Is Your Landfill's Environmental Monitoring Airtight?

Robert L. Westley and Larry E. Ruiz

Proper environmental landfill monitoring is a three-pronged attack. Just because you sample data and employ staff members whose job descriptions include this duty does not mean that your procedures are effective.

The amount of data and number of permits for solid waste facilities continue to rise. In some instances, the increase in monitoring conditions being managed starts off slowly, but quickly can become overwhelming.

In a survey of six solid waste facility owners (see table), one of the re-spondent was amazed at the number of data collection sites - 300 per quarter - that his staff visits to meet their permit needs. Approx-imately 1,300 data values are generated from their quarterly sampling - all which require handling, checking, analysis, interpretation and re-porting.

These data cover more than 10 landfills - active and closed - and are related to about 30 permits and/ or consent orders with many conditions in each. This owner's solution: an environmental manager and staff with the primary function to ensure that each site's environmental conditions remain in compliance with permit conditions and to confirm that site operations are not negatively impacting public health and welfare.

Based on the survey results, you should add an environmental manager to your staff if you do not already retain one, or at least hire a consultant to manage the collected data. Even if your data management activities are limited, adding a manager will still be worth the investment because as the manager's activities increase, your facilities ul-timately will too. The manager's knowledge will assist in negotiating with regulatory agencies, assessing your facilities' environmental impact and reviewing the environmental consultants' work.

Remember, environmental monitoring is crucial to your facility's continued operation.

Data: Collect Early

Do not wait until something goes wrong to collect environmental data. Those who collect the right data from the start can accomplish several objectives:

* developing data that represent the environment before the facility's establishment;

* keeping the facility in compliance with its permit conditions;

* knowing whether too many/few data are collected;

* knowing whether the operations have or may have detrimental effects on human health and welfare;

* defending against unfounded complaints; and

* monitoring conditions so that problems can be corrected early and cost-effectively.

To accomplish these goals, collect the necessary data to meet your permit's conditions and give yourself adequate information to assess the environmental effects of your landfill activities.

Frequently collect the obvious and easiest data. If you are not collecting the information required to meet your permit, collect the additional data.

It sounds simple, but many owners fail to pay attention to the data collected. These data are essential tools in ap-prising landfill conditions. For example, you should collect leachate sump fluid levels and leachate flows daily and keep an active plot with respect to time. Plot the identified levels and flows which are acceptable. Routinely update and review the plots to confirm that data are within acceptable limits.

Good, Bad Or Ugly?

The following fictional case studies illustrate three de-grees of environmental monitoring at landfills. Where does your facility stand?

The Good

This owner employs a full-time environmental manager and has an approved water quality monitoring program that includes groundwater monitoring wells plus surface water sampling locations. Samples are collected manually on a semi-annual basis and sent to an off-site laboratory for analysis.

The water quality parameters must meet specific permit requirements. The lab provides the results, the data are recorded in paper files and entered into a database for recording and analysis of each parameter. Before being passed to the facility's environmental consultant for review, the data are plotted and printed graphically for easy assessment.

This facility is starting to include historical data into the database to analyze long-term trends. With the exception of a few inorganic parameters in the background water quality, the data show the facility is in compliance with its environmental permit. Some long-term water quality trends are being watched for possible compliance issues and assessing if remedial actions will be needed.

The Bad

This owner employs a full-time environmental manager who also is responsible for numerous other landfills under the same ownership. The facility has an approved operation permit with specific conditions limiting landfill leachate levels. A field technician collects leachate level data daily and records on paper. The data indicates that levels are higher than allowed by the permit for several years, but no action is taken.

Although the data were properly collected, reviewed and recorded, they were not properly analyzed. As a result, the regulatory agency or-ders the owner to bring the facility into compliance. Because of the owner's neglect, the facility incurred substantial expenses related to retrofit construction to bring the leachate levels within its operating permit's limits.

The Ugly

This owner does not employ an environmental manager but has two full-time staff environmental engineers who oversee several landfills. The facility has an approved operation permit with specific conditions for off-site discharge to meet Class III water quality standards. Data are collected quarterly with manual equipment by a field technician and sent to an off-site laboratory for analysis.

After several years of operations, the permitting agency begins to question the quality of surface water being discharged off-site from the facility. The facility's administrator indicates the facility is in compliance, and offers the data to prove it. However, upon review of the data and lack of cooperation from the fa-cility personnel, the permitting agency requests assistance from the federal government for possible illegal discharge.

The owner spends hundreds of thousands of dollars in legal and en-gineering fees, millions of dollars in remedial actions and hires a new ad-ministrator.

Reap The Benefits

Whether you rank in the "good," "bad" or "ugly" category, managing, collecting data and attentiveness should be a landfill facility's priority to ensure that environmental effects are known and understood. The ideal facility will be kept in compliance with permit conditions and, when problems arise, have sufficient data on hand to plan corrective ac-tions.