The graveyard for consumer, agricultural and industrial waste
Local governments in South Dakota manage several large regional landfills. When I was a kid a landfill was known as a dump. We kids had no idea how significant a dump would become in the stewardship of the environment and in consideration of the natural environment, human health and safety. We thought landfills around Brown County were an unperfumed place where we could hunt rats and find treasures. Temporibus mutata. The operation of a modern landfill, also known as a solid waste facility, involves environmental risks such as possible damage caused by landfill-based liquids leaking into ground water causing contamination of ground water.
Modern landfills are often constructed with liners and other collection systems designed to prevent contamination of the ground, ground water and the air. Despite this protection, in 2003 the U.S. Geological Survey (citing the EPA) opined that “all landfills eventually will leak into the environment.”
A landfill can be a large pit or sectioned-off area of surface land. One of the goals of a managed landfill is to protect the surrounding watershed and ground water. The liners or membranes are used to attempt to stop liquids from passing outside of the landfill.
The landfill liner is usually made of clay, which is bonded to or layered between some type of textile, according to a fact sheet from the U.S. Environmental Protection Agency. Lining is the first step, because water percolation through a landfill is inevitable.
Except in Indian Country and on certain federal lands, state government is responsible for regulating storage, treatment, and disposal of solid waste in South Dakota. The waste management world created a separate operating system from hazardous wastes which have their own rules. For solid waste systems the state provides technical assistance, issues solid waste permits (licenses to operate), conducts solid waste facility inspections and investigates solid waste disposal complaints.
Exotic wastes like ‘cannabis waste disposal’ and such mundane items as discarded tires are both regulated solid wastes in South Dakota. The state has administrative rules governing the collection, transportation, storage, processing and disposal of waste. The permit holder is however the party obligated to actually manage and control the facility and must prepare periodic reports showing the safety and efficacy of the landfill.
In South Dakota ground water monitoring systems should be located by the permit holder near a landfill. These are designed to determine ground water quality and to detect any migration of leachate constituents from a landfill. Leachate is liquid percolating from a landfill containing soluble substances or substances in solution. Leachate may include several different chemical constituents.
For safe drinking water standards the state has adopted ‘maximum contaminant level goals’ established by the EPA for chemicals that may be found in water. The EPA created a comprehensive list of chemicals. The EPA tells us that its list reflects the maximum level of a contaminant in drinking water below which there is no known or expected risk to health.
A landfill permit holder is to submit an annual report to the state summarizing and interpreting ground water monitoring data. The ground water data is to be statistically analyzed. Let us look at the 2022 Brown County report concerning ground water at its permitted landfill. I will provide some questions.
In the report the amount of manganese tested was higher than the limit suggested by the EPA. Was any remedial action recommended because of the test? The state has previously published a comprehensive discussion of manganese at the following link: https://danr.sd.gov/OfficeOfWater/DrinkingWater/manganese.aspx
And for a number of chemical tests, the Brown County report generalized the results instead of providing specific information on quantities. Why was it done this way? References to the EPA’s maximum contaminant levels are a preferred method. Several chemicals were listed in tested amounts higher than what the report called a ‘laboratory reporting limit’. ‘Laboratory reporting limits’ are values set in a particular report which may be based on project-specific reporting limits, regulatory action levels, etc. To confuse matters, laboratory reporting limits are not the EPA maximums discussed above. I did not see an explanation of the methodology used to establish laboratory reporting limits in the report. Additionally, both glyphosate and atrazine – chemicals found in common herbicides, are included in the EPA list discussed above and are found in the state’s groundwater chemical lists with designated maximum concentration limits. Why did the county not test for these chemicals?
Brown County could suggest that my concerns and questions are ill-founded. The county might argue I do not understand their testing protocols or reporting system. Indeed, that may be the case because in the conclusion to the report the county stated that there are no indications of a problematic buildup of fluid and/or leachate in the landfill.
