Waste Associations Want Performance-Based End to Post-Closure Care

"We believe that a one-size-fits-all approach to post-closure care is too prescriptive and does not account for the differences among landfills," said Darrell Smith, NWRA's president and CEO. "A performance-based standard offers wider applicability to achieve the same environmental protection goals."

The Solid Waste Association of North America (SWANA) and the National Waste and Recycling Association (NWRA) are jointly recommending a major shift in the process states use to determine when closed municipal solid waste landfills are ready to end post-closure care. They jointly called for the length of required post-closure care to be determined on a site-specific basis, rather than set by regulation at a single pre-determined number of years for all closed MSW landfills in all 50 states.

"NWRA and SWANA worked hard to develop this document together. We believe that a one-size-fits-all approach to post-closure care is too prescriptive and does not account for the differences among landfills," said Darrell Smith, NWRA's president and CEO. "A performance-based standard offers wider applicability to achieve the same environmental protection goals."

RCRA Federal Subtitle D established a post-closure care period of 30 years but allowed states to adjust the actual length of time up or down as they thought necessary to protect human health and the environment. The federal standard did not specify the data or methodology required to be used. EPA addressed a similar lack of specificity regarding post-closure care for hazardous waste landfills in 2016.

Public and private landfill operators want to close facilities and complete post-closure care in ways that protect human health and the environment. In practice, many state regulations don't establish what needs to be measured and what measurement results will demonstrate the required level of protection for a closed landfill. This leads to a uncertainty about when post-closure care requirements can be terminated and what is considered a stable condition.

"We want to encourage our association members to work with the state regulatory agencies to establish regional performance-based evaluation processes," said Jeffrey S. Murray, SWANA International Board past president. "Holding owners and operators to the same science-based standard of performance will instill more confidence in how potential risks have been mitigated through facility closure and lead to smoother transitions to custodial or long-term management and potential reuse."

The NWRA and SWANA documents include examples of multiple state PCC period termination programs, all of which include recognition that landfills should demonstrate stability in four areas: groundwater monitoring, landfill gas, leachate, and stability and cover integrity. SWANA's technical policy and NWRA's position statement are very similar and reflect the collaboration between the members of the two associations on this topic. Both clearly emphasize the need for supporting data and protection of human health and the environment through the process of evaluating a landfill's stability and readiness for the termination of post-closure care.

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