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Page Ranch report 'inflammatory'

To the editor,

The Sept. 29, 1999 "Arizona Daily Wildcat" ran a story and editorial that was critical of the university's operation, closure and management of the Page Ranch Landfill. The story arose from a report prepared by Oracle resident Web Parton. I have been directly involved with the Page Ranch Landfill since 1981, so naturally I am concerned that information distributed about the site is complete and accurate. Unfortunately, Mr. Parton's report is written to be inflammatory, with key facts misunderstood and misrepresented, resulting in allegations that are false and conclusions that are incorrect.

A brief description of the site would be helpful. The Page Trowbridge Ranch consists of 640 acres of undeveloped desert grassland located north of State Highway 77, between Oracle Junction and the community of Oracle. The property has few structures, no utilities and has been used for a variety of agricultural and arid lands research activities over the years. The landfill cells comprise just over three acres in the extreme southwest corner of the property or one half of one percent of the total acreage.

The teaching of laboratory science and pursuit of new knowledge through laboratory research has always involved the use of chemicals. This was certainly true at the University of Arizona in 1962, as it is today. However, at that time there was little environmental awareness in this country and virtually no regulation of hazardous materials. This meant there were no facilities available anywhere for disposal of laboratory waste. The options were to throw chemicals out with the regular trash, pour them down the drain or do nothing, allowing them to accumulate in the lab. Instead, the university started burying these materials at Page Ranch. The site was well suited for this use because of low rainfall, stable geology and deep groundwater.

Certainly the initial disposal method of open pit burning was a far cry from current acceptable practice and technology. However, given that most of the wastes were flammable solvents, the decision to use open burning during the 1960s and 1970s is understandable for that time. In 1976, Congress passed the Resource Conservation and Recovery Act (RCRA) and the management of hazardous wastes in this country was dramatically changed. Shortly after the new regulations became effective in 1980, the university applied for and received an interim status permit from the Environmental Protection Agency (EPA) to operate as a landfill. The Arizona Department of Environmental Quality (ADEQ) also regulates this site. Both agencies conduct regular site inspections.

Groundwater beneath Page Ranch has been collected and analyzed on a continuous schedule since 1984. The aquifer, which lies 650 feet beneath the surface, is clean. Mr. Parton's report references method detection limits in analytical records and incorrectly concludes that these values represent contaminated groundwater. Halogenated compounds such as chloroform and carbon tetrachloride are among the most common laboratory contaminants. This is why field sampling always requires the use of trip blanks, which are samples of distilled laboratory water carried into the field and then tested for the same parameters as the groundwater. In some early lab results, trip blanks and the groundwater had very similar values at very low concentrations, suggesting laboratory contamination. As analytical techniques and equipment have improved, the incidence of such lab error has diminished. All testing results are on file with ADEQ, and have been reviewed by their hydrology and compliance staff. Additionally, samples have been independently tested by EPA and ADEQ, with similar non-detection results.

In 1984, President Henry Koffler established an ad hoc committee to evaluate the continued use of the site and later accepted their recommendation to close the site. Burials ceased in early 1986 and shortly thereafter, the first closure plan was submitted to ADEQ for review. At that time, standard practice for landfill closure was installation of a flexible membrane plastic liner over a compacted clay layer. In the years following, EPA developed much better science for landfill closure, publishing an analytical model for decisions that are driven by actual site conditions, with performance-based design criteria. Using this EPA guidance, it was determined that an engineered cap of compacted clay and native topsoil would fully prevent migration of rainwater into buried wastes, even under very adverse rainfall conditions. This is why the closure plan design changed from 1986 to what was approved by ADEQ and installed in 1997.

The presence of a hazardous waste facility is certainly a cause for scrutiny and diligence to ensure proper management and the protection of health and safety. The Page Ranch Landfill has been and will remain subject to continuous monitoring and oversight by multiple regulatory agencies for exactly this purpose. The university is committed to this effort and welcomes thoughtful comment on how to do this job better. Unfortunately, Mr. Parton's report was conceived and written to inflame opposition to real estate development near Oracle, and as such, it contributes little, if any value to this discussion.

Steven C. Holland

Director of Risk Management and Safety