The comments are in; we now await the response from the Department of Environmental Quality (DEQ) to the many suggestions for revising its proposed Closure Permit for Riverbend Landfill.
Most of the comments focus on particular language in the draft Permit, asking for restrictions that are more specific or for additional public participation. But one comment in particular focuses on important information that anyone living or working near Riverbend or downstream on the South Yamhill River -- or upstream, for that matter -- needs to know in order to plan for their own safety.
Richard McJunkin is a licensed and certified engineering geologist and hydrogeologist with more than 50 years experience evaluating landfills for compliance with seismic standards and regulations. For several years now, he has tried to share his expertise with DEQ, but no one in the agency has been listening. The latest evidence of this is the draft Permit's acceptance of a $15 million set-aside as sufficient to handle any "worst-case" scenario -- for example, a catastrophic failure of the dump in a 9.0 Cascadia subduction zone earthquake.
Per McJunkin's analysis, DEQ should be requiring Riverbend to set aside more than $750 million to pay for clean-up and compensate land and animal owners for damage resulting from a landfill collapse. His comment is worth reading in full. (Note: McJunkin also submitted comments regarding water contamination; we will feature those comments in a subsequent post.)
To: Permit Coordinator (deqwr.solidwastepermitcoordinator@deq.oregon.gov)
Oregon Department of Environmental Quality (DEQ)
I recommend that Oregon Department of Environmental Quality (DEQ) NOT ACCEPT “2021
Annual Financial Assurance Update and Recertification, Riverbend
Landfill; Solid Waste Disposal Permit No. 345 Yamhill County,” or “Final Engineered Site Closure and Post-Closure Plan, Riverbend Landfill, McMinnville, Oregon” (CP).
My
justification for this recommendation is that significant financial
closing costs for Riverbend Landfill (RL) were not only omitted from
planning but not even considered in the scenario for establishing
Closing Costs.... [The] scenario for total financial closing costs for RL, in no
uncertain terms, should have addressed a catastrophic seismic foundation
failure from an earthquake. It appears that specific geologic sampling
data from drilling data, that exposed wide-spread liquefiable sands to
be everywhere present in the geologic foundation for RL, were ignored.
If considered, these sampling data would have forced recognition of the landfill long-term vulnerability.
At least some of the liquefaction data collected by WMI [Waste Management, owner of RL] were in characterization efforts for constructing the Mechanically Stabilized Earthen (MSE) Berm; however and for whatever reason, liquefaction data were withheld from public access for approximately five years. During public WMI/DEQ meetings for the RL MSE Berm, the presence of liquefaction in the geologic foundation of RL was presented by the public as a big concern, especially as WMI sampling data indicated liquefiable sands were everywhere throughout the geologic foundation. DEQ, however, told the public that “No liquefiable sands were present beneath RL” even though sampling data from drilling operations at this same time period showed by laboratory analyses that liquefiable sands were wide-spread in the geologic foundation of RL. Samples, also verified as liquefiable by WMI laboratory analyses, appear to be present in 30 to 40 percent of subsurface sandsin the RL foundation.
Seismic/Liquefaction Considerations
At
the time the landfill was permitted [1980], Oregon seismic issues were only
beginning to be recognized as a potential threat to engineered
structures. Today, news agencies routinely present forecasts of a pending Cascadia
Fault Zone (CFZ) earthquake of Magnitude 9 on the Richter Scale. These
earthquake forecasts are based on recent scientific research that
indicates 19 earthquakes, caused by a complete break of the CFZ, have
occurred in the last 10,000-years, five...in the last 2,000-years. Besides
Magnitude 9 events, many magnitude 6, 7, and 8 earthquakes also occurred
with epicenters within 100-miles of the Pacific coast.
The last
full-break CFZ earthquake is well-dated and occurred in late January
1700, more than 100 years before the arrival of the Lewis and Clark
expedition. Given that five major earthquakes have occurred in the last
2,000 years and that the last Magnitude 9 CFZ earthquake was 322-years
in the past, the PNW is well into the window for a repeat full-break
of the CFZ that will result in a Magnitude 9 devastating earthquake. How could RL propose and DEQ accept the total closing cost amount now
set at a maximum cap of $15,425,086 given this pending earthquake threat? How could they, and who will pay for remediating a total failure of RL??
When
the MSE Berm was being permitted, geologic data, confirmed by WMI
laboratory analysis, showed that even though the landfill itself may be
stable when exposed to a magnitude 9 earthquake, the geologic foundation
for the landfill would fail by foundation liquefaction during an
earthquake of even moderate magnitude. Totally
overlooked (disregarded-?) in the RL Closure Plan was any mention of
these liquefaction data and the single largest long-term threat to RL:
Earthquakes
Seismic Wave Amplification: Overview
From
the lack of comments in the CP, WMI and DEQ also appear to not fully
recognize, or appreciate, that RL geologic site conditions favor
amplifying seismic wave energy during earthquakes (Seismic Wave
Amplification). This geologic situation is given to make shaking, even
from small earthquakes, more intense. Seismic wave amplification will
be generated at RL for one classic reason: loose geologic sedimentary
river deposits overlie hard well-cemented bedrock. In this setting,
seismic waves from deep underground earthquakes travel upward at
thousands of feet per second in dense well-cemented rock and then
propagate into soft near-surface sedimentary materials that have seismic
velocities less than 1,000 feet per second. As these high-velocity
waves are transmitted into near-surface much lower seismic velocity
loose sands and gravels, conservation of total seismic wave energy must
be maintained. To conserve total wave energy requires that seismic
wave amplitude be increased significantly, a given, with some localized
shaking severe. This setting translates into significantly higher
ground shaking for RL that undoubtedly exceeds what was used in Peak Ground Acceleration (PGA) stability calculations by WMI and approved by DEQ.
In
geologic settings for amplifying seismic wave energy similar to that of
RL, two examples are well-known: 1) Olive View Hospital in San
Fernando, California, which was destroyed in the 1971 San Fernando
earthquake (magnitude=6.6) and 2) the Cypress Viaduct freeway structure
for the Interstate 880 approach to the Bay Bridge from Oakland that failed
by collapse during the 1989 Loma Prieta earthquake (magnitude 6.9) and
also killed 42 people. In both of these cases, the structures were
built on slow-velocity geologic materials overlying higher velocity
bedrock with the low-velocity near-surface geologic materials amplifying
seismic wave energy.
Even
though both liquefaction and seismic wave amplification phenomena are
associated with the RL site, WMI is committed to persist with the
opinion that these threats are more conceptual than reality; therefore,
not of significant threat to RL seismic stability. As WMI minimizes
both concepts, they have had the full support of DEQ, which apparently also
considers seismic wave amplification and liquefaction as incapable of
generating any significant RL earthquake damage. Such a HUGE mistake!
Conclusions and Recommendations
The
data are clear that RL is geologically subject to Seismic Wave
Amplification. This phenomenon will increase ground shaking for any
given earthquake and be a threat to RL surface structures. To address
seismic data gaps that could be generated during any earthquake
impacting RL, I propose that DEQ ask WMI to install a permanently
affixed “strong-motion accelerograph” in an on-site location free
from structurally influenced ground motion. This accellerograph would
measure strong earthquake ground motion during seismic events and
provide for collecting valuable engineering data to analyze precise
ground motions, including PGAs, as well as enhanced motion velocities
and displacements. Data from such an accelerograph would be
beneficially invaluable for seismic engineering concerns, especially if
RL sustained damage or underwent total failure during an earthquake. This installation may be of technical interest to US Geological Survey
(USGS), which has an earthquake strong-motion monitoring program that
installs and monitors accelerographs. In other words, USGS may install
and service such an accelerograph free of charge.
In
my more than 50-years of geologic experience, one thing has been deeply
learned: moving earthen materials is expensive and time consuming. Further, the type of material being excavated and distance moved
determines the final cost, and moving clean soil is much-much cheaper
than moving contaminated soils. It is my estimate that a total seismic
failure of RL would require all of the landfill materials to be
‘eventually’ excavated, loaded, hauled, and dumped, possibly temporarily
for later movement to a final containment site.
In any catastrophic
failure, RL waste and leachate would be comingled into huge quantities
of soil, water, and pasty, leaking exposed landfill waste, all needing to be
excavated and removed. Necessary excavation, containment, transportation,
and disposal costs to an approved site could easily be in the range of
$600 to $800 per cubic yard. With cost overruns and the fact that the
waste needing to be remediated could be potentially hazardous, the final
cost per cubic yardage could be $900 to $1,000 per yard.
At these
rates (which address only remediating landfill waste), the minimum cost
for a catastrophic failure is estimated, on the low end, to be between
$500-million and $650-million dollars; a more realistic total of
$750-million to $900-million is probably more correct. Where did WMI
generate a dollar amount in the CP, that was approved by DEQ, of only
$15,425,086, which is almost a humorous amount? Again, who is
supposed to pay in the case of a total landfill failure? The
citizens of Yamhill County who once voted to approve using the
landfill?? The citizens of Oregon???
[The question is whether] the RL geologic foundation will perform without damage in
future earthquakes. What should be especially considered are WMI soil
samples, confirmed by laboratory analyses, showing loose liquefiable
sands being wide-spread in the RL geologic foundation. An answer needs
to be provided by DEQ.
Closing Statements
After
personally reviewing and studying RL geologic and seismic data from
drill logs and other measurements, and using my 50-years of professional
drilling and characterization experience, it is clear to me that the
geologic foundation of the RL is very fragile to seismic acceleration. In fact, it is much more fragile than WMI and DEQ have ever admitted. The high percentage of drill logs (30 - 40 percent) showing the presence
of liquefiable sands proves RL is a seismic accident waiting to
happen. Another condition is also set: Seismic failure of RL will
provide for the single largest environmental disaster in the
post-European settlement-history of Oregon.
RL
permitting and closure efforts in no way support the DEQ ‘Mission
Statement.’ RL failure debris will be a long-term issue with
wide-spread watery contamination everywhere down-gradient from the
landfill. The South Yamhill River, by its nature, will assist in spreading RL
contamination toward McMinnville, Newberg, and beyond to Portland.
Resources for addressing remediation of this disaster will not be
available for months, and possibly years. And all the while, Yamhill
County residents will be forced to live in conditions caused by failure
of the landfill; stinking conditions that would possibly not have
occurred if geologic and seismic data were fully recognized (understood)
by DEQ and used to address RL technical reviews. Upon any failure of
RL, especially from seismic sources, DEQ will encumber a huge long-term
debt of responsibility to the citizens of Yamhill County and Oregon, who
will be the ones truly experiencing post-disaster environmental
effects. These individuals will be the ones who bear the very
uncomfortable burden of living with a failed RL reality.
It is professionally disappointing to me that WMI very fully understands the threat from catastrophic
geologic details underlying RL and that the details will provide for
a total collapse during any future seismic event that lasts more than a
few seconds. This fact is also understood by DEQ, which, it appears, fully
supports the inadequate CP being submitted by WMI to the citizens of
Oregon. Further, no explanation is provided by WMI or DEQ for
apparently keeping confidential from public access, during a critical
permitting period, the full scope of technical understanding for
geologic and seismic liquefaction conditions underlying RL. Even though
WMI and DEQ always knew the true seismic risk from geology underlying
RL, it is minimized and disregarded. And the damaging data have been in
the WMI and DEQ records for years.
RL Closure needs a Final Closure Plan that financially addresses a
catastrophic event turning RL closure operations into the monumental
remediation of a totally destroyed landfill. Closure should only be
completed with a full commitment by WMI to adhere to future and
long-term maintenance issues that also include a total landfill
remediation from a PENDING extreme and scientifically forecasted
Cascadia Fault Zone (CFZ) earthquake. The future occurrence of a
magnitude 9 earthquake along the CFZ is a given. WMI has stated and
shown by mathematical calculation that RL will be completely stable in a
magnitude 9 earthquake. The landfill was sold to the Oregon public
under the pretense of seismic stability; therefore, WMI should fully
indemnify the landfill against seismic failure. Otherwise, the people
of Oregon will suffer the long-term financial responsibility to
remediate a failed landfill whose geologic foundation was positively
known to be seismically unstable by WMI and DEQ, which has excused the geologic facts from Closure consideration. A more
realistic ‘starting’ dollar amount of financial assurance for RL should
be at least $750,000,000 to address a total landfill failure
knowing that when such an event occurs, the final cost to remediate RL
will be one billion dollars ($1,000,000,000) or more--and it is
unavoidable.
