Landfill consolidation is the practice of combining the contents from two or more landfills at one property into a single landfill. At locations where older landfills leak or lack modern covers, consolidation may provide an overall improvement in environmental performance when the new site is upgraded to meet current environmental standards. Consolidation also may free up property from use restrictions, which landfills typically have, increasing the options for future use. This process may also decrease long-term monitoring costs.
Consolidated units are called Corrective Action Management Units, or CAMUs. State and federal regulations cover landfill consolidation. These regulations allow for consolidation without having to adhere to all the very restrictive requirements for the disposal of new hazardous waste. CAMUs are constructed where either a temporary removal of hazardous materials is necessary for remediation or a long-term consolidation occurs. Creating the CAMU as an alternative provides regulators and the people responsible for cleanup an added measure of flexibility that can expedite and improve remedial decisions. CAMU regulations establish specific treatment and design standards. Among other things, they impose minimum treatment standards for principal hazardous constituents in CAMU wastes and minimum liner and cap standards for CAMUs.
Limitations and Concerns
A major concern is that all the landfill material is not entirely removed, thereby leaving residuals at the “clean” site. This is particularly true at many old sites where landfill boundaries were not delineated.
Landfills do not lessen the toxicity, mobility, or volume of waste: they only control migration.
At sites where explosive hazards exists, consolidation may be inappropriate or dangerous.
Consolidation may release wastes that have been immobilized by containers or natural barriers. For example, at one location where fill material is being consolidated, there is a concern that fine lead particles will be mobilized.
Although the CAMU provision provides some additional flexibility, it is important to recognize that other existing requirements, policies, and guidelines for establishing site-specific cleanup goals and for selecting remedies remain in effect.
Landfill consolidation is applicable to landfills containing a variety of materials.
Technology Development Status
This is a commercial process that has been used at many sites.
Other Resources and Demonstrations
See RCRA regulations, Part 264—Standards for Owners and Operators of Hazardous Waste Treatment and Disposal Facilities, Subpart -S, Section 264.552.