Testimony Submitted by Stephen Lester, Science Director Before the PA Department of Environmental Protection July 18, 2016 My name is Stephen Lester and I am the Science Director for the Center for Health, Environment & Justice. I began my work on waste disposal issues more than 35 years ago when I was hired by the state of New York to provide scientific and technical assistance to the residents of Love Canal in Niagara Falls, NY. Love Canal is perhaps the most notorious landfill failure ever in U.S. history. Since that time, I have learned a great deal about landfills. The most important take-away from close to 40 years working on waste disposal issues is that all landfills leak, not necessarily right away, but eventually, all landfills will fail. In fact, it’s not possible to engineer a landfill that will not leak. It’s just a matter of time. This is the same conclusion that the U.S. EPA came to 1988 when it published its Subtitle D regulations for municipal solid waste landfills: “Even the best liner and leachate collection system will ultimately fail due to natural deterioration.” The U.S. Geological Survey came to a similar conclusion in 2003 when it wrote that: “Modern landfills are designed to minimize contaminations of groundwater, but modern landfills eventually may leak contaminants in the environment.” It remains true to this day that all landfills will eventually leak. If you look at the chemicals typically found in the leachate or the air emissions coming off a landfill, it reads like a witches brew of toxic chemicals. This includes common volatile organic compounds like benzene, toluene and xylene; heavy metals like lead, arsenic, cadmium and mercury; and more complex chemicals likes PCBs, PVC, phthalates and brominated flame retardants. Municipal solid waste does not just include the waste the general public throws away (though that would be bad enough), it also includes commercial and industrial waste, as well as many different kinds of “special” waste. Commercial and industrial waste especially from small businesses, have much more toxic chemical waste components than typical household garbage.
For this reason, as much as 20% of the garbage landfills like the Keystone site end up on the federal Superfund list, the worst contaminated toxic waste sites in the country. I was asked by the Friends of Lackawanna to review the air tests taken by the Pennsylvania DEP in April and June of last year (2015). These air samples were collected from 2 locations on the landfill site and four locations off-site. While there were many methodological problems with this analysis, what was clear from the sampling is that many toxic chemicals were found in the air samples taken on the landfill property. There were also a good number of toxic chemicals found in the air samples taken off-site including the April sample at Sherwood Park in April, a site that is located not far from the landfill. The limitations and inconsistencies of this testing are addressed in the attached Letter Report that I am submitting for the record. These findings raise many questions about the risks this facility poses to the people who live in the surrounding neighborhoods of Dunmore and Throop. The residents of these communities have endured this landfill and the pollution it generates for many years. Enough is enough! Itâ€™s time for the DEP to say no to this facility and to deny the permit extension. The people who live here should not have to bear the risks posed by this facility any longer. Thank you for the opportunity to submit these comments. Stephen Lester Science Director