Landfill Caps

In 1957, long before Oregon had a solid waste permitting program, the Grabhorn family started accepting other people’s trash on their property in Beaverton, Oregon.  An unregulated landfill was born.


In 1972, Lakeside Reclamation Landfill (the Grabhorn landfill) received a permit to accept construction/ demolition debris.  There is also active composting operation on the property shown above.  Over the years, Lakeside violated this permit by accepting things like motor oil and chromium-treated animal hides.  Because the landfill started before the days of modern environmental regulation, it does not contain modern linings and caps.  To make matters worse, the landfill abuts the Tualatin River.  DEQ reports show that the landfill discharges leachate that contaminates the surrounding groundwater.


Take a look at this Oregonian opinion piece and DEQ press release to learn how the state  and community are handling the environmental enforcement issues.  It makes for a heated discussion to say the least.

 I had a chance to visit the landfill in March of 2010. I went on behalf of PEAC with two environmental consultants.  The purpose of our trip was to learn more about the landfill’s current cap system and how to fix it.

My old professor refers to the landfill as a giant teabag of trash.  Whenever it rains, the rain water enters the inside of the landfill creating leachate, or trash tea.  This leachate, which contains carcinogens like tetrahydrofuran, benzene and arsenic, then flows directly into the groundwater because there is no protective lining.


My photos depict the landfill’s current evapotranspirative (ET) cap, which is basically a bunch of deciduous trees planted above the covered dump.  In theory, the trees’ large leaves and roots are supposed to absorb most of the rain water before it even reaches the trash.  Unfortunately, these trees look sickly because they are planted on top of decomposing waste; and they have no leaves because it’s cold outside.  Naturally in the Pacific Northwest, ET caps are not enough to control landfill leachate because the trees are barren during the wet season. Possible fixes include an impermeable cap, a lining and landfill gas flares.  Check out this EPA fact sheet for more information on ET caps.



Clear cutting is the complete removal of timber from an area.  Although clear cutting is more economically efficient than selective harvesting, the practice has a wide range of negative results.  These include loss of wildlife habitat, soil erosion, greenhouse gas emissions,  elevation in stream temperatures and soil nutrient levels, increased air pollution and adverse affects from logging access roads.


Old growth trees, commonly found in the Pacific Northwest are tall and straight, creating the best quality lumber, or “softwood.”  However, these stands are unique natural resources that cannot be replaced for generations, if ever.

Oregon’s Tillamook State Forest is home to many old growth species and is managed through a series of designated use plans.  Currently, all of the areas marked in red above are open to clear cutting in the next 50 years.  The yellow areas are open to thinning.


I visited a hunting and fishing trade show at Portland Expo Center on behalf of the Oregon Chapter of the Sierra Club to gather signatures on a petition asking Governor Kitzhaber to protect Oregon’s state forests by designating more areas of conservation.   Whether or not you want to sign is completely your prerogative.  I  intend for this blog to simply present facts and photos.   Sierra Club asks  for this public land to be managed for other uses besides logging like wildlife habitat, camping, fishing and hiking.  Although this petition does not speak to a specific bill in the legislative hopper, HB 2736 relates to the issue.  “This bill sets up a pathway for the Department of Forestry and counties to designate ‘natural resource conservation areas’ on state forestlands like the Tillamook, Clatsop, Santiam and Elliott State Forests.” Visit Sierra Club’s Legislative Tracker for more information.  The next day, I shot a few photos in the Tillamook State Forest. Enjoy!


Gasoline Terminals

Portland, Oregon has one of the most toxic airsheds in the nation, according to EPA’s National-Scale Air Toxics Assessment.  Pollutants emanating from several giant fuel holding tanks situated directly northwest of the city are one of the many contributors to this problem. These tanks store petroleum products like gasoline, diesel and industrial lubricant oils. They are operated by Chevron, Kinder Morgan, BP, Conoco, Shore Terminals (formerly Exxon Mobil) and Equilon Enterprises (formerly Texaco doing business as Shell). Fuel reaches these tanks via railroad cars, marine vessels and the Olympic pipeline, which is an underground pipeline operated by BP. Environmental reporter Paul Koberstein estimates these tanks leak hundreds of tons of gasoline each year.


There have been numerous incidents where NW residents have complained of gasoline odors and resulting headaches. For example, in the spring of 2009, NW Portland residents experienced “unburned fuel” odors that lasted approximately two weeks. These residents’ complaints triggered Oregon DEQ’s odor response plan. Each gasoline company is required to contact DEQ if there has been a leak, spill or control equipment malfunction.  However, it’s difficult to trace the source of an acute odor incident if companies fail to report.

I photographed these tanks from two vantage points: up close in NW Portland and also from the east side of the Willamette River at the Skidmore Bluff.


Chemicals like benzene, toluene and hexane are associated with gasoline storage. The federal minimum pollution prevention rules require gasoline holding tanks to be equipped with floating roofs, and primary and secondary seals. These rules also set pollutant emission limits and establish trigger levels for leak detection.

Neighbors for Clean Air is a coalition seeking to make public health a priority in the development of Oregon’s air quality standards. NCA’s website has a feature that lets you can map and track the locations of suspicious industrial odors reported in Portland! Here is a link to  NCA’s petition asking the state to “establish enforceable standards that address the risk of spikes of emissions in the toxic hot spots.” Whether to sign is your prerogative.  I intend for this blog to simply present facts and photos.


Below is footage from a devastating gasoline storage tank explosion in  Puerto Rico (2009).

Metal Plating

Attaching metals to other metals . . . so many commercial products undergo some sort of plating process.  The surfaces of items such as jewelry, hardware, auto parts, circuit boards and instruments are covered with other metals to enhance durability and protect against corrosion.

The metal plating industry is one of the largest users of toxic chemicals in the country, according to the Illinois Sustainable Technology Center at the University of Illinois at Urbana-Champaign.  It’s also the second largest user of nickel compounds and the third largest user of cadmium compounds.  This equates to serious hazardous waste streams.


There are several plating methods such as electroplating and electroless plating, most of which require a series of chemical baths.  I visited two plating operations, one out-of-business and the other in business.  The out-of-business operation is basically a bunch of chemical baths in a shed.  This set-up places the surrounding land quality in jeopardy considering the area is due for an earthquake.  The second business is a viable circuit board manufacturer with multiple controls such as a floor draining system and secondary containment.  Click here to access the Pacific Northwest Pollution Prevention Resource Center’s Report on Metal Plating.


This LA Times Article describes a motion that four LA City Council members introduced today (Friday Jan 21, 2011) that will designate areas with high volumes of hazardous waste-generating industries as “green zone districts.”  “The aim would be to attract clean industries through incentives, including help obtaining permits and tax and utility rebates. Polluters, meanwhile, would be targeted with tougher inspection and enforcement protocols . . . Manuel Pastor, director of USC’s Program for Environmental and Regional Equity, said that ‘in some of these neighborhoods there is no place that is not within 1,000 feet of a significant pollution hazard such as chrome-plating businesses, heavy industry and adjacent freeways.'”


Free Geek

Free Geek is a non-profit organization that originated in Portland, Oregon in 2000.  Since then, 11 other cities started their own Free Geek operations.  It is a “closed loop” system that reuses or recycles old computer equipment.  Free Geek’s Reuse Program Coordinator gave me a tour of the facility and explained how the program works.

First, Free Geek accepts almost any type of electronic equipment.  Then a host of volunteers are responsible for demanufacturing the equipment, testing it and building new computers, called Freek Boxes, from a series of parts.  Parts that do not have the potential for refurbishment are sent to various recycling centers.  Free Geek does not send its obsolete parts to any recyclers that ship hazardous materials overseas.  For example, all obsolete monitors and terminals are processed by Total Reclaim in Seattle, which is a signer of the BAN Pledge.  In 2009, the Basel Action Network recognized Free Geek as a e-Stewards Recycler, the gold standard for ethical practices in electronics recycling.

For more information, visit


NY Times photo story: a Global Graveyard for Computers in Ghana.

E-waste becomes a top priority for EPA

Oregon’s E-Cycles Program

Consumer Demand for Specialty Cars Puts Manufacturers at Higher Risk for Clean Air Act Violations

Despite the economic climate, an increasing number of Americans are willing to pay around $200,000 for a specialty car.  High-performance Japanese models featured in the “Fast and Furious” films are in high demand.  Also, classic pony car replicas such as the 1960 Camaro or Mustang are making frequent appearances on American highways.

To meet consumer desires for speed or nostalgia, Japanese vehicle importers and domestic manufacturers of classic car replicas are emerging to cash in on this trend.  In fact, the number of manufacturers listed in Kit Car Magazine’s 2008 Buyer’s Guide increased 20 percent from previous years.  Because this is a growing and lucrative business, manufacturers, retailers and importers of Japanese high-performance cars and classic car replicas are at a higher risk of liability under EPA’s Clean Air Act Kit Car Policy.


EPA’s Kit Car Policy applies to both types of cars.  Japanese high-performance cars constitute “kit car packages” if imported as a series of parts.  Domestically manufactured classic car replicas are simply “kits,” which typically contain new bodies, used drivetrains, and new or used chassis.

The Japanese high-performance kit car packages become “motor vehicles” if the importation shipment includes major components needed for assembly such as the body, chassis, engine and transmission.  Classic car replica kits become “motor vehicles” once they are fully assembled.

As “motor vehicles,” these cars are subject to Clean Air Act emissions standards for highway vehicles found at 40 C.F.R. Parts 85 and 86.  For each vehicle or engine family, a certificate of conformity must be issued to the “manufacturer,” which can include an importer or retailer.  To become certified, the manufacturer must conduct emissions tests on a number of prototype vehicles and prove that the emissions pass EPA standards.  Once a manufacturer is certified, it can import or assemble identical vehicles without violating the Clean Air Act.


For specialty car manufactures to produce EPA-certified cars, there are two options.  First, the manufacturer could become the certificate holder by hiring a third party laboratory to conduct the prototype vehicle emissions tests.  This can cost approximately $50,000 per engine family and an additional $33,838 to cover the EPA certification fee for light-duty vehicles.  In the alternative, a manufacturer could enlist an Independent Commercial Importer (ICI) to convert each uncertified vehicle into a certified one.  As a result, the ICI holds the certificate and charges a fee to convert each vehicle.  A list of eligible ICIs can be found on EPA’s website at  The choice of whether to apply for a certificate or utilize an ICI usually hinges on the number of vehicles that the manufacturer plans to sell.  In the context of specialty cars, where the manufacturer sells only a few vehicles at high prices, an ICI may be the best choice.

Because the certificate can be so costly, many specialty cars are uncertified in violation of the Clean Air Act.  Without a certificate, manufacturers can import or build cars without emission controls that could emit more nitrogen oxide, hydrocarbons, carbon monoxide, carbon dioxide, sulfur oxide and volatile organic compounds than the normal certified car.  Without the required emission controls, these dirty cars disproportionately contribute to public health problems and climate change.


According to US Immigration and Customs Enforcement (ICE), increasing numbers of uncertified Japanese high-performance cars are smuggled into the US.  These fully functioning cars are disassembled in Japan and imported as a series of parts.  At the time of sale however, these vehicles are assembled.  These importation packages contain all of the major components needed for assembly, but are fraudulently labeled as “used automobiles and parts.”  By labeling these greymarket vehicles as a series of parts, these importers claim that the kit car package is not a “motor vehicle” under EPA’s Kit Car Policy and therefore not subject emission regulations.  If the government proves the packages were fraudulently labeled, these importers and retailers can be liable for a variety of statutory penalties.

If kit car packages are fraudulently imported, ICE could enforce 19 U.S.C. § 545, which regulates smuggling goods into the United States.  The Department of Transportation could also enforce 49 U.S.C. § 30112, which prohibits the importation of non-complying motor vehicles and equipment.  Finally, EPA could bring an action for failure to import a certified vehicle under Clean Air Act Section 203(a)(1).  This Section also prohibits the manufacture of uncertified vehicles.  Thus, EPA could bring an action against a classic car replica manufacturer who constructs cars domestically without emission controls.   Government awareness of increased consumer demand requires specialty car industries to be cognizant of the responsibility to produce clean cars.

Because it’s slightly related, check out the documentary, “Who Killed The Electric Car”: