PB96-964416
EPA/ROD/R08-96/125
Janaury 1997
EPA Superfund
Record of Decision:
F.E. Warren Air Force Base,
Operable Unit 3; Landfill 6, Cheyenne, WY
1/22/1996
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DECLARATION FOR THE RECORD OF DECISION
INTERIM ACTION
OPERABLE UNIT 3; LANDFILL 6
i.o SITE NAME AND LOCATION
F. E. Warren Air Force Base
Cheyenne, Wyoming
2.0 STATEMENT OF BASIS AND PURPOSE
The selected interim action (remedy) for Operable Unit 3 (OU3), Landfill 6 (LF6), at F.E.
Warren Air Force Base (Base), in Cheyenne, Wyoming includes CAPPING and an active gas venting
system. The selected action, the third at the Base, was chosen in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA), and the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). The selected remedy addresses only source control at LF6, a
portion of OU3. This decision is based on the Administrative Record for the site. The United States
Environmental Protection Agency (EPA) and State of Wyoming Department of Environmental Quality
(WDEQ), as oversight agencies, concur with the selected remedy. The United States Air Force is the
lead agency for the site.
3.0 ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the remedy selected in this Record of Decision (ROD), may present a current or potential
threat to public health, welfare, or the environment.
The selected remedy for LF6 is a source control action that includes capping and an active gas
venting system. OU3 is the third of ten operable units to be investigated under terms of the Federal
Facility Agreement (FFA). The others are: OU1 - Spill Sites 1 through 7; OU2 - Facility Ground
Water (except at OUs 3, 6, 7 and 8); OU4 - Acid Dry Wells; OU 5 - Fire Protection Training Area 2;
OU 6 - Open Burning/Open Detonation Area; OU7 - Firing Ranges; OU 8- Landfill 5; OU9- Landfills
2 and 4; and OU10- Landfill 7 and Fire Protection Training Area 1. The ground water contamination
associated with OUs 3, 6, 7, and 8 will be investigated and remediated as part of those OUs, separate
from OU2. All of the investigations are being conducted in accordance with the FFA. It is anticipated
that the ROD for OU2 will be issued after the remedial investigation (RI) has been completed for the
other OUs.
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The function of the interim action is to control the LF6 site as a source of ground-water
contamination by reducing infiltration and the downward movement of contaminants to the ground
water, and to reduce the risks associated with exposure to contaminated materials. While the remedy
addresses one of the principal threats at the site, the final remedial alternative will address remediation
of the downgradient contaminant plume.
The major components of the selected remedy include:
• Capping Landfill 6 in accordance with relevant and appropriate Resource
Conservation and Recovery Act Subtitle C landfill closure requirements;
• Installing an active venting system to control methane production;
• Installing erosion and surface water controls;
• Conducting environmental monitoring to ensure the effectiveness of the interim
action; and
• Preparing final LF6 remedial investigation and feasibility studies to identify the
extent of ground-water contamination downgradient of the landfill and to develop and evaluate
appropriate remedial alternatives for ground water treatment.
5.0 STATUTORY DETERMINATIONS
The United States Air Force (USAF) has determined, with the concurrence of the Environmental
Protection Agency, and the State of Wyoming, that this interim action is protective of human health and
the environment, complies with Federal and State applicable or relevant and appropriate requirements
directly associated with this action, satisfies the requirements for a waiver of any standards that won't
be met, and is cost-effective. This action utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable for this site. However, because treatment of the
principal threats of the site was not found to be practicable, this remedy does not satisfy the statutory
preference for treatment as a principal element of the remedy. The size of the landfill and the fact that
there are no apparent on-site hot spots that represent the major sources of contamination preclude a
remedy in which contaminants could be excavated and treated effectively. Because this action does not
constitute the final remedy for LF6, the statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element will be addressed at the time of the final
response action. Subsequent actions are planned to address fully the principal threats posed by LF6.
CERCLA Section 121(c), 42 U.S.C. Section 962l(c), requires five-year reviews in the event
that hazardous substances, pollutants or contaminants remain on site. The USAF will conduct reviews
every five years after issuance of this ROD.
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6.0 SIGNATURE OF AGENCY ACCEPTANCE OF REMEDY (EPA)
The undersigned representative concurs with this Record of Decision for Interim Action,
Operable Unit 3: Landfill 6, at F. E. Warren AFB, Wyoming.
WILLIAM P. YELLOWTAILDate
ADMINISTRATOR!
EPA REGION
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6.0 SIGNATURE OF AGENCY ACCEPTANCE OF REMEDY (USAF)
The undersigned representative concurs with this Record of Decision for Interim Action,
Operable Unit 3: Landfill 6, at F. E. Warren AFB, Wyoming.
PATRICK P. CARUANA, LIEUTENANT GENERAL
VICE COMMANDER
AIR FORCE SPACE COMMAND
Date
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6.0 SIGNATURE OF AGENCY ACCEPTANCE OF REMEDY (WDEQ)
The undersigned representative concurs with this Record of Decision for Interim Action,
Operable Uwp: Landfill 6, at F/E/ Warren AFB, Wyoming.
Date
DENN HEMMER/X'
DIJ&CTOR
fOMING DEPARTMENT OF ENVIRONMENTAL QUALITY
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DECISION SUMMARY FOR THE RECORD OF DECISION
INTERIM ACTION
OPERABLE UNIT S:LANDFILL 6
i.o SITE NAME, LOCATION, AND DESCRIPTION
F. E. Warren Air Force Base (Base), occupies approximately 5,866 acres immediately adjacent
to the west side of the City of Cheyenne, Wyoming (Figure 1).
The Base was placed on the National Priorities List on February 21, 1990. Historically, the
Base has served a number of military functions, including; cavalry outpost, quartermaster depot and
intercontinental ballistic missile operations base. Operations began at the U. S. Army outpost named
Fort D. A. Russell in 1867. The name was changed to Fort F. E. Warren in 1930. The Base was a
major training facility during and after World War n. Fort F. E. Warren was transferred to the newly
formed U. S. Air Force in 1947 and was subsequently named F. E. Warren Air Force Base. The Base
underwent extensive renovation after World War n. The majority of the Army training facilities were
torn down and not replaced. Construction since that time has centered on facilities for Air Force
operations. Beginning in 1958, F. E. Warren Air Force Base became a Strategic Air Command
(SAC) base. Since then, F. E. Warren Air Force Base has served as an operations center for, first, the
Atlas Intercontinental Ballistic Missile (1CBM), followed by the Minuteman I and EQ and finally, the
Peacekeeper (MX) ICBMs. The Base was part of Air Combat Command (ACC) from 1992 to 1993,
and in July 1993, became part of Space Command.
F. E. Warren Air Force Base is bordered by agricultural land and rural or suburban residential
areas. The Base contains 831 residential housing units and several unaccompanied personnel housing
units (barracks), along with the services required by residents. The nearest residences to Landfill 6
(LF6), are off- Base, approximately 600 feet to the west.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
LF6 is an area of about 44 acres located north of Diamond Creek, west of Missile Drive, and
along the western boundary of the Base as shown in figure 2. The estimated volume of fill at the
landfill is 201,600,000 cubic feet. This volume could be considerably less if the disposal trenches were
15- to 20-feet deep as described in a report subsequent to the original records search which reported a
60-foot depth. The landfill has a soil and sparse-grass cover. Depth to the water table in the area of
LF6 ranges from about 5 to 41 feet below ground surface. The 1985 records search stated that LF6
was managed from 1971 until 1984; however a later 1993 report suggests that operations may have
started earlier. This site was operated as a trench-and-fill operation, with all refuse from the Base shops
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104^53'
104*52'
104*51'
RE. WARREN
AIR FORCE BASE
EXPLANATION
LANDFILL AND NUMBER
BOUNDARY OF F.E. WARREN
AIR FORCE BASE
41*08'
2.500
5.000 FEET
500 1,000 1,500 METERS
Figure 1. - Location of Landfill 6, F. E Warren Air Force Base, Wyoming
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Landfill 6
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TRICHLOROETHENE IN MICROGRAMS PER LITER
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1 to 5
5 to 10
10 to 100
100 to 1,000
1,000 to 10,000
Greater than 10,000
1,600 FEET
400 METERS
APPROXIMATE BOUNDARY OF LANDFILL
MONITOR WELL AND NUMBER
Figure 2. Landfill 6
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and housing area being transported to the landfill and covered with soil on a daily basis. The landfill
was closed for refuse disposal in September 1984. Coal ash from the Base coal-fired, high-
temperature-hot-water plant continued to be deposited in the landfill until December 1989. The Base-
shop wastes disposed of at the site included waste oils, solvents, ethylene glycol, silicone oil, hydraulic
fluid, mineral spirits, and waste JP-4 jet fuel. Batteries and battery acid were disposed of until 1982;
out-of-date pesticides, oil-based paints, and asbestos insulation were landfilled until closure in 1984. No
burning of landfill materials is believed to have occurred at LF6.
On September 26, 1991, a Federal Facility Agreement (FFA) was signed between the USAF,
EPA, and WDEQ. The FFA is required by Section 120 of CERCLA. The FFA provides the
framework for EPA and WDEQ oversight of continuing remedial investigations at the Base and further
identifies USAF investigation activities and schedules. The Base provides documents to EPA and
WDEQ for review and concurrence, in accordance with the FFA.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The USAF has prepared and implemented a community relations plan (CRP) in
accordance with CERCLA requirements, and the FFA. The CRP describes community
involvement activities the USAF will undertake during remedial activities at F. E. Warren Air
Force Base. The USAF has followed the requirements of the CRP, including issuance of
periodic fact sheets, holding public meetings, and providing the opportunity for public comment
throughout the LF6 investigation.
The Administrative Record has been established at an on-Base location and at the Laramie
County Public Library. The USAF has prepared and distributed fact sheets to all persons or
groups identified on the CRP mailing list (approximately 1400).
The announcement of the commencement of the public comment period was made on April
8, 1995, through advertisements in the Wyoming Tribune-Eagle and in the Casper Star-Tribune.
These advertisements announced and outlined the public comment period and public meeting.
The public comment period was scheduled from April 17 to May 16, 1995. A public meeting
was held at Cheyenne, Wyoming on April 25, 1995. An official transcript of the meeting has
been prepared and placed in the Administrative Record.
In addition to the newspaper announcements, the USAF also issued a press release and an article
appeared in the Base Sentinel newspaper on April 21, 1995. The public meeting was also
announced during the "Military Minute" on Cheyenne radio station KRAE. An article
describing the public meeting was published in the Wyoming Tribune-Eagle on April 26, 1995.
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Responses to all comments on the Proposed Plan are presented in the Responsiveness
Summary of this ROD.
4.0 SCOPE AND ROLE OF OPERABLE UNIT
The selected interim action LF6 is a source control action that includes capping and
active gas venting system. Operable Unit (OU) 3 is the third of ten OUs to be investigated
under terms of the Federal Facility Agreement (FFA). The others are: OU1 - Spill Sites 1
through 7; OU2 - Facility Ground water (except at OUs 3, 6, 7 and 8); OU4 - Acid Dry Wells;
OU 5 - Fire Protection Training Area 2; OU 6 - Open Burning/Open Detonation Area; OU7 -
Firing Range(s); OU 8- Landfill 5; OU9- Landfills 2 and 4; and OU10- Landfill 7 and Fire
Protection Training Area 1. The ground water contamination associated with OUs 3, 6, 7, and
8 will be investigated and remediated as part of these OUs, separate from OU2. All of the
investigations are being conducted in accordance with the FFA. It is anticipated that the ROD
for OU2 will be issued after the RI has been completed for the other operable units.
5.0 SITE CHARACTERISTICS
LF6 is the source of several chemicals found downgradient of the landfill at
concentrations in excess of Federal drinking water standards. The chemical most frequently
detected is trichloroethylene (TCE), considered to be a suspected carcinogen.
No specific characterization has been performed for the landfill contents. Based on the
EPA guidance on presumptive remedies for landfills, the source of contamination is considered
to be the entire landfill area.
Cores from 30 shallow-soil boreholes were sampled and analyzed for volatile organic
compounds (VOCs), semi-volatile organic compounds (SVOCs), organo-chlorine pesticides,
polychlorinated biphenyls (PCBs), metals, anions, and moisture content. One VOC, acetone,
was detected once, at a concentration of 0.10 mg/kg. No target analyte SVOCs were detected;
however a number of SVOC tentatively identified compounds (TICs) were found in the soils.
Although pesticides were initially detected in five of the 30 samples, only 4,4'-DDT and beta-
BHC in one sample each were verified. Surface samples from seven selected boreholes, and
from two sites where ash was observed on the landfill surface, were analyzed for
polychlorinated dibenzo-p-dioxins (PCDDs) and polychlorinated dibenzoftirans (PCDFs). One
such compound was detected in one of the nine samples.
Soil-gas samples were analyzed from 30 sites corresponding to the 30 soil boreholes.
Very high concentrations of methane, in excess of 2000 parts per million, were observed in
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three localized areas. The largest of these areas measured about 250 feet by 100 feet. Samples
from seven of the other 27 sites showed detectable contaminants - primarily vinyl chloride.
A series of 87 test wells were installed and sampled. Evaluation of data from these wells
was used to locate 31 monitor wells. Ground-water samples from the monitor wells were
analyzed for VOCs, SVOCs, organo-chlorine pesticides and PCBs, ethylene glycol, metals, and
anions. TCE was detected in samples from 8 of the 31 wells, with five wells having
concentrations in excess of the Maximum Contaminant Level (MCL) of 5 (ig/L. The solvent
1,1,1-trichloroethane was detected in water samples from three of the wells, one of which also
showed 1,1-dichloroethane. Gasoline components were detected in the sample from one well
located within the fire protection area adjacent to the east side of the landfill. No organo-
chlorine pesticides, PCBs, or ethylene glycol were verified. Nitrate was detected in samples
from six of the wells at concentrations above the MCL of 10 mg/L. Samples from four monitor
wells were analyzed for PCDDs and PCDFs, with no detects. Total dissolved solids (TDS)
above the Secondary Maximum Contaminant Level (SMCL) of 500 mg/L was detected in
samples from two of 12 wells tested.
Surface-water samples from three locations on Diamond Creek and three locations and
one spring on Crow Creek were analyzed for VOCs, SVOCs, organo-chlorine pesticides,
PCBs, ethylene glycol, PCDDs, PCDFs, metals, chromium (VI), and anions. These samples
represented conditions for the low-flow period of the year, during which the two watercourses
are gaining streams in the areas sampled. TCE (at 3.4ji/L) and cis-1, 2-dichloroethene
(1.6_|i/L) were detected in one sample from Diamond Creek site D3. No SVOCs, ethylene
glycol, or pesticides were verified. One dioxin compound (OCDD) was detected in one sample
from Diamond Creek (D2 at 140 pg/L) and the sample from the spring on Crow Creek (SP4 at
150 pg/L). Lead was the only metal detected at or near the MCL, at a concentration of 0.0065
mg/L in one of eight samples.
Bed material was sampled and analyzed from two locations on Diamond Creek and three
on Crow Creek. Like the surface-water samples these samples represent low-flow conditions.
Analyses included VOCs, SVOCs, organo-chlorine pesticides, PCBs, PCDDs, PCDFs, metals,
anions, and moisture content. No VOCs, SVOCs, organo-chlorine pesticides, PCBs, PCDDs,
or PCDFs were detected. The metals concentration in the bed-material samples from the
upstream parts of Diamond Creek and Crow Creek on the Base generally were higher than
those reported further downstream on Crow Creek on the Base. Lead was detected at 1,620
mg/kg where Diamond Creek enters the Base. Chloride and sulfate concentrations in the bed-
material samples generally were higher than in surface-soil samples.
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Based on the potential pathways that exist at landfill 6, as well as the current state of the
landfill, there are two primary pathways by which contaminants can migrate to potential
receptors.
Leaching of contaminants from landfill 6 to ground water is the main release mechanism
for contaminant movement. This mechanism occurs as the result of the rain water infiltration
and reaction with landfill contents, or from the movement of liquid waste from the landfill to
ground water. During transport by ground water, contaminants may undergo degradation and
transformation reactions that produce additional contaminants over time. Movement of ground
water away from the landfill towards Crow Creek transports contaminants towards potential
receptors. Primary receptors include the riparian environment at Crow Creek; secondary
receptors include people using the creek for recreational activities. The documented existence of
a TCE plume extending from landfill 6 to Crow Creek establishes that the ground-water
pathway is currently impacting this water course.
Contaminant transport by overland flow of surface water is considered a potential
migration pathway, although it is probably minor due to the semiarid climate and the relatively
flat topography of the site. However, contaminant transport may occur during periods of heavy
rainfall or rapid snowmelt.
Air-born dispersion of volatilized organic compounds and fugitive dust emissions are
aspects of the second pathway. Organic contaminants in soil at LF6 consist of SVOCs that are
readily sorbed to particulates and susceptible to transport. Inorganic contaminants consist of
metals that also exist primarily in the solid phase and thus are readily transported by wind.
Although the landfill has a soil and grass cover, without knowledge of the design, depth, and
condition of the cover, future direct contact with the landfill contents cannot be precluded, if the
selected remedy is not implemented.
Due to the proximity of Diamond Creek to the landfill, a third pathway of surface
transport of contaminants by erosion is possible, but limited due to the flat topography.
6.0 SUMMARY OF SITE RISKS
A streamlined risk assessment (SRA) was conducted for LF6 to determine the potential
human exposures and risks from chemicals under-baseline conditions. Surface soil contaminants
of concern are: beta-BHC, 4,4'-DDT, octachlorodibenzo-p-dioxin, aluminum, arsenic, barium,
beryllium, chromium, cobalt, lead, manganese, nickel, and vanadium. The ground-water
contaminants of concern are: Trichloroethylene, dichlorofluoromethane, trichlorofluoromethane,
butylbenzene, p-isopropyltoluene, cis-dichloroethene, n-propylbenzene, cis-l,2-dichloroethene,
1,1,1-trichloroethane, 1,2,4-trimethylbenzene, total xylenes, aluminum, arsenic, barium,
manganese, nitrate, and sulfate.
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Landfill 6 is the source of several chemicals found at concentrations in excess of Federal
drinking water standards. The most prevalent is trichloroethylene (TCE), considered to be a
suspected carcinogen. The carcinogenic risk from exposure to TCE in ground water is within
the target risk range of 10"4 to 10"6 (1 in 10,000 to 1 in 1,000,000).
Potential carcinogenic health effects were identified on the basis of the reasonable
maximum exposure (RME) calculations for both the residential and occupational scenarios. The
risk-based equations used to compute the preliminary remediation goals (PRGs) were derived to
reflect the potential risk from exposure to a single chemical, given a specific pathway, medium,
and land-use combination.
The use of the PRGs serves a two-fold purpose for risk characterization. First, the
comparison of the site and COC-specific RME concentration with the corresponding PRG gives
an immediate indication that a potential risk may exist when the PRG concentration is exceeded.
Second, the risk corresponding to the site and COC-specific RME can be calculated. Both of
these functions are useful when performing a risk screening. Also, as part of the risk
characterization phase of this SRA, the highest potential cumulative risks associated with ground
water were determined on the basis of a one acre residential plot exposure unit area. The
following is a summary of the SRA findings:
Residential Carcinogenic Ground Water Risk: The residential carcinogenic ground
water risk was estimated to range from 7.7 X 10"7 to 2.6 X 10"4
Arsenic accounted for the highest potential risk estimate at 2.6 X 10" . TCE accounted
for the next highest risk estimate at 1.2 X 10~5.
Occupational Carcinogenic Ground Water Risk: The occupational carcinogenic ground
water risk was estimated to range from 4.1 X 10~7 to 1.5 X 10~4.
Cumulative Residential Soil Carcinogenic Risk: 7.0 X 10" .
Cumulative Occupational Soil Carcinogenic Risk: 2.0 X 10"
Potential noncarcinogenic health effects were identified on the basis of the RME
calculations for both residential and occupational exposure scenarios. Manganese accounted for
the highest RME residential Hazard Quotient at 2.4 and a Hazard Index of 2.6.
Although an ecological investigation was conducted, an ecological risk assessment was
determined to not be necessary since the remedy (capping the landfill) will mitigate any
ecological risks.
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The selected interim action will:
• Decrease the potential for contamination of ground water by reducing the
movement of contaminants from the landfill.
• Provide protection against direct contact with the landfill contents.
• Control surface water (both run on and run off) and erosion.
• Provide protection to human health by eliminating exposure to contaminant
vapors and contaminated dust particulate.
• Eliminate direct contact with the landfill contents by constructing a RCRA cap
over the landfill, meeting RCRA landfill closure requirements, and implementing deed
restrictions to prohibit residential development of the site.
• Reduce the potential for landfill gas migration by installing an active landfill gas
venting system. The number of gas vents shall be determined during the remedial design. The
landfill gas venting system shall meet ARARs.
The function of this interim action is to control LF6 as a source of ground-water
contamination by reducing infiltration and the downward movement of contaminants to the
ground water and to reduce the risks associated with exposure to contaminated materials.
Actual or threatened releases of hazardous substances from the landfills, if not addressed,
may present a current or potential threat to public health and the environment.
7.0 DESCRIPTION OF ALTERNATIVES
Three alternatives for the interim remedial action were evaluated as part of the detailed
analysis in the focused feasibility study. All three alternatives are summarized in this section.
None of the alternatives are expected to be the final remedy for LF6. Institutional controls are
included for all alternatives. The purpose of these institutional controls is to limit direct
exposure to landfill contents and contaminated soils and to protect the integrity of the remedy.
Deed restrictions will not allow subsurface development (excavation) or vehicular traffic at LF6.
Implementing institutional controls will include:
• A continuing order of the Base Commander requiring implementation of the
landfill restrictions as long as the property is owned by F. E. Warren AFB.
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• Upon completion of construction at LF6, the Air Force will file notice of these
restrictions in the real- property records of the county in which the landfill is located. Before
transfer of the property, the Air Force will provide a deed covenant notifying the transferee of
the locations and the restrictions on the use of the areas.
• Fencing the landfill area and placing warning signs for the duration of the
remedial action. Additional deed restrictions may be required for effective implementation of
other technologies.
Alternative 1 is no action. Evaluation of the "no action" alternative is required by the
National Contingency Plan to be used as a baseline comparison for other alternatives. Under
this alternative the Air Force would take no action at the landfill to prevent exposures to
contamination.
Alternative 2 is a compacted soil cap with a gas venting system. This alternative consists
of the construction of a single-barrier compacted-soil cap to cover the entire surface of the
landfill. This cap will be designed such that it meets the minimum permeability requirements of
the Resource Conservation and Recovery Act (RCRA), subtitle D, so as to reduce infiltration of
water from the ground surface to the landfill contents. The single-barrier compacted-soil cap
consists of a compacted clay layer overlain by a gravel drainage layer. A final soil layer and
vegetative soil layer would be placed as a top cover to protect the cap from erosion and other
weather effects. Surface water diversion and erosion and ponding prevention would be included
as an integral part of the topsoil grading design. Methane gas would be controlled with an
active venting system, where pumped gas vent wells are used to provide positive reduction of
gas pressures. Uncontaminated cap and topsoil materials would be hauled to the landfill from a
borrow source. Long-term periodic monitoring of ground water would be performed. This
alternative will comply with Resource Conservation and Recovery Act (RCRA) subtitle D cap
requirements.
Alternative 3 is a composite cap with a gas venting system. This alternative consists of
the construction of a multiple-barrier cap to cover the surface of the landfill. A composite
barrier consists of a compacted clay layer covered by a synthetic liner. This, in turn, is overlain
by a drainage layer. A final soil layer and vegetative soil layer placed as a top cover serves to
protect the cap from erosion and other weather effects. Surface water diversion and erosion and
ponding prevention would be included as an integral part of the topsoil grading design. Any
liquid that percolates through the top soil cover is collected by the drainage layer. This landfill
cap will be designed to meet the permeability requirements of RCRA subtitle C, so as to reduce
infiltration of water from the ground surface to the landfill contents. Methane gas would be
controlled with an active venting system to provide positive reduction of gas pressures.
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Uncontaminated cap and topsoil materials would be hauled to the landfill from a borrow source.
Long-term periodic monitoring of ground water would be performed.
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Alternatives 2 and 3 are protective of human health and the environment because the cap
will reduce the rate at which contaminants move to the water table and prevent direct exposure
to surface contaminants. A reduction in the rate at which contaminants reach the water table
will decrease the concentrations of those contaminants in the shallow aquifer. Compliance with
Federal and State applicable or relevant and appropriate requirements (ARARs) relevant to the
landfill cap will be assured.
The preferred alternative is number 3. Alternative number 3 would achieve risk
reduction by limiting exposure and reducing the transport of contamination to ground-water by
reducing infiltration. The composite cap is potentially more reliable than the compacted-soil cap
because of the synthetic membrane liner. Based on the information available at this time, the
Air Force believes the preferred alternative will be protective of human health and the
environment and will comply with the ARARs. As an interim action, the preferred alternative is
expected to be consistent with the final remedy for Operable Unit 3.
Each of the alternatives has been evaluated against nine criteria established to provide a
uniform basis for comparison.
1. Overall Protection: The "no action" alternative will not treat, remove, or provide any
barrier other than the minimal existing cover to landfill contents. With no impediment to
infiltration of precipitation, leaching and downward movement of contaminants will continue
through the soil toward the water table if no action is taken. Air-born dispersion of volatilized
organic compounds and fugitive dust emissions would remain a problem. The "no action"
alternative does not guarantee overall protection of human health and the environment. This
alternative is not considered further in this analysis as an option for the landfills. Both capping
alternatives will prevent direct contact with landfill contents and contaminated dust. Both
capping options will also prevent the transport of volatile organic compounds to the atmosphere
and will reduce the rate at which chemicals move to the water table.
2. Compliance with ARARs: Alternative 2 would comply with RCRA subtitle D cap
requirements but not subtitle C cap requirements. Alternative 3 would comply with relevant and
appropriate RCRA subtitle C landfill closure requirements. Both capping alternatives would
comply with other applicable or relevant and appropriate State and Federal environmental laws
and regulations, except for groundwater chemical-specific ARARs which are temporarily
waived using the interim measures waiver.
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The Wyoming Water Quality Rules and Regulations, Chapter XVH, Appendix A, risk
assessment and fate and transport procedures were considered during the Feasibility Study and
in the selection of a remedy for this interim action. The parties to this ROD agree that the
selected remedy of a RCRA subtitle C landfill cap meets the intent of this regulation. The
parties to this ROD further agree that non-inclusion of Chapter XVII of the Wyoming Water
Quality Rules and Regulations as an ARAR in the ROD for this interim action was disputed and
will not be raised as a basis for an inconsistent application objection under 42 U.S.C. Section
9621(d)(4)(E) to identification of Chapter XVH as an ARAR for other actions.
A complete listing of the ARARs may be found at Appendix A. Waived groundwater
ARARs may be found at Appendix B.
3. Long-Term Effectiveness and Permanence: The capping alternatives leave the landfill
contents in place. Both alternatives will require the same institutional controls and regular
maintenance to ensure that the caps will continue to provide an appropriate level of protection
against direct contact, air transport, and erosion, as well as maintaining a barrier to infiltration.
Transport of contaminants to the ground water is diminished by either cap since the reduction of
infiltration lessens the amount of leachate produced. The composite cap is potentially more
reliable than the compacted-soil cap because of the addition of the synthetic membrane liner.
4. Reduction of Toxicity, Mobility, and Volume through Treatment: Because no treatment
technology is proposed under any of the alternatives, the considerations pertaining to treatment
technologies are not relevant.
5. Short-Term Effectiveness: The initial preparation for placement of either cap on the
landfills would cause disturbance of the existing ground surface. During this operation dust
could be generated and volatiles may be released to the air which would pose a minor, but
temporary, risk to both workers and the surrounding community. These risks will be minimized
by following health and safety procedures. Air monitoring will be used to assess the
requirement for temporary control measures during construction.
6. Implementability: The two capping options have no serious implementability problems,
and from a technical standpoint, implementation of either alternative should be fairly
straightforward. Other than adhering to site safety requirements, no special techniques,
materials, or labor would be required to prepare the site and place the compacted soil
(single-barrier) cap. All materials and equipment can be obtained locally. The geosynthetics
involved in the composite (multiple-barrier) cap require special handling techniques and labor
for proper placement of the layers to ensure integrity. Contractors with the appropriate
specialized experience are available.
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7. Cost: The capital cost differences between the two capping alternatives is due entirely to the
larger number of materials and special handling required for the composite cap. Yearly
operation and maintenance costs are estimated to be the same for both alternatives. The
comparison of the estimated project design and implementation costs is as follows:
Alternative 2, Compacted Soil Cap
w/ gas venting system, Landfill 6 $ 11.600.000
ALTERNATIVE 2, 30 YEAR
PRESENT WORTH TOTAL $ 15,700,000
Alternative 3, Composite Cap
w/ gas venting system, Landfill 6 $ 15.600.000
ALTERNATIVES, 30 YEAR
PRESENT WORTH TOTAL $ 19,700,000
8. State Acceptance: The State of Wyoming supports the preferred alternative as a partial
remedy, but has expressed concerns regarding the potential for landfill contents to be in contact
with ground water and for liquid wastes to be present in the landfill. These issues are more fully
discussed in Section D., STATE CONCERNS, of the Responsiveness Summary for the Record
of Decision.
9. Community Acceptance: The general community, consisting of the residents of the City of
Cheyenne, Laramie County, and F. E Warren AFB, have not expressed any comments or
concerns and apparently support the preferred alternative.
The Air Force's selected remedy for Operable Unit 3, Landfill 6 is alternative number 3.
9.0 STATUTORY DETERMINATIONS
The Air Force's selected remedy for Operable Unit 3, Landfill 6 is alternative number 3.
The selected remedy meets the statutory requirements of Section 121 of CERCLA as amended
by SARA. These statutory requirements include protectiveness of human health and the
environment, compliance with ARARs, cost effectiveness, utilization of permanent solutions and
alternative treatment technologies to the maximum extent practicable and preference for
treatment as a principal element. However, because treatment of the principal threats of the site
was not found to be practicable, this remedy does not satisfy the statutory preference for
treatment as a principal element of the remedy. The size of the landfill and the fact that there
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are no apparent on-site hot spots that represent the major sources of contamination preclude a
remedy in which contaminants could be excavated and treated effectively. The selected remedy
does comply with Section 300.403(a)(iii)(B) of the National Contingency Plan (NCP) which
states that engineering controls, such as containment, should be used for wastes that pose a
relatively low long-term threat or where treatment is impracticable. The preamble to the NCP
identifies CERCLA municipal landfills as a type of site where treatment of the waste may be
impracticable because of the size and heterogeneity of the contents. Subsequent actions are
planned to address the downgradient contamination associated with Landfill 6.
Since ground water chemical-specific ARARs will not be met by this action, these
requirements are temporarily waived using the interim measures waiver, granted through the
signing of this Record of Decision. The interim measures waiver will not cause additional
movement of contaminants, complicate the site response, present an immediate threat to public
health or the environment, or interfere with or delay the final remedy. The ground water
chemical-specific ARARs will be met in the final cleanup action for Operable Unit 3-Landfill 6.
10.0 EXPLANATION OF SIGNIFICANT CHANGES
The Proposed Plan was released for public comment in April, 1995. The preferred
alternative was for a source control action that includes capping and an active gas venting
system, and that this action is protective of human health and the environment. The USAF,
EPA, and WDEQ reviewed all written and verbal comments submitted during the public
comment period. It was determined that no significant changes were necessary to the preferred
alternative.
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RESPONSIVENESS SUMMARY FOR THE RECORD OF DECISION
INTERIM ACTION, OPERABLE UNIT 3: LANDFILL 6
INTRODUCTION
The responsiveness summary is organized into sections as follows:
A. Overview
B. Background on Community Involvement
C. Summary of Comments Received
D. State Concerns
Attachment: Community Relations Activities at F. E. Warren Air Force Base
A. OVERVIEW
At the time of the public comment period, the preferred alternative for the interim action at
Operable Unit 3, Landfill 6, at F. E. Warren Air Force Base, had been selected by the Air
Force, with EPA and Wyoming DEQ concurrence and was presented in the Proposed Plan.
The preferred alternative is a source control action that includes capping and an active gas
venting system.
Based on the public's response and comments received during the public comment
period, there are no significant objections to the preferred alternative.
B. BACKGROUND ON COMMUNITY INVOLVEMENT
Community interest in CERCLA/IRP (Installation Restoration Program) activities at F.
E. Warren Air Force Base has waxed and waned over the years since the records search and
interviews conducted for the Air Force in September 1985. No specific individuals or
organizations have been consistently involved over this period, although numerous groups and
persons have been involved from time to time. There were no concerns expressed during the
OU3, Landfill 6, Remedial Investigation, prior to the public comment period.
C. SUMMARY OF COMMENTS RECEIVED
The public comment period on the Proposed Plan for the Operable Unit 3: Landfill 6
interim action at F. E. Warren Air Force Base was held from April 17, 1995 to May 16, 1995.
Comments received during this time are summarized below. Similar comments have been
combined where possible to prevent duplication of responses. There were no specific legal or
technical questions.
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D. STATE CONCERNS
The State of Wyoming is concerned that waste materials contained in Landfill 6 may be
residing in ground water at times when the water table is elevated. As has been described in the
Record of Decision (ROD), the installation of a cap will significantly reduce the potential for
precipitation to infiltrate the landfill contents and contribute to ground water leachate. However,
the cap will not prevent the ongoing contamination of ground water if the landfill materials are
in contact with ground water. Additionally, the potential for liquid wastes to be present in the
landfill exists which would also constitute a source of ground water contamination not addressed
by the installation of the cap. For these reasons, the State of Wyoming supports the construction
of the cap as a partial solution. The outstanding issues of direct contact between the landfill
materials and ground water, and possible liquid wastes within the landfill are to be investigated
and addressed during the remaining investigations and comprehensive ROD at the completion of
investigation and feasibility studies for the site.
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ATTACHMENT A
COMMUNITY RELATIONS ACTIVITIES
At
F.E. WARREN AIR FORCE BASE
OVERVIEW
The unique community involvement needs of F. E. Warren Air Force Base
ERP/CERCLA activities are addressed in the Community Relations Plan (CRP). In late 1990,
during plan development, interviews were held with 56 people representing F. E. Warren Air
Force Base, other Federal agencies, State, city and county agencies, community groups, well
owners, and other individuals. The most significant issues identified in the interviews were
concerns about potential drinking water contamination and about the community involvement
process. A brief description of each of the activities which have been developed to address the
unique F. E. Warren Air Force Base situation is contained in this attachment.
HISTORY OF COMMUNITY INVOLVEMENT
News releases and articles in the Cheyenne and F. E. Warren Air Force Base
newspapers have been part of the IRP process since 1985. Briefings were provided to
congressional staffs, the Governor, and mayor in addition to Federal agencies, Wyoming State
departments, and local government officials directly responsible for resources potentially
affected by the IRP process. Presentations were made to various community groups such as
Optimist Club, Military Affairs Committee, Civilian Advisory Council, Society of American
Military Engineers, and Wyoming Against MX. Information was disseminated at F. E. Warren
Air Force Base through the Commanders Call which reaches all enlisted personnel through the
command structure.
The Technical Review Committee was established as part of the IRP/Superiund process
and had its first meeting in May of 1988. The three initial public members were nominated by
the Governor of Wyoming, Mayor of Cheyenne, and Laramie County Commission. This
committee's membership and a general knowledge of the community, served as the initial basis
for the selection of people to be interviewed. One of the peripheral goals of the interview
process was to provide a list of potential candidates for the public representatives on the TRC.
An environmental display was presented in July 1990 in the Base Exchange Mall.
Pictures of all IRP sites were displayed. Site specific fact sheets, environmental brochures, and
EPA literature were made available.
The process designed to tailor the CRP to local concerns, needs, and conditions began in
February 1990 with interviews of a former base commander and a concerned citizen who are
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both involved in a variety of groups within the community. Interviews were also held at the
regular March meeting of Wyoming Against MX, attended by 4 Air Force, 2 EPA, and 1 State
official working on the IRP/Superfund process, in addition to 10 members of the group itself.
These initial public contacts focused on identifying critical public concerns.
The purpose of the community interviews was to identify groups and issues which may
relate to the F. E. Warren Air Force Base IRP/Superfund process. Thirty-four interviews were
conducted with 56 people, either representing themselves or 20 groups within the area. The
Wyoming Department of Environmental Quality and City/County Health were particularly
helpful in accompanying interviewers.
Among the people interviewed were congressional staffers, an official Air Force
representative, F. E. Warren Air Force Base housing residents, non-DOD Federal agencies and
state and local government agencies. Among community groups a wide range of interests were
sampled. There were three individuals identified as involved with a variety of groups, but
viewed as reputational leaders beyond their group membership.
Special emphasis was placed on interviewing those who rely on private wells adjacent to
F. E. Warren Air Force Base for drinking water. An introductory letter, Fact Sheet, and
discussion guide were prepared for the interviews. The Fact Sheet was actually a status report
on the IRP/Superfund process with a brief description of each of the sites. The purpose of the
status report was to provide information and a basis of discussion for those who might not have
heard of the program and included an installation map with the sites and key features of F. E.
Warren Air Force Base and immediate surrounding area. These fact sheets and the introductory
letter were made available for distribution to all interested parties.
Interviews took place in October and November 1990, with a few follow-up interviews
and phone conversations continuing into December.
During the interview process it was recognized that the neighborhood located on the
south boundary of F. E. Warren Air Force Base depends on domestic wells for drinking water.
An agreement was made with the City/County Health Department and Wyoming Department of
Environmental Quality to process a small number of water samples, if residents requested it.
Sample collection was done December 4th and 5th, 1990, by a conjunctive effort of DEQ,
City/County Health, and EPA personnel.
ISSUES AND CONCERNS
Based on the community interviews, IRP/Superfund activities are not a source of
significant concern to the greater Cheyenne community. This may be due to the public's belief
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that the contamination is contained within the boundaries of F. E. Warren Air Force Base. The
potential for drinking water contamination is the most significant issue associated with the
IRP/Superfund process. Awareness of this issue beyond those who were involved with the
process was practically nonexistent.
None of the drinking water well users contacted in the interviews were aware of the
IRP/Superfund process or the potential contamination. The initial reaction of well owners was
extreme concern. However, after being provided information about the IRP/Superfund
activities and an opportunity to have wells tested by City/County Health and the Wyoming
Department of Environmental Quality, their concern decreased. They continue to have a high
level of interest and awareness, and want to be kept informed on a regular basis.
The need to keep the community informed and involved was mentioned frequently in the
interviews. In the business community, there was confidence in the Air Force's ability to solve
the problem. Other groups, such as Wyoming Against the MX, and the potentially affected
neighborhoods, indicated a need for greater community information and involvement than had
been provided prior to the interviews and adoption of the Community Relations Plan.
The community relations program for the IRP/Superfund activities is designed to inform
the public about, and provide opportunities for participation in, the process. To be effective, the
community relations program will be responsive to the level of interest expressed by the
community. At this time, the primary need voiced by the public is to be kept well informed of
the status of activities and to be involved in the decision making process.
The potential for TCE contamination in the ground water surrounding F. E. Warren Air
Force Base is the most sensitive issue identified in the community interviews associated with the
entire IRP/Superfund process.
SPECIAL CONSIDERATIONS
Interviews with residents in the Nob Hill and Fairacres neighborhoods revealed that
direct contact with members of the neighborhood is the most effective method of providing
necessary information. This approach was confirmed during 1994 with 5 neighborhood
meetings conducted for the two areas as a result of concerns about off base contamination.
ADMINISTRATIVE RECORD REPOSITORY
An Administrative Record Repository containing documentation of the IRP/CERCLA
process was established in October 1989 and is maintained at the following locations to insure
accessibility.
Laramie County Library 90 CES/CEVR
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Reference Section Environmental Restoration Section
2800 Central Avenue 300 Vesle Drive
Cheyenne WY 82001 F. E. Warren AFB WY 82005-2788
Phone (307) 634-3561 Phone (307) 775-3468
This record is maintained according to EPA guidelines, by the Environmental Restoration
Flight, and is updated at least quarterly. The Administrative Record Repository also functions
as the required information repository. A copy of the Administrative Record is housed in the
Laramie County Library reference section to insure public access.
TECHNICAL REVIEW COMMITTEE
Procedures to establish the TRC began in November 1987. Actual meetings began in
May of 1988. They are held quarterly, generally on the fourth Wednesday in January, April,
July, and October. TRC public members were nominated by the Governor of Wyoming,
Laramie County and the city of Cheyenne, Wyoming. The purposes of the committee are as
follows:
1. The purpose of the TRC is to review and comment on Department of Defense actions
and proposed actions with respect to releases or threatened releases of hazardous substances into
the environment at F. E. Warren Air Force Base, as well as to ensure open communication and
exchange of ideas relating to the F. E. Warren Air Force Base IRP and Comprehensive
Environmental Response, Compensation, and Liability Act - CERCLA, 1980, Superfund
Amendments and Reauthorization Act, 1986.
2. All TRC members understand and agree that the primary purpose and function of the
TRC is informational, specifically to foster community and inter-agency awareness and
understanding of F. E. Warren Air Force Base actions with respect to the IRP remedial actions
related to the releases or threatened releases of hazardous substances at F. E. Warren Air Force
Base , Wyoming, and to inform F. E. Warren Air Force Base of community attitudes. The
TRC also serves as the entity to deal with public concerns regarding hazardous substance
releases and the ERP.
RESTORATION ADVISORY BOARD
In an effort to improve public participation in environmental cleanup activities at F. E.
Warren Air Force Base, a Restoration Advisory Board (RAB) has been formed to replace the
TRC. The RAB consists of community volunteers and representatives from the Base, EPA and
WDEQ. It is chaired by a community member and a senior base official.
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The board offers community members the opportunity to provide input to the decision
making process used by the base to clean up contaminated sites.
MAILING LIST
A major part of the public relations activities is the mailing list. In an attempt to
proactively contact the 2,300 well owners identified in the EPA Superfund ranking, F. E.
Warren sent a general mailing to well owners within a 3-mile radius. The Wyoming State
Engineer's Office provided the mailing list of well owners. The mailing included a brief status
report and a coupon to be mailed back if the well owner wanted to be added to the mailing list
for distribution of later status reports. This activity resulted in the current list that has about
1450 names on it. The mailing list is maintained in the F. E. Warren Air Force Base Public
Affairs Office. Status Reports or Fact Sheets are mailed on a quarterly basis. Anyone who
desires to be included on the list should contact either of the following offices.
90MW/PA 90CES/CEVR
5305 Randall Ave 300 Vesle Drive
F.E. Warren AFBWY 82005-2271 F. E. Warren AFB WY 82005-2788
Phone (307) 775-3381 Phone (307) 775-3468
INFORMATION CONTACT
An information contact person has been designated within the F. E. Warren Air Force
Base Environmental Restoration Section to maintain regular contact with the community. This
person is responsible for responding to requests for information and planning and scheduling
activities included in the plan. The preparation of materials for public distribution will be
coordinated with the Public Affairs Office. General public information requests should be
directed to (307) 775-4353. The media contact for F. E. Warren Air Force Base is the Public
Affairs office at (307) 775-3381.
DRINKING WATER WELL SAMPLING
City/County Health Department has been sampling wells south of F. E. Warren Air
Force Base since 1988. At the outset of the interview process, it became evident that owners of
private drinking water wells south of F. E. Warren Air Force Base were not aware of the
IRP/Superfund process or any potential contamination. Air Force concern prompted an
agreement for water sampling made with City/County Health and Wyoming State Department of
Environmental Quality, Water Quality Section (WDEQ) to provide for the testing of wells for
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concerned citizens. The agreement was to cover less than 10 wells. During the interview
process, some concerns bordering on alarm were encountered. Such concerns were lowered
with the testing procedure. The testing was not part of the technical scientific sampling done for
the IRP/Superfund process because the criteria for sampling was solely based on individual
citizen concerns. The testing took place on December 4 and December 5, 1990. In addition to
the City/County Health and DEQ personnel, two EPA staff from the Denver Office assisted.
Sampling was also conducted during June 1991 through July 1992.
In some cases, nitrate concentrations were found to exceed the Federal Drinking Water
Standard of 10 milligrams per Liter. The test results were presented by individual meetings with
all well owners whose wells were tested. These meetings were held by WDEQ with an EPA
toxicologist present. Courtesy copies of the test results were provided by WDEQ to all involved
agencies including the Air Force. USAF, WDEQ, and EPA scheduled an availability session to
provide an opportunity for Nob Hill and Fairacres residents to discuss the WDEQ testing.
As a result of the remedial investigation work at the landfill sites, residential wells in both
neighborhoods were sampled again in 1994. To date, a series of five neighborhood meetings
have been held to discuss the sampling results and the options for actions the Air Force is
planning to take.
OU3 RELATED ACTIVITIES
Operable Unit 3:Landfill 6 has been addressed in Fact Sheets, Status Reports, newspaper
advertisements and articles since Fact Sheet 1 was prepared, by the Air Force, in October 1990
for the initial interviews. Fact Sheet 1 was mailed in May 1991. After the Federal Facility
Agreement became effective, a Status Report update was distributed on December 12, 1991,
with information on all of the operable units. Since then, the quarterly status update reports
have informed the public about OU 3 and Landfill 6 activities on a regular basis.
The Proposed Plan for OU3:LF6 was prepared in April, 1995. A display advertisement
concerning the Proposed Plan and the public meeting was placed in the Wyoming Tribune-Eagle
on April 8, 1995. Another public announcement was placed in the Casper Star-Tribune on
April 8, 1995, and a copy of the Proposed Plan was sent to all persons on the mailing list. A
copy of the Proposed Plan was placed in the Administrative Record and the Laramie County
Library Records Repository on May 15, 1995. All of the newspaper advertisements and the
mailings were coordinated between the Air Force, EPA and Wyoming DEQ before publication
or distribution. In addition to the paid advertisements, the Air Force issued press releases which
resulted in articles published in the Wyoming Tribune-Eagle on April 26, 1995, and the F. E.
Warren Air Force Base Sentinel on April 21, 1995.
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Appendix A
Federal and Wyoming State
Applicable, or Relevant and Appropriate Requirements (ARARs)
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-------
Table A-l - Federal Chemical-Specific ARARs
[USC, United States Codes; CFR, Code of Federal Regulations; Statute; Exec.,Executive; DOT, Department of Transportation; FS, Feasibility Study)
Standard requirement,
criteria, or limitation
Clean Water Act
USEPA Toxic Pollutant Standards
Clean Air Act
National Primary and Secondary Ambient Air
Citations
33 USC 1251-1376
40 CFR 129
42 USC 740 1-7642
40 CFR 50
Description
Establishes effluent standards or
prohibitions for certain toxic pollutants
Establish standards for ambient air quality
Applicable/
Relevant and
Appropriate
No/No
Yes/NA
Comments
Listed toxins not detected in ground-
water or surface water at site.
Emissions from interim action
Quality Standards
National Emission Standards for Hazardous
Air Pollutants
to protect public health and welfare
(including standards for particulate matter
and lead)
40 CFR 61, Subpart A Establish regulatory standards for specific
hazardous air pollutants
Standards of Performance for New Stationary 40 CFR 60, Subpart
Sources WWW (Proposed)
Resource Conservation and Recovery Act
Hazardous Waste Management System:
General
40 CFR 260
Identification and Listing of Hazardous Waste 40 CFR 261
Land Disposal Restrictions
40 CFR 268
Establish performance standards for
venting of landfill gases as a type of new
stationary source.
Establish definitions as well as procedures
and criteria for modification or revocation
of any provision in 40 CFR Parts 260-265
Define those solid wastes which are
subject to regulations as hazardous wastes
under 40 CFR 264
Identity hazardous wastes that are
restricted from land disposal and defines
those limited circumstances under which a
prohibited waste may continue to be land
disposed
remediation process will be subject to
NAAQS unless state standards are
more stringent.
No/Yes Current assessments indicate
regulation is not relevant and
appropriate, but venting of landfill
gases reaching regulatory thresholds
could possibly make this regulation
relevant and appropriate.
No/No Proposed regulation establishing
standards for landfills as specific
sources of air pollution, if
promulgated, will be considered
during remedial design phase.
No/No Involved as needed to implement
other 40 CFR 264 substantive
requirements.
Yes/NA Applicable in identifying listed or
characteristic hazardous waste in
landfill subject to 40 CFR 264
substantive requirements.
No/No Interim action will generate no
prohibited wastes beyond boundaries
of site.
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Table A-1 - Federal Chemical-Specific ARARs
(Continued)
Standard requirement,
criteria, or limitation
Citations
Description
Applicable/
Relevant and
Appropriate
Comments
Hazardous Chemical Reporting Community Right- 40 CFR 370
To-Know
Corrective Action tor Solid Waste Management 55 FR 30798
Units
Standards for the Identification and Listing of 57 FR 21450
Hazardous Wastes
Land Disposal Restrictions for Newly Listed 59 FR 958
Wastes and Contaminated Debris
Establish reporting requirements which
provide the public with important
information on the hazardous chemicals in
their communities
No/No
No/No
No/No
No/No
Independent administrative
requirements, but not substantive
standards.
Interim action will generate no wastes
beyond boundaries of site.
Interim action will generate no wastes
beyond boundaries of site.
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Table A-2 - State Chemical-Specific ARARs
[CFR, Code of Federal Regulations; P.L, Public Law; W.S., Wyoming Statute]
Standard requirement, Citations
criteria, or limitation
Wvomin* Environmental Qualitx Act W S. 35-1 1-101 to 35-1 1-
1428
Wyoming Environmental Quality Act. Art 2 W S. 35-1 1-201
Wyoming Air Quality Standards and Regulations
Section 2
Section 3 (b)
Section 4
Section 6
Section 7
Section 8
Section 9
Section 10
Section 1 1
Section 12
Description
Discharge or emission of air contaminants
Definitions
Total Suspended Particulates
Sulfur Oxides
Sulfation
Hydrogen Sulfide
Photochemical Oxidants
1 ly drocarbons
Nitrogen Oxides
Fluorides
Carbon Monoxide
Applicable/
Relevant and
Appropriate
Yes/NA
No/No
Yes/NA
Yes/NA
Yes/NA
Yes/NA
No/No
Yes/NA
No/No
No/No
No/No
Comments
Compliance with state air quality numeric and
other substantive requirements identified as
ARARs satisfies all requirements of this
provision.
Involved as needed to implement other WAQS
requirements.
Emissions from interim action will be subject to
standards.
Emissions from interim action will be subject to
standards.
Emissions from interim action will be subject to
standards.
Emissions from interim action will be subject to
standards.
No photochemical oxidants anticipated during
interim action.
Emissions from interim action will be subject to
standards.
Emissions from interim action will be subject to
federal standards.
No fluoride emissions anticipated during
interim action.
Emissions from interim action will be subject to
federal standards.
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Table A-2 - State Chemical-Specific ARARs
(Continued)
Standard requirement,
criteria, or limitation
Citations
Section 26
Description
Ambient Air Quality Standard for Lead
Applicable/
Relevant and
Appropriate
No/No
Comments
Emissions from interim action will be subject to
Wyoming Environmental Quality Act. Article 3
WS. 35-1 1-301
Prohibits certain acts without a permit
Wyoming Water Quality Rules and Regulations
Chapter 1
Quality Standards for Wyoming Surface
Waters
Department of Environmental Quality Consolidated
Hazardous Waste Rules and Regulations
Chapter XVII
Chapter I
Chapter II
Underground Storage Tanks
General Provisions
Identification and Listing of Hazardous
Wastes
federal standards.
Yes/NA Although there is no federal counterpart which
meets or exceeds the requirement that there be
no threat to pollute the waters of the state, the
selected remedy of a RCRA subtitle C landfill
cap will comply with and meet the intent of this
requirement for this interim action The
selected remedy will adequately reduce any
threat to groundwater or surface water quality
from migration of landfill contaminants
resulting from infiltration or surface runoff of-
precipitation. Further, compliance with state
water quality substantive requirements (permits
are not required) identified as ARARs satisfies
all requirements of this provision.
Yes/NA Site runoff will be subject to substantive
chemical-specific numeric standards for surface
waters and discharges to surface waters, if
more stringent than federal standards.
Comments to W.S. 35-11-301 above apply to
Chapter I, section 1, prohibiting the threatening
of violating a surface water quality standard.
No/No See Record of Decision, Section 80
No/No Involved as needed to implement other CI1WR
requirements.
No/No Interim action will generate no wastes beyond
boundaries of site.
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Table A-3 - Federal Action-Specific ARARs
[USC, United States Codes; CFR, Code of Federal Regulations; P.L, Public Law; Stat., Statute; Exec.,Executive; DOT, Department of Transportation]
Standard requirement,
criteria, or limitation
Citations
Description
Applicable/
Relevant and
Appropriate
Comments
Safe Drinking Water Act
Underground Injection Control Regulations
Clean Water Act
NPDES Storm Water Regulations
National Pretreatment Standards
Dredge and Fill
USEPA Toxic Pollutant Standards
Clean Air Act
National Primary and Secondary Ambient Air
Quality Standards
National Emission Standards tor Hazardous
Air Pollutants
42 USC 300g
40 CFR 144 to 147
33 USC 1251-1376
40 CFR 122
40 CFR 403
40 CFR 230
33 CFR 320 to 330
40 CFR 129
42 USC 7401-7642
40 CFR 50
40 CFR 61. Subpart A
Establishes regulations for subsurface No/No
injections for protection of ground water
used for drinking water
Establishes requirements for discharge of Yes/NA
storm water.
Establishes standards for controlling No/No
pollutants which pass through or interfere
with treatment processes in POTW or
which may contaminate sewage sludge
Establishes requirements for permits to No/No
authorize the discharge of dredged or fill
material into navigable waters
Establishes effluent standards or No/No
prohibitions for certain toxic pollutants
Establish standards for ambient air quality Yes/NA
to protect public health and welfare
(including standards for participate matter
and lead)
Establish regulatory standards for specific No/Yes
air pollutants
Interim action does not include injection.
Storm water runoff may occur from the
site making substantive requirements
applicable.
Interim action does not include
pretreatment.
Interim action does not include discharge
of dredged or fill material
Listed toxins not detected in groundwater
or surface water at site.
Emissions from interim action
remediation process will be subject to
NAAQS unless state standards are more
stringent.
Current assessments indicate regulation
is not relevant and appropriate, but
venting of landfill gases reaching
regulatory thresholds could possibly
make this regulation relevant and
appropriate.
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Table A-3 - Federal Action-Specific ARARs
(Continued)
Standard requirement, Citations
criteria, or limitation
Description
Applicable/
Relevant and
Appropriate
Comments
Standards of Performance for Ne\\ Stationary 40 CFR 60. Subpart
Sources WWW (Proposed)
Standards of Performance for Volatile
Organic Storage Vessels
Standards of Performance for Incinerators
Solid Waste Disposal Act
Guidelines for the Land Disposal of Solid
Wastes
Criteria for Classification of Solid Waste
Disposal Facilities and Practices
Resource Conservation and Recovery Act
Hazardous Waste Management System:
General
Standards Applicable to Generators of
Hazardous Wastes
Standards Applicable to Transporters of
Hazardous Wastes
40 CFR 60
Subpart Kg
40 CFR 60
Subpart E
42 USC 6901-6987
40 CFR 241
40 CFR 257
40 CFR 260
40 CFR 262
40 CFR 263
Establish performance standards for No/No
venting of landfill gases as a type of new
stationary source.
Establishes standards of performance for No/No
storage tanks containing volatile organic
liquids
Establishes standards of performance for No/No
solid waste incinerators
Establish requirements and procedures for No/No
land disposal of solid wastes
Establish criteria for use in determining No/No
which solid waste disposal facilities and
practices pose a reasonable probability of
adverse effects on health or the
environment
Establish definitions as well as procedures No/No
and criteria for modification or revocation
of any provision in 40 CFR Parts 260-265
Establish standards for generators of No/No
hazardous waste
Establish standards which apply to No/No
persons transporting hazardous waste
within the U.S. if the transportation
requires a manifest under 40 CFR Part 262
Proposed regulation establishing
standards for landfills as specific sources
of air pollution, if promulgated, will be
considered during remedial design phase
Interim action does not include storage of
volatile organic liquids.
Interim action does not include
incineration.
Interim action does not include handling
residential or commercial sanitary waste.
Relevant but not appropriate to selected
remedy.
Involved as needed to implement other 40
CFR 264 substantive requirements.
Unhazardous waste is generated during
construction, this regulation would apply
If hazardous waste is generated during
construction, this regulation would apply
-------
Table A-3 - Federal Action-Specific ARARs
(Continued)
Standard requirement,
criteria, or limitation
Standards lor Owners and Operators of Hazardous
Waste Treatment. Storage, and Disposal Facilities
General Facilit\ Standards
Preparedness and Prevention
Citations
40 CFR 264
Subpart H, Section
264.18(b)(l)(n)
Subpart C. Section
264.31
Description
Establishes washout standards for design,
construction, maintenance and operation
of existing hazardous waste landfills.
Establishes general requirement for design,
construction, maintenance and operation
Applicable/
Relevant and
Appropriate
No/Yes
No/Yes
Comments
Relevant and appropriate if landfill
located within a 100-year floodplain as
defined in 40 CFR 264.18 (bX2).
Contingency Plan and Emergency Procedures Subpart D
Manifest System Record Keeping and
Reporting
Releases from Solid Waste Management
Units
Closure and Post Closure
Financial Requirements
Use and Management of Containers
Subpart E
Subpart F, Sections
264.97, 264.98,
264.99
Subpart G, Sections
264.11L 264.116,
264.117
Subpart H
Subpart 1
of hazardous waste facilities to minimize
the possibility of fire, explosion or
unplanned release.
Establishes requirements for a contingency
plan and emergency procedure at
hazardous waste treatment, storage, and/or
disposal facilities
Establishes requirements for the manifest
system, record keeping, and reporting at
hazardous waste treatment, storage, and/or
disposal facilities
Establishes requirements for detection and
monitoring of releases into ground-water
from hazardous waste treatment, storage,
and/or disposal facilities
Establishes general standards for closure
and post-closure at hazardous waste
treatment, storage, and'or disposal
facilities
Establishes fiscal requirements for liability
insurance and financial assurance for
closure and post-closure at hazardous
waste treatment, storage, and/or disposal
facilities
No/No Involved as needed to implement other 40
CFR 264 substantive requirements.
No/No Involved as needed to implement other 40
CFR 264 substantive requirements.
No/Yes Ground-water monitoring requirements
applicable. Subpart F concentration
limits in Section 264.94 located in
Appendix B.
No/Yes Interim action qualifies as part of the
process of closure. Section 264.116 only
applicable to extent of requiring surveyed
benchmarks of the landfill.
No/No Not a substantive requirement
No/No Interim action does not include storage of
containers of hazardous waste.
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Table A-3 - Federal Action-Specific ARARs
(Continued)
Standard requirement,
criteria, or limitation
Tanks
Surface Impoundments
Citations Description
Subpart J
Subpart K. Establishes design and operational
Applicable/
Relevant and
Appropriate
No/No
No Yes
Comments
Interim action does not include storage of
containers of hazardous waste.
Surface impoundment may be used
Waste Piles
Land Treatment
Landfills
Standards for Incinerators
Standards for Miscellaneous Units
Subpart 1.
Subpart M
Subpart N
Subpart O
Subpart X
Standards for Management of Specific Hazardous 40 CFR 266
Wastes & Specific Types of Hazardous Waste
Management Facilities
Land Disposal Restrictions
Underground Storage Tanks
40 CFR 268
40 CFR 280
requirements for surface impoundments
used for treatment, storage, and/or
disposal of hazardous wastes
Establishes design and operational
requirements for hazardous waste landfills
Establish requirements which apply to
recyclable materials that are reclaimed to
recover economically significant amounts
of precious metals including gold and
silver
Identity hazardous wastes that are
restricted from land disposal and defines
those limited circumstances under which a
prohibited waste may continue to be land
disposed
Establish regulations related to
underground storage tanks
during construction to control site runoff.
No/No Interim action does not include treatment,
storage, and/or disposal of hazardous
wastes in waste piles.
No/No Interim action does not include operation
of a hazardous waste land treatment unit.
No'Yes Interim action does not include operation
of a landfill. Standards for closure and
post-closure may be used.
No/No Interim action does not include operation
of an incinerator
No/No Interim action does not include operation
of a miscellaneous unit.
No^No Interim action does not include recycling
of materials
No/No Interim action does not include land
disposal of hazardous waste outside of
the site boundary.
No/No Interim action does not involve
underground storage tanks.
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Table A-3 - Federal Action-Specific ARARs
(Continued)
Standard requirement,
criteria, or limitation
Transport of RCRA Wastes to POTW
Citations
40 CFR 270.60
Description Applicable/
Relevant and
Appropriate
No/No
Comments
Interim action does not involve transport
Criteria for Municipal Solid Waste Landfills
Toxic Substances Control Act
40 CFR 258
15 USC 2601-2629
Polychlorinated Biphenyls (PCBs) Manufacturing, 40 CFR 761
Processing, Distribution in Commerce, and Use
Prohibitions
Asbestos Abatement Projects 40 CFR 763
Subpart G
DOT lla/.ardous Material Transportation 49 CFR 170-177
Regulation
Miscellaneous
Requirements for the Treatment and Disposal of 40 CFR 161
Insecticides, Fungicides and Rodenticides
Dioxin Furan Requirements
Effluent Guidelines and Standards for the Point
Source Category
40 CFR 766
Guidelines for Source Separation for Material 40 CFR 246
Recovers
40 CFR 404-474
Establishes design and operational
requirements for municipal waste landfills
(RCRA, subtitle D)
Establish prohibitions of, and
requirements for, the manufacture,
processing, distribution in commerce, use,
disposal, storage, and marking of
polychlorinated biphenyls (PCBs) and
PCB items
Establish requirements which must be
followed during asbestos abatement
projects
Regulate transportation of hazardous
materials
Establishes requirements for the treatment
and disposal of concentrated insecticides,
fungicides, and rodenticides
Establishes requirements for
manufacturers, importers and processors
to identify substances with regulated
dioxins'furans
Establishes requirements for specific
effluent limitations and guidelines and
pretreatment standards for specific
industrial discharges under NPDES.
No "No
No "No
No/Mo
No/No
No/No
No No
No No
No/No
of waste to POTW.
Relevant but not appropriate to selected
remedy.
PCB's have not been detected at the site
Asbestos has not been detected at the
site.
Interim action does not involve
transportation of hazardous waste off
site.
Interim action does not involve the
management of concentrated pesticides.
Although Dioxin/Furan compounds have
been detected in one location at the site,
regulation does not address landfills.
Interim action docs not include recycling
of materials.
Interim action will involve no industrial
operation and none exist at the site.
10
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Table A-3 - Federal Action-Specific ARARs
(Continued)
Standard requirement,
criteria, or limitation
Standards for Protection Against Radiation
Citations
10CFR20
Description Applicable/
Relevant and
Appropriate
No/No
Comments
Although the presence of radioactive
Land Disposal Restrictions for Newly Listed 59 FR 958
Wastes and Contaminated Debris
No-No.
contaminants has not been investigated at
the site, site history does not include
disposal of radioactive wastes
Interim action will generate no wastes
beyond boundaries of site.
11
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Table A-4 - State Action-Specific ARARs
[CFR, Code of Federal Regulations; P.L, Public Law; W.S., Wyoming Statute]
Standard requirement,
criteria, or limitation
Citations
Description
Applicable/
Relevant and
Appropriate
Comments
Wyoming Environmental Quality Act. Art 2
WS. 35-11-201
Discharge or emission of air
contaminants
Wyoming Environmental Quality Act, Article 3 W.S. 35-11-301 Prohibits certain acts without a permit
Wyoming Environmental Quality Act, Art. 4 W.S. 35-1 M01(e)(iii) Land Quality
Wyoming Environmental Quality Act, Art. 5 W S 35-1 1-509
Wyoming, Air Quality Standards and Regulations
Section 2
Section 13
Section 14
Land ban on battery disposal
Definitions
Open Burning
Control of Participate Emissions
Yes MA
Yes/NA
No Yes
No Yes
Yes'lvIA
No/Yes
Yes/NA
Compliance with state air quality numeric and
other substantive requirements identified as
ARARs satisfies all requirements of this
provision.
Although there is no federal counterpart which
meets or exceeds the requirement that there be
no threat to pollute the waters of the state, the
selected remedy of a RCRA subtitle C landfill
cap will comply with and meet the intent of this
requirement for this interim action. The selected
remedy will adequately reduce any threat to
groundwater or surface water quality from
migration of landfill contaminants resulting from
infiltration or surface runoff of precipitation.
Further, compliance with state water quality
substantive requirements (permits are not
required) identified as ARARs satisfies all
requirements of this provision
Relevant and appropriate only if soil is borrowed
on-site to be used as capping materials.
Quantities required make this unlikely.
Definitions frequently action-based. Involved as
needed to implement other WAQSR
requirements.
Interim action does not involve open burning.
However may be applicable for flare treatment of
landfill gases.
Emissions from interim action will be subject to
standards.
12
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Table A-4 - State Action-Specific ARARs
(Continued)
Standard requirement, Citations
criteria, or limitation
Section
Section
Section
Section
Section
Section
Section
(J)
Section
15
1 6 ( a ). ( c )
17
18
19
20
21(c)(v)and
22
Description
Wood Waste Burners
Odors
Motor Vehicle Pollution Control
Diluting and Concealing Emissions
Abnormal Conditions and Equipment
Malfunctions
Air Pollution Emergency Episodes
Permit Requirements for Construction,
Modification and Operations
New Source Performance Standards
Applicable/
Relevant and
Appropriate
No/No
YesNA
Yes/NA
Yes'NA
Yes/NA
Yes NA
Yes/NA
No/No
Comments
Interim action does not involve wood waste
burning.
Emissions from interim action will be subject to
standards.
Motor vehicles used during interim action will be
subject to standards.
Emissions from interim action will be subject to
standards.
Interim action will be subject to standards.
Interim action will be subject to standards.
Although permits are not required, substantive
requirements of BACT apply.
Proposed federal regulation at 40 CFR Part 60,
Wyoming Water Quality Rules and Regulations
Section 24
Section 28
Chapter I
Prevention ol Significant Deterioration Yes/NA
Visibility YesNA
Quality Standards for Wyoming Surface Yes NA
Waters
Subpart WWW, will be considered if
promulgated.
Emissions from interim action will be subject to
standards.
Emissions from interim action will be subject to
standards. Applicable only if area of landfill
redesignated as a Class 1 area.
Site runoff will be subject to substantive
chemical-specific numeric standards for surface
waters and discharges to surface waters, if more
stringent than federal standards. Comments to
W.S. 35-11-301 above apply to Chapter I,
section 1, prohibiting the threatening of
violating a surface water quality standard.
13
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Table A-4 - State Action-Specific ARARs
(Continued)
Standard requirement, Citations
criteria, or limitation
Description
Applicable/
Relevant and
Appropriate
Comments
Chapter II
Chapter III
Discharges Permit Regulations for No/No
Wyoming
Regulations for Permit to Construct, Yes/NA
Install or Modify Public Water Supplies.
Wastewater Facilities, and other
Facilities Capable of Causing or
Contributing to Pollution
Although permits are not required, substantive
requirements of other regulations must be met
Discharge standards may be used.
Although permits are not required, substantive
requirements of regulation apply
Wyoming Solid Waste Management Rules and
Regulations
Chapter IV
Chapter IX
Chapter XI, Section 31
and Part O
Chapter XVII
Chapter XVIII
Chapter 1
Chapter II
Regulations for Release of Oil and
Hazardous Substances into Waters of the
State of Wyoming
Wyoming Groundwater Pollution
Control Permit
Design and Construction Standards for
Sediment Control Facilities and Monitor
Wells
Underground Storage Tanks
General NPDES Permits
General Provisions
Sanitarv Landfill Regulations
Yes/NA Site runoff will be subject to requirements. Also
applicable in the event fuels or other pollutants
are released during construction
No'No Not required.
Yes/NA Substantive requirements of these regulations
apply (permits are not required) if sediment
control structures or monitor wells are
constructed, or if existing monitor wells are
abandoned.
No/No See Record of Decision, Section 8.0.
No/No Although permits are not required, substantive
requirements for storm water discharges must be
met.
No/No Definitions action-based. Clarifies authority and
jurisdictional issues. Involved as needed to
implement other WSWMRR requirements.
No/No Landfill 6 does not fall under the definition of a
municipal landfill.
14
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Table A-4 - State Action-Specific ARARs
(Continued)
Standard requirement,
criteria, or limitation
Citations
Description
Applicable/
Relevant and
Appropriate
Comments
Chapter III
Chapter IV
Chapter V
Industrial Landfill Regulations
Construction and Demolition Landfill
Regulations
1 and farm Regulations (proposed)
No/No Interim action qualifies as part of the process of
closure, but selected remedy picks up RCRA
subtitle C standards
Nolvio Interim action does not involve construction and
demolition landfill activities.
No^No Interim action does not involve landfarming
Wyoming Hazardous Waste Management Rules
and Regulations
State Engineer's Office Rules and Regulations
Chapter VI
Chapter VII
Chapter VIII, Sections
3(bXi)&(ii)and
4(cXiii),(iv)&(v)
Chapter XV, Sections
ll(dXD(m),(p)&(q)
Chapter 1
Parti
Transfer, Treatment. Processing and
Storage Facility Requirements
Financial Assurance Requirements
Special Waste Management Standards
Wyoming Solid Waste Management
Rules and Regulations, 1975
General Provisions
Chapter II Rules and Regulations
Chapter X, Section Special Requirements for Liquids
Permitting Requirements for Use of
Wyoming Surface Waters
No'No Interim action does not involve transfer,
treatment, processing, or storage.
No/No Not a substantive requirement
Yes/NA Substantive requirements within this regulation
apply if landfill contains asbestos.
Yes/NA Requirements more stringent than 40 CFR 264
apply.
Definitions. Involved as needed to implement
other substantive WHWMRR requirements more
stringent than federal requirements.
No'No Describes type of waste contained in landfill
Yes/NA More stringent than 40 CFR 264.314 for
placement of liquids in hazardous waste landfill.
No/No No use of surface waters is anticipated for
interim action.
15
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Table A-4 - State Action-Specific ARARs
(Continued)
Standard requirement, Citations
criteria, or limitation
Pan 11 PC
Description
emitting Requirements for Use of
Applicable/
Relevant and
Appropriate
Ycs/NA
Comments
No use of ground water is anticipated for interim
Wyoming Game and Fish Regulations
Groundwater in the State of Wyoming
W S 23-1-101 Wyoming Game and Fish Department
Responsible for Wildlife Within the State
of Wyoming
Fish and Wildlife Wyoming Game and Fish Department
Coordination Act PI. Coordination with Activities on Federal
85-624 Land
action, and no new monitoring wells are
anticipated as part of this interim action, but
substantive requirements of this regulation
would apply although no permits are required.
Yes/NA Applicable in the event the interim action results
in an impact wildlife, although this is not
anticipated.
No/No In the event the interim action results in an
unanticipated impact on wildlife, an
administrative consultation requirement exists.
16
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Table A-5 - Federal Location-Specific ARARs
[USC, United States Codes; CFR, Code of Federal Regulations; P.L., Public Law; Stat., Statute; Exec..Executive; DOT, Department of Transportation]
Standard requirement,
criteria, or limitation
Archaeological and Historic Preservation Act
Archaeological Resources Protection Act
(1979)
National Historic Preservation Act
Citations
16 USC 469
40CFR6.301(c)
93 Stat 721
16 USC 470
16 USC 470
40CFR6.301(a)-(c)
36 CFR Part 800
32 CFR 229
Description
Establish procedures to provide for
preservation of historical and archaeological
data which might be destroyed through
alteration of terrain as a result of a Federal
construction project or a Federally licensed
activity or program
This act requires a permit for any
excavation or removal of archaeological
resources from public or Indian land
Require Federal agencies to take into
account the effect of any Federally assisted
undertaking or licensing on any district,
site, building, structure, or object that is
included in or eligible for the Register of
Historic places
Applicable/
Relevant and
Appropriate
No/No
No/No
Yes/NA
Comments
No historical or archeological data
will be destroyed through interim
action
No archeological objects will be
excavated through interim action
F.E. Warren Air Force Base is on the
National Register of Historic Places.
Section 106 consultation will be
performed.
Historic Sites, Buildings, and Antiquities Act
Fish and Wildlife Coordination Act
Endangered Species Act
16 USC 461-467
40CFR6.301(a)
16 USC 1531-666
40CFR6.302(g)
16 USC 1531-1543
50 CFR Parts 17.402
40CFR6.302(g)
50 CFR 222
Require Federal agencies to consider the No/No
existence and location of landmarks on the
National Registry' of Natural Landmarks to
avoid undesirable impacts on such
landmarks
Require consultation when Federal No/No
department or agency proposes or
authorizes any modification of stream or
other water body and adequate provision for
protection offish and wildlife resources
Require that Federal agencies insure that No/No
any action authorized, funded, or carried
out by the agency is not likely to jeopardize
the continued existence of any threatened or
endangered species or destroy or adversely
modify critical habitat
There are no items at the site listed in
theNRNL
No modification to streams or water
bodies is intended.
Interim action at the site will not
impact any endangered species or
critical habitat.
17
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Table A-5 - Federal Location-Specific ARARs
(Continued)
Standard requirement,
criteria, or limitation
Citations
Description
Applicable/
Relevant and
Appropriate
Comments
Executive Order on Floodplain Management
Executive Order on Protection of Wetlands
Wild and Scenic Rivers Act
Miscellaneous
Impact on Wilderness Area
Impact on Wildlife Refuges
Impacts on Coastal Zones
Exec. Order No
11,988
40CFR6.302(b)&
Appendix A
Exec. Order No.
11,990
40CFR6.302(a)£
Appendix A
16 USC 1271-1287
40CFR6.302(e)
50CFR35.1
50 CFR 27
16 USC 1451-1464
Require Federal agencies to evaluate the
potential effects of actions they may take in
a floodplain to avoid, to the extent possible.
the adverse impacts associated with direct
and indirect development of a floodplain
Require Federal agencies to avoid, to the
extent possible, the adverse impacts
associated with the destruction or loss of
wetlands and to avoid support of new
construction in wetlands if a practicable
alternative exists
Establish requirements applicable to water
resource projects affecting wild, scenic, or
recreational rivers within or involved in
studies for inclusion in the National Wild
and Scenic Rivers System
Establishes the National Wilderness
Preservation System in order to preserve
wilderness areas
Establishes restrictions on activities within a
National Wildlife Refuge.
Establishes prohibitions on federal agency
activities inconsistent with a state's
approved coastal zone management
program
No/No
No/No
No/No
No/No
No/No
No/No
Interim action at the site will not
impact floodplain.
Interim action at the site will not
result in destruction or loss of
wetlands.
No water resource projects are
planned as part of interim action.
There are no wilderness areas
associated with the site.
There are no wildlife refuges
associated with the site.
There are no coastal zones at the site
18
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Table A-6 - State Location-Specific ARARs
[CFR, Code of Federal Regulations; P.L, Public Law; W.S., Wyoming Statute]
Standard requirement,
criteria, or limitation
Environmental Quality Act
Wyoming Water Qua! irv Rules and Regulations
Citations
Article 5, W S.
35-11-501 to
35-11-514
Chapter I, Appendix A
Description
Solid Waste Management
Quality Standards for Wyoming
Applicable/
Relevant
and
Appropriate
No/No
Yes-MA
Comments
Location-specific requirements for siting landfills are
administrative in nature and do not apply to an
already sited landfill
Specifies surface water classifications for Crow Creek
State Engineer's Office Rules and Regulations
Parti
Part II
36 CFR £00
Surface Waters
Permitting Requirements for Use of
Wyoming Surface Waters
Permitting Requirements for Use of
Groundwater in the State of
Wyoming
Procedures for Protection of Cultural
Properties, State of Wyoming
Archives, Museums and Historical
Sites
and Diamond Creek which determine standards for
surface waters.
No/No No use of surface waters is anticipated for interim
action.
Yes/N A No use of ground water is anticipated for interim
action. Permitting is not required, but substantive
provisions would apply to ground water use.
No/No Interim action will not cause loss of scientific or
archaeological data.
19
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Appendix B
Temporarily Waived Federal and Wyoming State
Applicable, or Relevant and Appropriate Requirements (ARARs)
20
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Table B-l - Federal Chemical-Specific ARARs
[DSC, United States Codes; CFR, Code of Federal Regulations; Statute; Exec.,Executive; DOT, Department of Transportation; FS, Feasibility Study]
Standard requirement,
criteria, or limitation
Safe Drinking Water Act
National Primary Drinking-Water
Regulations
Citations Description
42 USC 300g
40 CFR 141, Establish health based standards lor the public
Subparts B water systems (maximum contaminant levels)
and G
Applicable/
Relevant
and
Appropriate
No Yes
Comments
Groundwater is a potential or actual source of dnnking water
This interim action is due to groundwater contamination. The
cleanup of ground water will be addressed in subsequent
actions.
National Secondary Drinking-Water
Regulations
Maximum Contaminant Level Goals
(set at levels above zero)
Clean Water Act
Water Quality Criteria
Resource Conservation and Recovers Act
Standards lor Owners and Operators of
Hazardous Waste Treatment, Storage, and
Disposal Facilities: Releases from Solid
Waste Management Units
40 CFR 143.3
40 CFR 141,
Subpart F
33 USC
1251-1376
40 CFR 131
Establish welfare based standards for the
public water systems (secondary maximum
contaminant levels)
Establish non-enforceable drinking water
quality goals set at levels of no known or
anticipated adverse health effects, with an
adequate margin of safety
Set criteria for water quality based on toxicity
to aquatic organisms and human health
40 CFR 264 Establishes concentration limits for hazardous
Subpart F. constituents in the ground water
Section 264.94
No Yes Groundwater is a potential or actual source of dnnking water
This interim action is due to groundwater contamination. The
cleanup of ground water will be addressed in subsequent
actions.
No Yes Groundwater is a potential or actual source of drinking water.
This interim action is due to groundwater contamination. The
cleanup of ground water will be addressed in subsequent
actions. Relevant and appropriate only for constituents of
concern with an MCLG greater than zero.
No Yes Groundwater is a potential or actual source of drinking water.
This interim action is due to groundwater contamination. The
cleanup of ground water will be addressed in subsequent
actions.
Yes/NA Groundwater is a potential or actual source of drinking
water. This interim action is due to groundwater
contamination. The cleanup of ground water will be
addressed in subsequent actions.
21
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Table B-2 - State Chemical-Specific ARARs
(DSC, United States Codes; CFR, Code of Federal Regulations; Statute; Exec.,Executive; DOT, Department of Transportation; FS, Feasibility Study]
Standard requirement, Citations
criteria, or limitation
Description
Applicable/
Relevant and
Appropriate
Comments
Wyoming Water Quality Rules and Regulations
Chapter VIII
Quality Standards for Wyoming
Groundwaters
Chapter XVII,
Appendix A. Sections
III and IX
Underground Storage Tanks
Wyoming Hazardous Waste Rules and
Regulations
Chapter X. Sections
6(c)-6(g)
Standards for Owners and Operators of
Hazardous Waste Treatment Storage and
Disposal Facilities
Yes'NA Groundwater is a potential or actual source of
drinking water. This interim action is due to
ground water contamination. The cleanup of
ground water will be addressed in subsequent
actions. Regarding Section 1, compliance with
other state water quality substantive
requirements (permits are not required)
identified as ARARs satisfies all requirements
of this provision.
No Yes Groundwater is a potential or actual source of
drinking water. This interim action is due to
groundwater contamination. The cleanup of
ground water will be addressed in subsequent
actions. Drinking Water Equivalent Levels
(DWELs) established in Section IX are relevant
and appropriate only if federal MCLs do not
exist. Potential or actual relevance and
appropriateness of these DWELs does not
invoke any soil cleanup or soil contamination
concentration standard requirements of Chapter
XVII for soils located within the landfill
boundaries which are capped.
YesNA Groundwater is a potential or actual source of
drinking water. This interim action is due to
groundwater contamination. The cleanup of
ground water will be addressed in subsequent
actions. Substantive groundwater protection
standards and concentration limits that are more
stringent than federal requirements for some
contaminants apply.
22
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Table B-3 - State Action-Specific ARARs
[USC, United States Codes; CFR, Code of Federal Regulations; Statute; Exec.,Executive; DOT, Department of Transportation; FS, Feasibility Study]
Standard requirement,
criteria, or limitation
Citations
Description
Applicable/
Relevant and
Appropriate
Comments
Wyoming Water Quality Rules and Regulations Chapter VIII
Quality Standards for Wyoming
Ground waters
Yes MA Groundwater is a potential or actual
source of drinking water This interim
action is due to groundwater
contamination. The cleanup of ground
water will be addressed in subsequent
actions. Regarding Section 1, compliance
with other state water quality substantive
requirements (permits are not required)
identified as ARARs satisfies all
requirements of this provision.
23
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