542F03015
                      Evapotranspiration  Landfill
                      Cover  Systems Fact  Sheet
INTRODUCTION

Alternative   final  cover  systems,   such  as
evapotranspiration  (ET) cover  systems,  are
increasingly  being considered for  use at waste
disposal sites, including municipal solid waste
(MSW)  and  hazardous waste landfills when
equivalent performance to conventional final cover
systems  can  be   demonstrated.     Unlike
conventional  cover  system designs that  use
materials with low hydraulic permeability (barrier
layers) to minimize the  downward migration of
water from the cover to the waste (percolation), ET
cover systems use water balance components to
minimize percolation.  These cover systems rely
on the  properties of soil to store water until it is
either transpired through vegetation or evaporated
from the soil surface.  Compared to conventional
cover systems, ET cover  systems are expected to
be  less costly to construct.  While  ET cover
systems are being proposed, tested, or have been
installed at a number of waste disposal sites, field
performance data and design guidance for these
cover systems are  limited (Benson and  others
2002; Mauser, Weand, and Gill 2001).

This fact sheet provides a brief summary of ET
cover systems, including general considerations in
their design, performance,  monitoring,  cost,
current status, limitations  on their use, and project-
specific examples. It is intended to provide basic
information   to  site  owners  and  operators,
regulators,  consulting  engineers, and  other
interested parties about these potential design
alternatives.   An  on-line database  has  been
developed that provides  more information about
specific projects using ET covers, and is available
at http:lfcluin.orgfproducts/altcovers.  Additional
sources of information are also provided.

The information contained in this fact sheet was
obtained  from  currently  available  technical
            literature and from discussions with site managers.
            It is not intended to serve as guidance for design
            or construction, nor indicate the appropriateness of
            using ET final cover systems at a particular site.
            The fact sheet does  not  address  alternative
            materials (for example, geosyntheticclay liners) for
            use in final  cover systems, or other alternative
            cover system designs, such as asphalt covers.
                         Online Database:
                 http:llcluin.orglproductslaltcovers
            BACKGROUND

            Final cover systems are used at landfills and other
            types of waste disposal sites to control moisture
            and percolation, promote surface water runoff,
            minimize erosion, prevent direct exposure to the
            waste, control gas emissions and odors, prevent
            occurrence  of  disease  vectors   and  other
            nuisances, and meet aesthetic and other end-use
            purposes.  Final cover systems are intended to
            remain in place and maintain'their functions for an
            extended period of time.

            In addition, cover systems are also  used in the
            remediation  of hazardous  waste  sites.   For
            example, cover systems may be applied to source
            areas contaminated at or near the ground surface
            or at abandoned dumps. In such cases, the cover
            system  may be used alone or in conjunction with
            other technologies to contain  the  waste  {for
            example, slurry walls and groundwater pump and
            treat systems).

            The design of cover systems is site-specific and
            depends on the intended function of the final cover
            - components  can range  from a  single-layer
            system to a complex multi-layer system.  To
77?/s fact sheet is intended solely to provide general information about evapotranspiration covers,  it is not intended, nor can it be
relied upon, to create any rights enforceable by any party in litigation with the United States. Use or mention of trade names does
not constitute endorsement or recommendation for use.
United States
Environmental Protection
Agency
Solid Waste and
Emergency Response
(5102G)
EPA542-F-03-015
 September 2003
   www.epa.gov
  http://cluin.org

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minimize percolation, conventional cover systems use
low-permeability barrier layers.  These barrier layers
are   often   constructed   of   compacted   clay,
geomembranes,   geosynthetic  clay  liners,  or
combinations of these materials.

Depending on  the material type  and construction
method, the saturated hydraulic conductivities for these
barrier layers are typically between  1x10'5 and 1x109
centimeters   per  second  (cm/s).    In  addition,
conventional   cover  systems  generally   include
additional layers, such as surface  layers to prevent
erosion;  protection layers to minimize  freeze/thaw
damage; internal drainage layers; and gas collection
layers (Environmental Protection Agency [EPA] 1991;
Mauser, Weand, and Gill 2001).

Regulations  under the Resource Conservation and
Recovery Act (RCRA) for the design and construction
of final cover systems are based on  using a barrier
layer  (conventional cover system).  Under RCRA
Subtitle D (40  CFR 258.60), the  minimum design
requirements for final cover systems at MSW landfills
depend on the bottom  liner system or  the natural
subsoils, if no liner system is present.  The final cover
system must have a permeability less than that of the
bottom liner system (or natural subsoils) or less than
1x10'5 cm/s,  whichever  is  less.   This  design
requirement was established to minimize the "bathtub
effect," which occurs when the landfill fills with liquid
because the cover system is more permeable than the
bottom liner  system.  This  "bathtub effect" greatly
increases the potential  for generation of leachate.
Figure 1  shows an example of a RCRA D cover at a
MSW landfill with  a 6-inch soil  erosion  layer,  a
geomembrane, and an 18-inch barrier layer of soil that
is compacted  to yield a hydraulic conductivity equal to
or less than 1x10'5 cm/s (EPA 1992).
Figure 1. Examples of Final Cover Systems
                                    Geomembrane
                                 )• Composite barrier
   (a) MSW Landfill
      As required £$8M  Topsoil layer  •£$£?
          -.•y* &l&&U.1^2AV:£A.-.U*.>*M^LVv!kl.£jv&.^

   » Frost penetration griSjES Cover soil layer
                                    Geomembrane
             M  C°T^?'^y9r P  Composite barrier
             :«lsS.  --.,.k *,1.9, ,cr!1/B, .. - . .^ I
      As required  ,:!   Gas drainage layer  ;.


   (b) Hazardous Waste Landfill
For hazardous waste landfills, RCRA Subtitle C (40
CFR  264 and  265)  provides certain  performance
criteria for final cover systems.  While  RCRA does not
specify minimum design requirements, EPA has issued
guidance for the minimum design of these final cover
systems.  Figure 1 shows an example of a RCRA C
cover at a hazardous waste landfill (EPA 1989).

The design and construction requirements, as defined
in the RCRA regulations, may also be applied under
cleanup programs, such as Superfund or state cleanup
programs, as part of a remedy for hazardous waste
sites such as abandoned dumps. In these instances,
the RCRA regulations for conventional covers usually
are identified as applicable or relevant and appropriate
requirements for the site.

Under RCRA,  an alternative design,  such  as an ET
cover, can be proposed  in lieu of a RCRA design if it
can be demonstrated that the alternative provides
equivalent performance  with respect  to reduction  in
percolation  and  other   criteria,  such as  erosion
resistance and gas control.

DESCRIPTION

ET cover systems use  one or more vegetated soil
layers to retain water until it is either transpired through
vegetation or evaporated from the soil  surface. These
cover systems rely on the water storage capacity of the
soil layer,  rather  than  low  hydraulic conductivity
materials, to minimize percolation.  ET cover system
designs are based on using the hydrological processes
(water balance components) at a site, which include
the water storage capacity of the soil,  precipitation,
surface runoff, evapotranspiration, and infiltration. The
greater the storage capacity and evapotranspirative
properties,  the  lower the potential  for percolation
through the cover system. ET  cover system designs
tend  to  emphasize  the following  (Dwyer  2003;
Hakonson 1997; Mauser, Weand and Gill 2001):

   •   Fine-grained soils, such as silts and clayey silts,
      that have a relatively high water storage capacity

   •   Native vegetation to increase evapotranspiration

   •   Locally available soils to streamline construction
      and provide for cost savings

In addition to being called ET cover systems, these
types  of  covers  have also been  referred  to in the
literature as water balance covers, alternative earthen
final   covers, vegetative landfill  covers,  soil-plant
covers, and store-and-release covers.

Two general types of ET cover systems are monolithic
barriers and capillary barriers.  Monolithic covers, also
referred to as monofill covers,  use a single vegetated

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soil layer to retain water until it is either transpired
through vegetation or evaporated from the soil surface.
A conceptual design of a monolithic cover system is
shown in Figure 2. Exhibit 1 provides an example of a
full-scale monolithic  cover at a MSW landfill.

Capillary barrier cover systems consist of a finer-
grained soil layer (like  that  of  a  monolithic cover
system) overlying a coarser-grained material layer,
usually sand or gravel,  as shown conceptually  in
Figure 3. The differences in the unsaturated hydraulic
properties between the two layers minimize percolation
into   the   coarser-grained   (lower)  layer   under
unsaturated conditions. The finer-grained layer of a
capillary barrier cover system has the same function as
the monolithic soil layer; that is, it stores water until it
is removed from the soil by evaporation or transpiration
mechanisms.  The  coarser-grained  layer forms  a
capillary break at the interface of the two layers, which
allows the finer-grained layer to retain more water than
a  monolithic  cover system  of equal  thickness.
Capillary forces  hold the water in  the finer-grained
Figure 2.  Conceptual Design of a Monolithic ET
Final Cover
                            Vegetation

                            Fine-grained Layer

                            Interim Cover

                            Waste
layer  until  the  soil near the interface approaches
saturation.   If saturation of the finer-grained  layer
occurs, the water will move relatively quickly into and
through the coarser-grained layer and to the waste
below. Exhibit 2 provides an example of a capillary
barrier field demonstration at a MSW landfill (Dwyer
2003, Stormont  1997).
  Exhibit 1.  Monolithic ET Cover at Lopez Canyon Sanitary Landfill, Los Angeles, CA

  Site type:  Municipal solid waste landfill
  Scale: Full-scale
  Cover design: The ET cover was installed in 1999 and consists of a 3-foot silty sand/clayey sand layer, which
  overlies a 2-foot foundation layer. The cover soil was placed in 18-inch lifts and compacted to 95 percent with
  a permeability of less than 3x10"5 cm/s.  Native vegetation was planted, including artemesia, salvia, lupines,
  sugar bush, poppy, and grasses.
  Regulatory status: In 1998, Lopez Canyon Sanitary Landfill received conditional approval for an ET cover,
  which required a minimum of two years of field performance data to validate the model used for the design. An
  analysis was conducted and provided the basis for final regulatory approval of the ET cover. The cover was
  fully approved in October 2002 by the California Regional Water Quality Control Board - Los Angeles Region.
  Performance data: Two moisture monitoring systems were installed, one at Disposal Area A and one at
  Disposal Area ABplus in May and November 1999, respectively. Each monitoring system has two stacks of
  time domain reflectometry probes that measure soil moisture at 24-inch intervals to a maximum depth of 78
  inches, and a station for collecting weather data.  Based on nearly 3 years of data, there is generally less than
  a 5 percent change in the relative volumetric moisture content at the bottom of the cover compared to nearly 90
  percent change near the surface. This implies that most of the water infiltrating the cover is being removed via
  evapotranspiration and is not reaching the bottom of the cover.
  Modeling: The numerical model UNSAT-H was used to  predict the annual and cumulative percolation through
  the cover.  The model was calibrated with 12 months of soil moisture content and weather data. Following
  calibration, UNSAT-H  predicted a cumulative percolation  of 50 cm for the ET cover and 95 cm for a
  conventional cover over a 10-year period. The model predicted an annual percolation of approximately 0 cm
  for both covers during the first year. During years 3 through 10 of the simulation, the model predicted less
  annual percolation for the ET cover than for the conventional cover.
  Maintenance activities: During the first 18 months,  irrigation was conducted to help establish the vegetation.
  Once or twice a year, brush is cleared to comply with Fire Department regulations. Prior to the rainy season,
  an inspection is conducted to check and clear debris basins and deck inlets.  No mowing activities or fertilizer
  applications have been conducted or are planned.
  Cosf: Costs were estimated at $4.5 million,  which includes soil importation, revegetation, quality control and
  assurance, construction management, and installation and operation of moisture monitoring systems.
  Sources: City of Los Angeles 2003, Hadj-Hamou and Kavazanjian 2003.
  More information available at http:llcluin.orglproductslaltcovers

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Figure 3.  Conceptual Design of a Capillary
Barrier ET Final Cover
                          •Vegetation

                          Fine-grained Layer

                          Coarse-grained Layer
                          Interim Cover

                         • Waste
In addition to being potentially less costly to construct,
ET  covers have  the  potential to provide  equal or
superior performance compared to conventional cover
systems,   especially  in   arid  and   semi-arid
environments.  In these environments, they may be
less prone to deterioration from dessication, cracking,
and freezing/thawing cycles.  ET covers also may be
able to minimize side slope instability, because they do
not  contain geomembrane layers, which can cause
slippage (Weand and others 1999; Benson and others
2002; Dwyer,  Stormont, and Anderson 1999).

Capillary barrier ET cover systems may also eliminate
the  need  for  a  separate biointrusion and/or  gas
collection layer. The coarser-grained layer can act as
a   biointrusion layer to resist root penetration  and
animal intrusion, due to its particle size and low water
content. The  coarser-grained layer also can act as a
gas collection  layer, because the soil properties  and
location within the cover system are comparable  to a
typical gas collection  layer in a  conventional  cover
system (Dwyer 2003, Stormont 1997).
LIMITATIONS

ET cover systems are generally considered potentially
applicable only in areas that have arid or semi-arid
climates; their  application  is generally  considered
limited to the western United States.  In addition, site-
specific  conditions, such as site location and landfill
characteristics, may limit the use or effectiveness of ET
cover systems.  Local climatic  conditions, such as
amount,  distribution,   and  form  of  precipitation,
including  amount  of  snow  pack,  can limit  the
effectiveness  of an ET cover at a given site.  For
example, if a  large amount of snow  melted when
vegetation was  dormant,  the cover may not have
sufficient water storage capacity, and percolation might
occur (EPA 2000a; Mauser, Weand, and Gill 2001).

Further, landfill characteristics, such as production of
landfill gases, may limit the use of ET covers. The
cover system  may  not  adequately  control gas
emissions since typical ET cover designs do not have
impermeable layers to restrict gas movement.  If gas
collection is required at the site, it may be necessary to
modify the design of the cover to capture and vent the
gas generated in the landfill. In addition, landfill gas
may limit the effectiveness of an ET cover, because
the gases may be toxic to the vegetation (Weand and
others 1999; EPA 2000a).

Limited data are available to describe the performance
of ET cover systems in terms of minimizing percolation,
as well as the covers' ability to minimize erosion, resist
biointrusion,  and remain  effective for an extended
period of time. While the principles of ET covers and
  Exhibit 2.  Capillary Barrier ET Cover at Lake County Landfill, Poison, Montana

  Site type:  Municipal solid waste landfill
  Scale:  Field demonstration under Alternative Cover Assessment Program (ACAP)
  Cover designs: The capillary barrier test section was installed in November 1999.  From the surface
  downward, it is composed of 6 inches of topsoil, 18 inches of moderately compacted silt, and 24 inches of
  sandy gravel.  The cover was seeded in March 2000 with a mixture of grasses, forbs, and shrubs, including
  bluegrass, wheatgrass, alfalfa, and prickly rose shrubs. A conventional composite cover test section was also
  constructed at the site.
  Performance data: Percolation is being measured with a lysimeter connected to flow monitoring systems, soil
  moisture is being measured with water content reflectometers, and soil matric potential and soil temperature
  are being monitored with heat dissipation units.  From November 1999 through July 2002, the capillary barrier
  cover system had a cumulative percolation of 0.5 mm. Total precipitation was 837 mm over the 32-month
  period.  Additional field  data are expected to be collected through 2005.
  Modeling:  Numerical modeling was conducted using HYDRUS 2-D, which simulated the wettest year on
  record over the simulation period of 10 years. The  model predicted approximately 0.6 mm of percolation during
  the first year, and 0.1 mm per year for the remaining 9 years.
  Sources: Bolen and others 2001, Benson and others 2002.
  More information available at http:llcluin.orglproductslaltcovers

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their  corresponding  soil  properties  have   been
understood for many years, their application as final
cover systems for landfills has emerged only within the
past 10 years. Limited performance data are available
on which to base applicability or equivalency decisions
(Dwyer 2003; Dwyer, Stormont,  and Anderson 1999;
Mauser and Weand 1998).

Numerical models are used to predict the performance
and assist in  the design of final  cover systems. The
availability of models used to conduct water balance
analyses of ET cover systems is  currently limited, and
the results can be inconsistent.  For example, models
such as Hydrologic Evaluation of Landfill Performance
(HELP)  and   Unsaturated  Water  and  Heat  Flow
(UNSAT-H) do not address all of the factors related to
ET cover system performance.   These  models, for
instance,  do not  consider  percolation  through
preferential   pathways;  may   underestimate  or
overestimate  percolation; and have different levels of
detail regarding  weather, soil,  and vegetation.  In
addition,  HELP   does  not  account  for physical
processes,  such as matric potential, that generally
govern  unsaturated  flow  in  ET  covers.   Further
information about numerical models is provided under
the Performance and  Monitoring section of this fact
sheet (Dwyer 2003; Weand and others  1999;  Khire,
Benson, and Bosscher 1997).

GENERAL CONSIDERATIONS

The design of ET cover systems is based on providing
sufficient   water   storage  capacity   and
evapotranspiration to control moisture  and  water
percolation into the underlying waste. The following
considerations generally are involved in the design of
ET covers.

Climate - The total  amount of precipitation  over a
year, as well as its form and distribution, determines
the total amount of water storage capacity needed for
the  cover  system.    The  cover  may need  to
accommodate a spring snowmelt event that causes the
amount of water at the cover to be relatively high for a
short period of time or conditions during cool winter
weather with  persistent, light precipitation. Storage
capacity is particularly important if the event  occurs
when local  vegetation  is  dormant, yielding  less
evapotranspiration.  Other factors related to climate
that are important to cover design are temperature,
atmospheric pressure, and relative humidity (Benson
2001; EPA 2000a; Hauser, Weand, and Gill 2001).

Soil type - Finer-grained materials, such as silts and
clayey silts, are typically used for monolithic ET cover
systems and  the top layer of a  capillary barrier ET
cover system because they contain finer particles and
provide a greater storage capacity than sandy soils.
Sandy soils are typically used for the bottom layer of
the capillary barrier cover system to provide a contrast
in unsaturated hydraulic properties between the two
layers.  Many ET covers are constructed of soils that
include clay loam, silty loam, silty sand, clays, and
sandy loam.

The storage capacity of the soil varies among different
types of soil,  and depends on the quantity of fine
particles and the bulk density of the soil.  Compaction
impacts bulk density, which in turn affects the storage
capacity of the soil and the growth of roots. One key
aspect of construction is minimizing the amount of
compaction during placement.  Higher bulk densities
may reduce the storage capacity of the soil and inhibit
growth of roots (Chadwick and others 1999; Hauser,
Weand, and Gill 2001).

Soil thickness - The thickness of the  soil layer(s)
depends on the  required storage capacity, which is
determined by the water balance at the site.  The soil
layers  need  to  accommodate   extreme   water
conditions,   such   as  snowmelts  and  summer
thunderstorms, or periods of time during which ET
rates are low and plants are dormant.  Monolithic ET
covers have been constructed with soil layers ranging
from 2 feet to 10 feet. Capillary barrier ET covers have
been constructed with finer-grained layers ranging from
1.5 feet to 5 feet, and coarser-grained layers ranging
from 0.5 foot to 2 feet.

Vegetation types - Vegetation for the cover system is
used to promote transpiration and minimize erosion by
stabilizing  the  surface of the  cover.    Grasses
(wheatgrass and clover),  shrubs (rabbitbrush  and
sagebrush), and trees (willow and hybrid poplar) have
been used  on ET covers.  A mixture of native  plants
consisting of warm- and cool-season species usually
is planted, because native vegetation is more tolerant
than imported vegetation to regional conditions, such
as extreme weather and disease. The combination of
warm- and cool-season species provides water uptake
throughout the entire growing season, which enhances
transpiration. In addition, native  vegetation is usually
planted, because these species  are  less likely to
disturb the natural ecosystem (Dwyer, Stormont, and
Anderson 1999; EPA 2000a).

Soil and organic properties -  Nutrient  and salinity
levels affect the ability of the soil to support vegetation.
The soil layers  need  to  be capable of providing
nutrients to promote vegetation growth and maintain
the vegetation  system. Low nutrient or high salinity
levels can be detrimental to vegetation growth, and if
present, supplemental nutrients may need  to be added
to promote  vegetation  growth.  For example, at Fort
Carson,  Colorado,  biosolids  were added  to a
monolithic ET cover to increase organic  matter and
provide  a  slow  release  of nitrogen to  enhance
vegetation  growth.   In addition,  topsoil promotes

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growth of vegetation and reduces erosion.  For ET
covers, the topsoil layer is generally a minimum of six
inches thick (McGuire, England, and Andraski 2001).

Control layer types - Control layers, such as those
used to minimize animal intrusion, promote drainage,
and control and collect landfill gas, are often included
for conventional cover  systems  and may  also be
incorporated  in  ET cover system designs.    For
example, a proposed monolithic ET cover at Sandia
National  Laboratories in New Mexico  will  have  a
biointrusion fence with 1/4-inch squares between the
topsoil layer  and the  native soil  layer to  prevent
animals from creating preferential pathways, potentially
resulting  in  percolation.   The  biointrusion  layer,
however,  will not inhibit root growth  to allow for
transpiration.  At another site, Monticello Uranium Mill
Tailings Site in Utah, a capillary barrier ET design has
a 12-inch soil/rock admixture as an animal intrusion
layer  located  44 inches below the surface, directly
above the capillary barrier layer.

In addition, a  capillary barrier cover demonstration at
Sandia National Laboratories has a drainage  layer
located above the capillary  break.  A drainage  layer
consisting of an upper layer  of sand  and  a lower layer
of gravel is located directly below the topsoil  layer.
The sand serves as a filter to prevent topsoil  from
clogging the drainage layer, while the gravel allows for
lateral drainage of water that has infiltrated through the
topsoil (Bolen and others 2001, Dwyer 2003).

In more recent applications,  several types of ET cover
designs also  have incorporated synthetic materials,
such as geomembranes, which are  used to enhance
the function of minimizing water into the waste.  For
example,  the Operating Industries Inc.  Landfill in
California   has  incorporated  a  soil layer  with  a
geosynthetic  clay liner  in  the design.   The  cover
system for this site will reduce surface gas emissions,
prevent oxygen intrusion and percolation, and provide
for erosion control (EPA 2000b).

PERFORMANCE AND MONITORING

Protection  of groundwater quality  is a  primary
performance goal for ail waste containment systems,
including final cover systems.  The potential adverse
impact to groundwater quality results from the release
of leachate generated  in  landfills or  other waste
disposal units such  as surface impoundments.  The
rate of leachate generation  (and potential  impact on
groundwater)  can be minimized by keeping liquids out
of a  landfill  or  contaminated  source area   of  a
remediation site. As  a result, the function of minimizing
percolation becomes a key performance criterion for a
final cover system (EPA 1991).
Monitoring the performance of ET cover systems has
generally focused on evaluating the ability of these
designs to  minimize water drainage into the waste.
Percolation performance typically is reported as a flux
rate (inches or millimeters of water that have migrated
downward through the base of the cover in a period of
time, generally  considered as  1 year).  Percolation
monitoring for ET cover systems is measured directly
using monitoring  systems  such  as  lysimeters  or
estimated indirectly using soil moisture measurements
and calculating a flux rate. A more detailed summary
on  the  advantages and disadvantages  of  both
approaches can be found in Benson and others 2001
(EPA 1991, Benson and others 2001).

Percolation monitoring can also be evaluated indirectly
by using leachate collection and removal systems. For
landfills underlain with these systems, the amount and
composition of leachate generated can be used as an
indicator of the  performance of a cover system (the
higher the percolation, the more leachate that will be
generated) (EPA 1991).

Although the ability  to  minimize percolation  is  a
performance criterion for  final cover systems, limited
data are available about percolation performance for
final  cover systems  for both  conventional  and
alternative designs.  Most of the recent data on flux
rates have been generated by two federal  research
programs, the Alternative Landfill Cover Demonstration
(ALCD)  and the  Alternative  Cover Assessment
Program (ACAP); see Exhibits  3 and 4, respectively,
for further information on these programs.  From these
programs, flux rate performance data are available for
14 sites with demonstration-scale ET cover systems
(Dwyer 2003, Benson and others 2002).

In addition, previous studies have been conducted that
monitored the performance of  ET covers.  Selected
studies  include the  following: integrated  test plot
experiment in Los Alamos, NM, which monitored both
types of ET covers from  1984  to  1987 (Nyhan,
Hakonson,  and  Drennon  1990); Hill Air Force Base
alternative cover study in Utah, which evaluated three
different covers (RCRA Subtitle D, monolithic ET, and
capillary barrier  ET) over  a 4-year period (Hakonson
and others 1994);  and Hanford field  lysimeter test
facility in Richland, WA, which monitored ET covers for
6 years (Gee and others 1993).

Additional  demonstration projects  of  ET  covers
conducted  in  the   1980's  and  early 1990's are
discussed in the ACAP  Phase I Report,  which  is
available at http:llwww.acap.dri.edu.

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Exhibit 3. Alternative Landfill Cover Demonstration (ALCD)
The U.S. Department of Energy (DOE) has sponsored the ALCD, which is a large-scale field test of two conventional
designs (RCRA Subtitle C and Subtitle D) and four alternative landfill covers {monolithic ET cover, capillary barrier ET
cover, geosynthetic clay liner cover, and anisotropic [layered capillary barrier] ET cover). The test was conducted at
Sandia National Laboratories, located on Kirtland Air Force Base in Albuquerque, New Mexico, with cover design
information available at http://www.sandia.goviSubsurfacelfactshtslert/alcd.pdf. The ALCD has collected information on
construction, cost, and performance that is needed to compare alternative cover designs with conventional covers. The
RCRA covers were constructed in 1 995, and the ET covers were constructed in 1 996. All of the covers are 43 feet wide by
328 feet long and were seeded with native vegetation. The purpose of the project is to use the performance data to help
demonstrate equivalency and refine numerical models to more accurately predict cover system performance {Dwyer 2003).
The ALCD has collected data on percolation using a lysimeter and soil moisture to monitor cover performance. Total
precipitation {precip.) and percolation (perc.) volumes based on 5 years of data are provided below. The ET covers
generally have less percolation than the Subtitle D cover for each year shown below. More information on the ALCD cover
performance can be found in Dwyer 2003.

Monolithic
ET
Capillary
barrier ET
Anisotropic
{layered
capillary
barrier) ET
Geosynthetic
clay liner
Subtitle C
Subtitle D
1997
(May 1 -Dec 31)
Precip.
(mm)
267.00
267.00
267.00
267.00
267.00
267.00
Perc.
(mm)
0.08
0.54
0.05
0.51
0.04
3.56
1998
Precip.
(mm)
291.98
291.98
291.98
291.98
291.98
291.98
Perc.
(mm)
0.22
0.41
0.07
0.19
0.15
2.48
1999
Precip.
(mm)
225.23
225.23
225.23
225.23
225.23
225.23
Perc.
(mm)
0.01
0.00
0.14
2.15
0.02
1.56
2000
Precip.
(mm)
299.92
299.92
299.92
299.92
299.92
299.92
Perc.
(mm)
0.00
0.00
o.oo
0.00
0.00
0.00
2001
Precip.
(mm)
254.01
254.01
254.01
254.01
254.01
254.01
Perc.
(mm)
0.00
0.00
0.00
0.02
0.00
0.00
2002
(Jan 1 - Jun 25)
Precip.
(mm)
144.32
144.32
144.32
144.32
144.32
144.32
Perc.
(mm)
0.00
0.00
0.00
0.00
0.00
0.74

Monitoring  systems  -  Lysimeters  are installed
underneath a cover system, typically as geomembrane
liners backfilled with a drainage layer and shaped to
collect water percolation.   Water collected  in  the
lysimeter is  directed  toward a monitoring point and
measured using a variety  of devices (for example,
tipping bucket, pressure tranducers). Lysimeters have
been  used in  the ALCD  and  ACAP programs for
collecting performance data for ET cover systems.

Soil moisture monitoring can be  used to determine
moisture content at discrete locations in cover systems
and to evaluate changes over time  in horizontal or
vertical gradients.  Soil moisture  is measured using
methods to  determine  relative  humidity, soil matrix
potential, and resistance. Table 1  presents examples
of non-destructive techniques that have been used to
assess soil moisture cpntent of ET cover systems. A
high  soil  moisture value  indicates  that  the  water
content of the cover system is approaching its storage
capacity,  thereby  increasing  the  potential  for
percolation.  Soil moisture  is especially important for
capillary  barrier ET cover systems; when  the finer-
grained layer becomes saturated, the capillary barrier
can fail resulting in water percolating through the highly
permeable layer to the waste below (Hakonson 1997).

Maintaining the effectiveness of the cover system for
an  extended period of time  is another  important
performance  criterion for ET  covers  as  well as
conventional  covers.    Short-term  and   long-term
performance  monitoring  of  a  final  cover system
includes settlement effects, gas emissions, erosion or
slope failure, and other factors.

Numerical models - While there are limitations to
numerical models, as previously described, they have
been used to predict cover performance and assist in
the design of ET cover systems. Numerical models
have been used to compare the expected performance
of ET cover systems to conventional cover systems.
By entering multiple parameters and evaluating the
design of cover systems, designs can be modified until

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Exhibit 4. Alternative Cover Assessment Program (ACAP)
EPA is conducting the ACAP to evaluate the performance of alternative landfill covers. ACAP began in 1998, and cover
performance is currently being evaluated at 13 sites. The sites are located in eight states from California to Ohio, and
include a variety of landfill types, such as MSW, construction and demolition waste, and hazardous waste landfills. At eight
sites, conventional and ET covers are being tested side by side. At the remaining five sites, only ET covers are being
tested.
The alternative covers typically were constructed with local soils and native vegetation. At two facilities, however, hybrid
poplar trees were used as vegetation, At 1 1 sites, percolation performance is being evaluated by lysimeters. At the other
two sites, performance is being evaluated indirectly by monitoring leachate production. Soil moisture is also being
evaluated at all 13 sites. Below is an example of the field data for precipitation (precip.) and percolation (perc.) volumes at
3 of the sites. A summary of field cover performance for all 1 3 sites through July 2002 is provided in Albright and Benson
2002. More information about ACAP is available on the Desert Research Institute website at http://www.acap.dri.edul.
Site
Altamont, CA
(semi-arid)
Poison, MT
(semi-arid)
Omaha, NE
(humid)
Cover Design
Monolithic ET
Composite/
compacted clay
Capillary barrier ET
Composite/
compacted clay
Capillary barrier ET
(thick)
Capillary barrier ET
(thin)
Composite/
compacted clay
Start
Date
11/00
11/00
11/99
11/99
10/00
10/00
10/00
Yearl
Precip.
(mm)
225
225
300
300
600
600
600
Perc.
(mm)
negligible
negligible
0.05
0.5
55
100
5
Year 2
Precip.
(mm)
300
300
300
300
200
200
200
Perc.
(mm)
1.5
negligible
0.05
0.5
negligible
negligible
negligible
Year 3
Precip.
(mm)


250
250



Perc.
(mm)


0.45
0.5




Table 1. Examples of Non-Destructive Soil Moisture Monitoring Methods
Method
Tensiometer
Psych rometer
Electrical resistance blocks
Neutron attenuation
Time domain reflect rometry
Description
Measures the matric potential of a given soil,
which is converted to soil moisture content
Measures relative humidity (soil moisture)
within a soil
Measures resistance resulting from a gradient
between the sensor and the soil; higher
resistance indicates lower soil moisture
Emits high-energy neutrons into the soil that
collide with hydrogen atoms associated with
soil water and counts the number of pulses,
which is correlated to moisture content
Sends pulses through a cable and observes
the reflected waveform, which is correlated to
soil moisture
Instrumentation
Commonly consists of a porous ceramic cup
connected to a pressure measuring device
through a rigid plastic tube
Generally consists of a thermocouple, a
reference electrode, a heat sink, a porous
ceramic bulb or wire mesh screen, and a
recorder
Consists of electrodes embedded in a
gypsum, nylon, or fiberglass porous material
Consists of a probe inserted into access
boreholes with aluminum or polyvinyl chloride
casing
Consists of a cable tester (or specifically
designed commercial time domain
reflectrometry unit), coaxial cable, and a
stainless steel probe

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• specific performance  results are achieved.   The
 numerical model HELP is the most widely used water
 balance model for landfill cover design. UNSAT-H and
 HYDRUS-2D are two other numerical models that have
 been  used  frequently  for the design of  ET covers.
 HELP and UNSAT-H are in the public domain, while
 HYDRUS-2D is available from the International Ground
 Water  Modeling  Center  in   Golden,   CO
 http:lltyphoon. mines.edu (Dwyer2003; Khire, Benson,
 and Bosscher 1997).

 Recent studies  have compared available numerical
 models and found that  cover design depends on site-
 specific factors,  such as climate and  cover type, and
 that no single mode! is  adequate to accurately predict
 the performance of all ET covers.   Several of the
 studies  identified  are:   intercede comparisons  for
 simulating water balance of surficial sediments in semi-
 arid  regions, which  compared  results  of  seven
 numerical  models  for nonvegetated,   engineered
 covers  in   semiarid  regions;   water  balance
 measurements and computer simulations of landfill
 covers, which evaluated ALCD cover performance and
 predicted results from HELP and UNSAT-H; and field
 hydrology and model predictions for final covers in the
 ACAP, which compared performance results with those
 predicted by HELP and UNSAT-H (Scanlon and others
 2002;  Dwyer 2003; Roesler, Benson,  and Albright
 2002).

 COST

 Limited cost data are available for the construction and
 operation and  maintenance (O&M)  of  ET cover
 systems. The available construction cost data indicate
 that these cover systems have the  potential to be less
 expensive   to  construct  than  conventional  cover
 systems.  Factors  affecting the cost  of construction
 include availability of materiats, ease of installation,
 and project  scale.   Locally available soils, which are
 usually less costly than  imported  clay  soils,  are
 typically used for ET cover systems.  In addition, the
 use  of  local   materials   generally   minimizes
 transportation costs {Dwyer 2003,  EPA 2000a).

 While the construction cost for an ET cover is expected
 to  be  less  than  that for  a conventional cover,
 uncertainty  exists  about the costs  for  O&M after
 construction. Several factors affecting the O&M cost
 include frequency  and level of  maintenance  (for
 example, irrigation and nutrient addition), and activities
 needed  to  address erosion  and biointrusion.   In
 addition, when  comparing the costs  for  ET and
 conventional covers, it is  important  to consider the
 types of components for each cover and their intended
 function.  For example,  it would generally  not  be
 appropriate  to compare the costs  for a conventional
 cover with a gas collection layer to an ET cover with no
such layer. Additional information about the costs for
specific ET cover systems is  provided  in  project
profiles, discussed below under Technology Status.

TECHNOLOGY STATUS

A searchable on-line database has been developed
with information  about  ET  cover  systems  and is
available at http:flcluin.org/productslaltcovers.  As of
September 2003,  the database contained 56 projects
with monolithic ET cover systems and 21 projects with
capillary barrier ET cover systems; these systems have
been proposed, tested, or installed at 64 sites located
throughout the United States, generally from Georgia
to Oregon.  Some sites  have multiple projects, and
some projects have multiple covers and/or cover types.

The database provides project profiles that include site
background information  (for example, site type,
climate, precipitation), project information (for example,
purpose, scale, status), cover information (for example,
design, vegetation, installation), performance and cost
information, points of contact, and references. Table
2 provides a summary of key information  from  the
database for 34 recent projects with monolithic ET or
capillary barrier ET covers.

In addition  to this  on-line database, several ongoing
federal and state initiated programs are demonstrating
and assessing the performance of ET cover systems.
The following programs  provide performance data,
reports, and other useful information to help evaluate
the applicability of ET designs for final cover systems.

  •  Alternative Landfill Cover Demonstration - See
     Exhibit   3   for   more  information   or
     http://www.sandia.gov/Subsurface/factshtslertl
     alcd.pdf

  *  Alternative Cover Assessment Program - See
     Exhibit  4   for   more   information   or
     http://www. acap.dri. edu

  •  Interstate Technology and Regulatory Council -
     Published a  report called Technology Overview
     Using Case Studies  of  Alternative  Landfill
     Technologies   and  Associated  Regulatory
     Topics;  March 2003.  For further information,
     see http://www.iircweb.org

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Table 2. Selected Sites Using or Recently Demonstrating Evapotranspiration (ET) Covers

Site Name and Location ' Site Type
Monolithic ET Covers - Full Scale Projects
Barton County Landfill, Great Bend, KS MSW landfill
Coyote Canyon Landfill, Somis, CA MSW landfill
Duvall Custodial Landfill, Duvall, WA MSW landfill
Fort Carson, Colorado Springs, CO MSW landfill
Hastings Groundwater Contamination Superfund Site, MSW landfill
Hastings, NE
Horseshoe Bend Landfill, Lawrenceburg, TN Industrial waste landfill
Idaho National Engineering and Environmental Laboratory Radioactive waste site
Superfund Site, Idaho Falls, ID
Industrial Excess Landfill Superfund Site, OH Industrial waste landfill
Johnson County Landfill, Shawnee, KS MSW landfill
Lakeside Reclamation Landfill, Beaverton, OR Construction debris
Lopez Canyon Sanitary Landfill, Los Angeles, CA MSW landfill
Marine Corps Logistics Base Superfund Site, GA MSW and hazardous waste landfill
Municipal Waste Landfill at Kirtland Air Force Base, NM MSW landfill
Operating Industries Inc. Landfill Superfund Site, CA MSW landfill
Pantex Plant, Amarillo, TX Construction debris
Site Name and Location Site Type
Capillary Barrier ET Covers - Full Scale Projects
Gaffey Street Sanitary Landfill, Wilmington, CA MSW landfill
Hanford Superfund Site, Richland, WA* Radioactive waste site
McPherson County Landfill, McPherson, KS MSW landfill
Site Name and Location Site Type
Monolithic ET Covers - Demonstration Projects
Altamont Landfill, Livermore, CA (ACAP project) Non-hazardous waste site
Bluestem Landfill #2, Marion, IA (ACAP project) MSW landfill
Finley Buttes Regional Landfill, OR (ACAP project) MSW landfill
Green II Landfill, Logan, OH (ACAP project) MSW and hazardous waste landfill
Kiefer Landfill, Sloughhouse, CA (ACAP project) Non-hazardous waste site
Marine Corps Logistics Base, Albany, GA (ACAP project) MSW and hazardous waste landfill
Milliken Landfill, San Bernadino County, CA (ACAP project) MSW landfill
Monterey Peninsula Landfill, Marina, CA (ACAP project) Non-hazardous waste site
Rocky Mountain Arsenal Superfund Site, Denver, CO Hazardous waste site
Sandia National Laboratories, NM (ALCD project) Non-hazardous waste site
Site Name and Location Site Type
Capillary Barrier ET Covers - Demonstration Projects
Douglas County Landfill, Bennington, NE (ACAP project) MSW landfill
Hill Air Force Base, Ogden, UT Hazardous waste landfill
Lake County Landfill, Poison, MT (ACAP project) MSW landfill
Lewis and Clark County Landfill, MT (ACAP project) Non-hazardous waste site
Sandia National Laboratories, NM (ALCD project) Non-hazardous waste site
Uranium Mill Tailings Repository, UT (ACAP project) Hazardous waste landfill
Status of Project

Installation
Operational
Operational
Operational
Design
Operational
Proposed
Proposed
Installation
Operational
Operational
Proposed
Operational
Operational
Operational
Status of Project

Installation
Operational
Operational
Status of Project

Operational
Operational
Operational
Operational
Operational
Operational
Operational
Operational
Complete
Operational
Status of Project

Operational
Operational
Operational
Operational
Operational
Operational
Date Installed

NA
April 1994
1999
October 2000
NA
1998
NA
NA
NA
1990
1999
NA
2002
May 2000
2000
Date installed

NA
1994
2002
Date Installed

November 2000
October 2000
November 2000
2000
July 1999
March 2000
1997
May 2000
April 1998
1996
Date Installed

August 2000
1994
November 1999
November 1999
1996
July 2000
Notes:
* Project conducted as Superfund treatability test study with cover constructed over an existing waste site
NA     Not Applicable
ALCD   Alternative Landfill Cover Demonstration; program supported by DOE
ACAP   Alternative Cover Assessment Program; program supported by EPA
                                                     10

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^REFERENCES

 Albright, W.H. and C.H. Benson.  2002. "Alternative
    Cover Assessment Program 2002 Annual Report."
    Desert Research Institute. Publication No. 41182.
    October.

 Benson, C.H. 2001. "Alternative Earthen Final Covers
    (AEFCs)  or  'ET  Caps."    GEO  Institute.
    Proceedings,  Liners and Covers for  Waste
    Containment  Facilities.    Atlanta,  Georgia.
    November 14 through 16.

 Benson, C.H. and others.  2001.  "Field Evaluation of
    Alternative Earthen Final Covers." International
    Journal of Phytoremediation. Volume 3, Number
    1. Pages 105 through 127.

 Benson, C.H. and others.  2002.  "Evaluation of Final
    Cover Performance:    Field   Data from  the
    Alternative Landfill Cover Assessment Program
    (ACAP)."  Proceedings,  WM 2002 Conference.
    Tucson, Arizona. February 24 through 28.

 Bolen, M.M. and others.  2001.  "Alternative Cover
    Assessment  Program:    Phase  II   Report."
    University of  Wisconsin-Madison.    Madison,
    Wisconsin. September.  Geo Engineering Report
    01-10.

 Chadwick, Jr., D. and others. 1999.  "Field Test of
    Potential RCRA-Equivalent Covers at the  Rocky
    Mountain  Arsenal,  Colorado."   Solid  Waste
    Association.   Proceedings, North America's 4th
    Annual Landfill Symposium.  Denver, Colorado.
    June 28 through 30.  GR-LM  0004.  Pages 21
    through 33.

 City  of  Los Angeles.   2003.    E-mail  Message
    Regarding Lopez  Canyon Landfill.  From Doug
    Walters, Sanitary Engineer, Department of Public
    Works. To Kelly Madalinski, EPA. September 25.

 Dwyer, S. 2003.  "Water Balance Measurements and
    Computer  Simulations  of  Landfill  Covers."
    University of  New  Mexico,  Civil Engineering
    Department.  May.

 Dwyer, S.F., J.C.  Stormont, and C.E. Anderson. 1999.
    "Mixed Waste Landfill  Design  Report."   Sandia
    National Laboratories. SAND99-2514. October.

 Gee,  G.  and others.  1993.  "Field Lysimeter Test
    Facility Status Report IV:  FY 1993."   Pacific
    Laboratory, Richland, Washington.  PNL-8911,
    UC-902.
Hadj-Hamou, T. and  E. Kavazanjian,  Jr.   2003.
    "Monitoring and Evaluation of Evapotranspirative
    Cover Performance." GeoSyntec Consultants.

Hakonson, T.E.  1997.  "Capping as an Alternative for
    Landfill Closures-Perspectives and Approaches."
    Environmental Science and Research Foundation.
    Proceedings, Landfill Capping  in the Semi-Arid
    West:  Problems,  Perspectives, and Solutions.
    Grand Teton National Park, Wyoming.  May 21
    through 22.  ESRF-019.  Pages 1 through 18.

Hakonson, T. and  others.   1994.   "Hydrologic
    Evaluation of Four Landfill Cover Designs at Hill
    Air Force Base, Utah."  Los  Alamos National
    Laboratory, Los Alamos, New Mexico.  LAUR-93-
    4469.

Hauser,V.L.,andB.L.Weand. 1998. "Natural  Landfill
    Covers."     Proceedings,   Third   Tri-Service
    Environmental Technology Workshop. San Diego,
    California. August 18 through 20.

Hauser, V.L., B.L.  Weand,  and M.D.  Gill.   2001.
    "Natural  Covers for Landfills and Buried Waste."
    Journal  of  Environmental  Engineering.
    September.  Pages 768 through 775.

Khire, M.V., C.H. Benson, and P.J.  Bosscher.  1997.
    "Water  Balance  Modeling  of Earthen Final
    Covers."     Journal  of  Geotechnical  and
    Geoenvironmental Engineering.  August.  Pages
    744 through 754.

McGuire, P.E., J.A. England, and B.J. Andraski. 2001.
    "An Evapotranspiration Cover for Containment at
    a Semiarid Landfill Site."  Florida State University.
    Proceedings, 2001 International Containment &
    Remediation  Technology Conference.  Orlando,
    Florida. June 10 through 13.

Nyhan, J., Hakonson, T., and Drennon, B. 1990. "A
    Water Balance  Study  of Two Landfill  Cover
    Designs  for  Semi-arid  Regions."   Journal  of
    Environmental Quality.  Volume 19.  Pages 281
    through 288.

Roesler, A.C., C.H. Benson, and W.H. Albright. 2002.
    "Field  Hydrology and Model Predictions for Final
    Covers in the  Alternative Cover Assessment
    Program-2002." University of Wisconsin-Madison.
    Geo Engineering Report No.  02-08.  September
    20.

Scanlon,   B.R.,  and  others.   2002.   "Intercede
    comparisons  for simulating  water balance  of
    surficial sediments  in semiarid  regions."   Water
    Resources Research. Volume 38, Number 12.
                                                 11

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Stormont,  John C.   1997.  "Incorporating Capillary
    Barriers   in   Surface   Cover  Systems."
    Environmental Science and Research Foundation.
    Proceedings, Landfill Capping in the Semi-Arid
    West:   Problems,  Perspectives, and Solutions.
    Grand Teton National Park, Wyoming.  May 21
    through 22.  ESRF-019. Pages 39 through 51.

EPA.  1989.  Technical Guidance Document: "Final
    Covers on Hazardous Waste Landfills and Surface
    Impoundments."  EPA/53O-SW-89-047. July.

EPA.   1991.   "Seminar Publication, Design  and
    Construction of  RCRA/CERCLA Final Covers."
    EPA/625/4-91/025. May.
EPA.  1992.  "Subtitle D Clarification."  40 CFR 257 &
    258.     Federal   Register  pages  28626
    through28632. June.

EPA. 2000a. Introduction to Phytoremediation. Office
    of Research and  Development. Washington, DC.
    EPA/600/R-99/107.  February.

EPA.   2000b.   "Operating Industries Inc.   Final
    Construction As Built Report." May.

Weand, B.L., and others. 1999. "Landfill Covers for
    Use at Air Force Installations." AFCEE.  Brooks
    Air Force Base, Texas. February.
NOTICE

Preparation of this fact sheet has been funded wholly
or in part by the U.S. Environmental Protection Agency
under Contract  Number 68-W-02-034.  For  more
information regarding this fact sheet, please contact
Mr. Kelly  Madalinski,  EPA, at (703)  603-9901 or
madalinski.keily@epa.gov.

This fact sheet is available for viewing or downloading
from EPA's Hazardous Waste Cleanup Information
(CLU-IN) web site at http://cluin.org. Hard copies are
available free of charge from:

U.S. EPA/National Service Center for Environmental
Publications (NSCEP)
P.O. Box42419
Cincinnati, OH 45242-2419
Telephone: (513) 489-8190 or (800) 490-9198
Fax: (513)489-8695
ACKNOWLEDGMENT

Special  acknowledgment  is given  to  the following
individuals for their review and thoughtful suggestions
to support the preparation of this fact sheet:  David
Carson (EPA), Steve Rock (EPA), Ken Skahn (EPA),
Steve Wall (EPA), Greg Mellama (U.S. Army Corps of
Engineers), Joey Trotsky  (U.S. Navy), Bill Albright
(Desert Research Institute), Craig Benson (University
of Wisconsin-Madison), Steve Dwyer (Sandia National
Laboratory), Glendon Gee (Pacific Northwest National
Laboratory),  Tanya Goldfield (City of Los Angeles),
Charles  Johnson  (Colorado  Department of  Public
Health),  Doug Walters (City of Los Angeles), and Tom
Hakonson (Environmental Evaluation Services, LLC).
                                                 12

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