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TYPES OF LANDFILL DISPOSAL
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Landfills
are disposal facilities where hazardous and other solid waste are placed into the land. Landfills designed according to RCRA rules must contain systems to collect contaminated surface water run-off as well as synthetic liners below and around the landfill.
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Surface Impoundments
are depressions or diked areas where solid waste can be stored, disposed of or treated. Pits, ponds, lagoons and basins are all forms of surface impoundments.
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Waste Piles
are accumulations of solid waste, sometimes used as disposal sites and sometimes as storage facilities.
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Land Treatment
is a disposal process in which solid waste is applied on top of or mixed into soil. Land application or land farming facilities are examples of land treatment.
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Source: Environmental Protection Agency, Solving the Hazardous
Waste Problem: EPA's RCRA Program (Washington, D.C., November 1986).
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At the bottom of the TCEQ's hierarchy of hazardous waste management methods is
land disposal, be it in a landfill, surface impoundment, land treatment units, or waste piles. Landfills and other forms of land disposal are controversial for a simple
reason: past and present experience has shown that such facilities can eventually leak hazardous materials that can contaminate both the nearby soil, surface water, and groundwater.* The Industrial and Hazardous Waste Division of the TCEQ reports that there are 83 industrial facilities with hazardous
waste land disposal units subject to groundwater detection monitoring programs and some 180 facilities which must report groundwater monitoring to the Texas
Commission on Environmental Quality *. Between 1989 and 2002, industrial
hazardous-waste disposal facilities, or industrial unauthorized discharges of wastewater, were responsible for 538 cases of groundwater contamination -- including 26
new cases in 2002 -- that have yet to be cleaned up.*.
Texas does not depend on landfills for hazardous waste disposal as much as some
states. In 1999, only 40,000 tons of hazardous waste -- less than one percent -- was managed in on-site landfills, and only 3,365
tons of Texas-generated hazardous waste was disposed at off-site commercial facilities.* Two commercial landfills are
currently receiving hazardous wastes in Texas—Waste Control Specialist in Andrews County and TECO in Robstown, Nueces County.* Seven commercial landfills presently accept Class I nonhazardous waste in Texas.
Under Federal Land Disposal Restriction (LDR) rules, all hazardous waste must be treated before land disposal.
Congress required the EPA to establish treatment standards by 1992 for all waste determined to be hazardous in 1984.
In addition, Congress required the EPA to establish treatment standards for all "newly identified" hazardous waste
within six months of identification. After failing to meet this deadline, and as a result of a lawsuit filed by the
Environmental Defense Fund, the EPA established a phased-in schedule for Land Disposal Restriction rules. In 1998,
under the final phase of its LDR rules, the EPA promulgated land disposal standards for metal-bearing waste as well as
some mineral processing waste which had previously been exempt from being considered hazardous under an
amendment known as the Bevill exclusion. In 1998 the EPA also finalized a rule listing as hazardous wastes four
different types of waste from petroleum refining operations, including crude oil storage tank settlement. Another ten
types of waste from petroleum refining operations were not listed as hazardous wastes.* All of these new rules are
causing some waste that had previously been disposed of in on-site or off-site disposal units to be sent for treatment,
such as stabilization. For example, the TCEQ estimates that some 47,830 tons of waste previously excluded under the Bevill exclusion will now require stabilization treatment*.
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NAME
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TYPE
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LOCATION
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Texas Ecologists (TECO)
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Hazardous
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Robstown, Nueces County
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Waste Control Specialists
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Hazardous, Mixed
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Andrews County
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Browning-Ferris Inc.
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Non-Hazardous
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Anahuac, Chambers County
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Browning Ferris Inc.
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Non-Hazardous
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Sinton, San Patricio County
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Browning Ferris Inc.
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Non-Hazardous
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Itasca, Hill County
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CSC Disposal
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Non-Hazardous
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Avalon, Ellis County
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Covel Gardens Landfill & Recycling Center
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Non-Hazardous
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San Antonio, Bexar County
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Waste Management of TX
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Non-Hazardous
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Atascocita, Harris County
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Waste Management of Texas
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Non-Hazardous
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Newton County
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The land disposal restrictions have prevented some types of wastes from being disposed of in
landfills, further decreasing the demand for this technology.* In addition, cleanup of abandoned
hazardous waste sites under the Superfund program is now emphasizing cleanup of contaminated soils on site rather than shipment of the soils off site. This policy also has also
reduced the amount of waste landfilled.* Finally, increasing land disposal costs because of RCRA regulations, as well as public opposition and
lawsuits over the health impacts of toxic waste landfills, have shifted waste management strategies away from land disposal. In Texas, proposals to locate landfills near the Texas-Mexico border have been particularly controversial.
Despite more stringent regulations and permitting requirements, not all disposal of industrial waste
into landfills or surface impoundments is closely monitored or requires a permit. For example,
most on-site facilities that manage nonhazardous industrial waste do not meet the same strict standards applicable to facilities that manage hazardous waste or even municipal waste landfills.* Yet many Class I wastes are toxic and potentially dangerous to human health and the environment.
Of special concern in Texas is the oil and gas industry. Presently, the oil and gas industry disposes of its wastes through
a variety of mechanisms. Under Statewide Rule 8, the Railroad Commission of Texas regulates the surface storage and
disposal of oil and gas wastes and brine-retention facilities. There are currently 28 land-farming facilities permitted for
disposal of oil and gas waste and 4,220 pits permitted for storage or disposal of such wastes or the retention of brine.
However, in 2002, only 55 sites regulated by Statewide Rule 8 required groundwater monitoring.* The Railroad
Commission reports225 cases of groundwater contamination from oil and gas activities in 81 different counties, including 26 new cases in 2002.* These cases included facilities covered under Rule 8, both those requiring permits
and those which do not require them, as well as illegal waste sites identified through a complaint or investigation.
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