California Extension Programs at Davis, Berkeley, Santa Barbara, Riverside and Los Angeles. Several of Dr. Jones-Lee's and Dr. Fred Lee's papers on landfill issues are appended to this statement, including preprints of two papers that have been recently completed by Drs. Jones-Lee and Lee concerned with the design of hazardous and non-hazardous landfills and landfill closure.

The bottom-line issue is that minimum RCRA Subtitle C and D landfills of the type that can be permitted will only likely postpone when groundwater pollution occurs. The liner systems that are used, whether single or double composite, will ultimately fail to prevent leachate from passing through them and entering the aquifer system below the landfill. The groundwater monitoring system that used at Subtitle C and D landfills where vertical monitoring wells spaced hundreds to a thousand or so feet apart at the point of compliance for monitoring has a low probability of detecting pollution of groundwater before widespread pollution occurs.

to ensure that the remediation approach for a particular waste management unit protects public health and the environment from any residual wastes present at the site.

References

Jones-Lee, A. and Lee, G.F., "Groundwater Pollution by Municipal Landfills: Leachate Composition, Detection and Water Quality Significance," Proceedings of Sardinia '93 IV International Landfill Symposium, Sardinia, Italy, pp. 1093-1103, October (1993).

Lee, G.F. and Jones, R.A., "Application of Site-Specific Hazard Assessment Testing to Solid Wastes," In: Hazardous Solid Waste Testing: First Conference, ASTM STP 760, ASTM, pp 331-344 (1981).

Lee, G.F. and Jones-Lee, A., "Municipal Landfill Post-Closure Care Funding: The 30-Year Post-Closure Care Myth," Report of G. Fred Lee & Associates, El Macero, CA, 19pp, (1992).

Lee, G.F. and Jones-Lee, A., "Landfill Post-Closure Care: Can Owners Guarantee the Money Will Be There?", Solid Waste and Power, 7(4):35-39 (1993).

Lee, G.F. and Jones-Lee, A., "Does Meeting Cleanup Standards Mean Protection of Public Health and the Environment?," IN: Superfund XV Conference Proceedings, Hazardous Materials Control Resources Institute, Rockville, MD, pp. 531-540 (1994a).

Lee, G.F. and Jones-Lee, A., "Landfilling of Solid & Hazardous Waste: Facing Long-Term Liability." IN: Proceedings of the 1994 Federal Environmental Restoration III & Waste Minimization II Conference, Hazardous Materials Control Resources Institute, Rockville, MD, pp. 1610-1618, April (1994b).

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