In an earlier article I wrote about the ban on free liquids in waste disposed of in a landfill, read:  Generator Ban on Liquids in Landfills Under the Generator Improvements Rule.  A ban on liquid disposal in landfills is nothing new, it has been in place since the inception of RCRA regulations in 1980.  However, a recent rule-change: the Generator Improvements Rule, expanded the responsibility for keeping liquids out of landfill from solely the landfill operator to the hazardous waste generator.

Left unchanged by the new rule, the ban on free liquids applies to both hazardous waste landfills and non-hazardous waste landfills, including a landfill designed primarily for disposal of household waste: the municipal solid waste landfill (MSWLF).

But saying, “no disposal of any and all free liquids in a MSWLF” is not accurate.  Some liquids are OK in a MSWLF.  These are codified at 40 CFR 258.28 and explained below.

Before we begin:

• Liquid waste is any waste material that is determined to contain free liquids as defined by Method 9095 (Paint Filter Liquids Test), as described in Test Methods for Evaluating Solid Wastes, Physical/Chemical Methods (SW-846).
• Gas condensate means the liquid generated as a result of gas recovery processe(es) at the MSWLF unit (§258.28(c)).

Unacceptable at a MSWLF:

Unlike hazardous waste landfills, a MSWLF is not allowed to accept bulk or non-containerized waste (liquid or solid) except the following:

• Household waste (excluding septic waste).
• Leachate or gas condensate derived from the MSWLF and the MSWLF is designed with a composite liner and leachate collection system per §258.40(a)(2).  MSWLF must keep a record of its compliance with these regulations and notify its state.
• The MSWLF is a Project XL MSWLF and complies with §258.41. MSWLF must keep a record of its compliance with these regulations and notify its state.

The Ban on Free Liquids in a MSWLF (sorta):

Containers holding liquid waste may not be placed in a MSWLF.

Unless…

• The container is a small container similar in size to that normally found in household waste.
• The container is designed to hold liquids for use other than storage.  e.g., a battery or capacitor.
• The waste is a household waste.

Conclusion:

Why does this matter to you?  Good question.  Likely your interest is limited to that of a business or government agency and its responsibility under the hazardous waste regulations of the USEPA or your state.  You may not be interested in the regulations applicable to a municipal solid waste landfill and household waste, but you should be.  Because a MSWLF may also receive other types of nonhazardous wastes, such as commercial solid waste, nonhazardous sludge, very small quantity generator waste, and industrial nonhazardous solid waste.

If there are free liquids in your waste destined for disposal in a MSWLF, you must get them out.  You may do this by decanting the liquid so no free-standing (i.e. visible) liquid remains or you may use sorbents to remove any free liquids.

Please contact me if you have any questions about the generation, management, and disposal of waste.