em
                           PB95-208922
                           530-R-95-020
           DAMAGE CASES:
       CONSTRUCTION AND
                           WASTE
              LANDFILLS
                401 M streei, SW
                Washington, DC 20406 '
                   Prepared for

            U.S. Environmental Protection Agency
                 Office of Solid Waste

                      by

                  ICF Incorporated
               Contract No. 68-W3-0008
                   January 1995
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              *** January 5,1995 Draft Document ***
                 EPA Headquarters Library

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                                  TABLE OF CONTENTS
EXECUTIVE SUMMARY	-.	-.	"	  ES-1

       Background	'.	'. . . .  ES-1
       Purpose of This Report	'.	  ES-1
       Methodology	'.	  ES-1
       Results		:			  ES-2

CHAPTER 1. INTRODUCTION	,	'	  1-1
              '                                             '             .
       Regulatory Background	....'....  1-1
       Focus on C&D Landfills 	'	  1-1
       Purpose and Organization of This Report	. ..	  1-2

CHAPTER 2. IDENTIFYING DAMAGE CASES  . .	  2-1

       Criteria for Selecting Damage Cases	'...'......	  2-1
       Existing Studies	. • • • •	•. -. •  2-1
       .Superfund Program  ..,'/.	'.. '.	  2-2
       EPA Regions  	.;....	  2-3
       State and County Agencies	  2-3

CHAPTER 3. DAMAGE CASES	-	  3-1

       Fair Street C&D Site, Patterson, New York	".	  3-4
       Garofalo C&D Site,  Islip, New York .	  3-7
       Moran C&D Site, Philmont, New York		  3-9
       Route 52-Hills Holding Corporation Site, Fallsburg, New York		3-12
       Cox's Darbytown Road Landfill, Henrico County, Virginia	 3-15
       Crippen Stump Dump, Fairfax County, Virginia	3-18
       Furnace Road Debris Landfill, Lorton, Virginia	3-21
       Qualla Road Landfill, Chesterfield  .County, Virginia		:	3-24
  "    Schuylkill Debris Landfill, Prince George County, Virginia	3-27
       Janesville Demolition Waste Landfill, Janesville, Wisconsin	3-29
       Terra Engineering Demolition Waste Landfill, Dane County, Wisconsin	 3-31

CHAPTER 4.  FINDINGS AND CONCLUSIONS  .......:		  4-1

       Summary of Damages and Contributing Factors	.:.,.;	•.  4-1
       Conclusions	  4-8

APPENDIX A. CONTACTS  	"	'	'	A-l
                          *** January 5,1995 Draft Document ***

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                                    EXECUTIVE SUMMARY
        The U.S. Environmental Protection Agency (EPA) is currently developing a rule addressing non-
 municipal facilities (industrial waste facilities, including construction and demolition waste landfills) that
 may receive hazardous wastes from conditionally exempt small quantity generators (CESQGs), or
 generators of less than 100 kilograms per month of hazardous waste.  This report, prepared in support of
 EPA's rulemaking, presents information on environmental damages from construction and demolition
 (C&D) waste landfills, i.e., landfills that receive materials generated from the construction or destruction
 of structures such as buildings, roads, and bridges. C&D waste landfills are being examined because the
 Agency believes that the largest potential impact from this rulemaking will be on these facilities.

 BACKGROUND

       The 1984 Hazardous and Solid Waste Amendments  (HSWA) to the Resource Conservation and
 Recovery Act (RCRA) required  EPA to revise the existing standards and guidelines governing the
 management of household hazardous wastes and hazardous wastes from small quantity generators.  EPA
 responded in  1991 by revising the existing criteria  for solid .waste disposal facilities and'practices (40 CFR ,
 Part 257). In 1991 EPA issued revised criteria in 40 CFR Part 258 for municipal solid waste landfills
 (MSWLFs) that receive household hazardous wastes and CESQG wastes. EPA did not establish revised
 criteria for non-municipal facilities and subsequently was sued by the Sierra Club.  A consent agreement
 was reached in January 1994, and EPA is now fulfilling the remainder of the HSWA mandate by regulating
 CESQG wastes that are disposed in non-municipal facilities.  The final rule must be signed by  the EPA
 Administrator by May 15, 1995.  The rule will require facilities receiving CESQG wastes to have adequate
 ground-water  monitoring, corrective action requirements, and location restrictions.

 PURPOSE OF THIS REPORT
                    '                '                           -
       The purposes of this study were to (1) determine whether the disposal of C&D waste in landfills
 has led to contamination of ground water or surface water, or damages of ecological resources, and (2)
examine whether these environmental damages can be attributed to specific aspects of the site such as the .
 types of waste received, design and operating practices, and environmental setting/location.

METHODOLOGY               -

       To compile documentation of environmental  impacts resulting from C&D waste landfills, EPA
searched for sites that met the following criteria:

       •      The landfill received predominantly C&D waste, with or without CESQG waste mixed in.
              Landfills that were known to have received significant quantities of municipal,  industrial,
              or hazardous wastes were excluded.
            ,        '   -         '             "*>•
       »      The use of the site as a C&D landfill had to be the only potential source of the observed
              contamination. Sites located near other potential sources of the contamination such as
              underground storage tanks were excluded.          .                                  -

       •      There had to be  documented evidence of ground-water contamination, surface  water
              contamination, or ecological damage at the site! "Contamination" was defined as an
                             *** January 5, 1995 Draft Document ***

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ES-2.
                increase in constituent levels above background, or an exceedance of an applicable
                regulatory standard or criterion attributable to releases from the site.

        EPA searched for sites meeting these criteria using four information sources:

        •       Existing studies of C&D waste landfills.  Two studies provided particularly useful
                background information: (1) Construction and Demolition Debris Disposal Issues: An
                Alachua County Perspective (Hanrahan, 1994); and (2) Construction and Demolition Waste
                Disposal: Management Problems and Alternative Solutions (Lambert and Domizio, 1993).

        •       Materials available through the Superfitnd program. Superfund databases were searched to
                identify C&D waste landfills on the National Priorities List or under investigation.  None
                of the Superfund sites were found to be appropriate damages cases, typically because they
                received a wide variety of wastes in  addition to C&D waste.

        •       Representatives of EPA Regions were contacted.  Because C&D waste landfills are
                regulated by the states rather than EPA, the representatives provided lists of state
                contacts.            . ,          •         '  .                       ;

        •       Representatives of state and county environmental agencies were contacted in 32 states.
                Only three states - New York, Virginia, and Wisconsin - clearly identified C&D waste
                landfills that met the criteria listed above. These states allowed EPA to review
                documentation on potential damage cases to obtain more detail on the cases reported
                here.  Documentation reviewed included preliminary site assessments for New York sites,
                C&D site background files and monitoring data for Virginia sites,  and  a ground-water
                impact investigation for Wisconsin sites.

RESULTS

        Only 11 damage cases were identified using  the above methodology.  All 11 sites reported ground-
water contamination within the property boundary; none reported ground-water contamination off site.
This does not mean that there was no off-site ground-water contamination; in most cases, ground-water
monitoring was not performed beyond the site. boundary.                                   ,

        Although most of the sites monitored ground water for a wide range of organic and  inorganic
constituents, virtually all of the contamination was associated with inorganics.  Constituents that exceeded
state ground-water protection standards or federal drinking water criteria most frequently were iron,
manganese, total dissolved solids (TDS), and lead. Two of these constituents - iron and manganese -
were found to exceed applicable standards by a factor of 100 or more in at least one sample at many     ;
landfills (i.e., at 5 of the 11 sites for iron, and at 4 of the 11 sites for manganese).  It is noteworthy that for
both constituents, the standard that was exceeded  is  a secondary, rather than primary, drinking water
standard (MCL). Secondary MCLs are set to protect the water supply for aesthetic (e.g., taste) rather than
health-based reasons.

        Six sites had surface water contamination; three of these sites also had some contamination of
sediments. At two sites, the surface water and sediment contamination was off site as well as on site.  As
with ground water, most of the contamination was associated with inorganic constituents. Constituents
that exceeded state surface water standards or EPA's Ambient Water Quality Criteria (AWQC) for the
protection of freshwater aquatic life most frequently were iron, zinc, lead, copper, and acidity (pH).  Two


                              *»* January S, 1995 Draft Document ***

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                                                                                             •  ES-3

 of the sites reporting contamination of sediments had elevated levels of poJynuciear aromatic hydrocarbons
 (PNAs).   '         ••'                                              •

        The source documents rarely examined the possible link between environmental damages observed
 at a site and the design, operating, or location attributes of the site.'  Factors that might have contributed
 to the damages' at the 11 sites are as follows:

        •      Seven landfills contained other types of wastes that had been disposed of legally or
               illegally, including tires, household hazardous wastes, and other materials.

        •      Environmental controls were typically inadequate or absent.  Only two  landfills were
               equipped with partial bottom liners and leachate collection systems (LCSs).  Run-on
               and/or run-off controls were mentioned for only three sites.  Six sites apparently had. some
               type of final/cover, but only two had more than a thin soil cover.  For four sites, no
               environmental controls were mentioned in the source documents.

        •     .  Many of the landfills are characterized by environmental settings that could facilitate the
               release and transport of contaminants, including shallow ground water,  complex ground-
               water flow conditions, and highly permeable subsoils. Many landfills had ponds, streams,
              • or wetlands either on site or within close proximity; one site was located in a 100-year
               floodplain.      .                          •

        Although this study demonstrates that specific C&D waste landfills can lead to ground-water and
surface water contamination, the Agency believes that it has insufficient data, at this point, to require more
than the statute requires (i.e., ground-water monitoring, corrective action, and location restrictions).  The
Agency made a concerted effort to identify C&D damage cases by contacting 32 state agencies and  was
able to identify only 11 cases where there was a high probability that damages were associated with C&D
wastes.  The Agency's limited data (11 damage cases out of a total of approximately 1,800 C&D facilities)
makes it difficult for the Agency to determine whether C&D facilities are posing sufficient risk to human
health and the environment to warrant additional controls beyond those required by the statute.
                              "** January 5, 1995 Draft Document ***

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   CHAPTER 1.                                      .  _...                     INTRODUCTION
          This report presents information on environmental contamination that has resulted from the
  operation of construction and demolition (C&D) debris landfills. These are landfills that receive materials
  generated predominantly from the construction or destruction of structures such as buildings, roads, and
  bridges. There are currently about 1,800 C&D debris landfills operating in the United States.

          This report was written in support of a rulemaking currently being developed by the U.S.
  Environmental Protection Agency (EPA).  This chapter provides a background discussion of this
  rulemaking, and then discusses the purpose and organization of this report.
                                        r                     -
  REGULATORY BACKGROUND                                               '     .

          The Resource Conservation and Recovery Act (RCRA), passed in 1976, required the
  Environmental Protection Agency (EPA) to promulgate standards and guidelines for the management of
,  ^ solid wastes. In response to this mandate, EPA promulgated regulations for the management of hazardous
  wastes under Subtitle C of RCRA, and for non-hazardous wastes under Subtitle D. The Subtitle C
  standards applied to  all  facilities generating more than 1,000 kg/mo of hazardous wastes, but conditionally
  exempted from full regulation facilities generating less than this amount.  Subtitle D guidelines address the
  management of all other solid wastes, such as municipal wastes and non-hazardous industrial .wastes
  (including construction and demolition wastes).

          In 1984, Congress passed the Hazardous and Solid Waste Amendments (HSWA), which made
  several changes to RCRA.  One important change was the creation of two categories of small quantity
  hazardous waste generators: generators of 100  to 1,000. kg/mo, and generators of less than 100 kg/mo.
  HSWA added specific provisions for the first category, but gave EPA discretion as to whether to
  promulgate new requirements for the second.  EPA has since defined generators of less than 100 kg/mo as
  conditionally-exempt small quantity generators, or CESQGs.  CESQGs are responsible for the proper
  management of their wastes, but are not required to comply with many of the Subtitle C regulations
 .specified for larger hazardous waste generators.  v

         Another important change imposed by HSWA was the addition of Section 4010 to Subtitle D,
  requiring EPA to promulgate revised criteria addressing the management of household hazardous wastes
  and hazardous wastes from small quantity generators. EPA responded in ,October 1991 by promulgating
  the revised Municipal Solid Waste Landfill  (MSWLF) Criteria (40 CFR Part 258). This partially fulfilled
  the HSWA mandate by addressing household hazardous wastes and CESQG wastes that are disposed in
  MSWLFs. After a consent agreement with the Sierra Club on January 28, 1994, EPA is now fulfilling the
  remainder of the HSWA mandate by regulating CESQG wastes that are disposed in non-municipal
  facilities. The final rule must be signed by the EPA Administrator by May 15, 1995.  The rule will require -
  facilities receiving CESQG wastes to have adequate ground-water monitoring, corrective action
  requirements, and location restrictions.                ....

  FOCUS ON C&D LANDFILLS

         Many different types of Subtitle D waste management units other than MSWLFs may receive
  CESQG wastes and may therefore be affected by this rulemaking, including the following:

         •      Commercial Subtitle D industrial waste landfills;


                             *•'• January 5,1995 Draft Document ***

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        •       On-site Subtitle D industrial waste management units such as landfills, surface .
               impoundments, land treatment units, and waste piles; and

               C&D debris landfills.              .    ,

EPA believes that .the only waste management units that may be impacted significantly by this rulemaking
are the C&D landfills., C&D landfills are therefore the focus of this report.

PURPOSE AND ORGANIZATION OF THIS REPORT

        The purposes of this study were to (1) determine whether the disposal of C&D debris in landfills
has led to contamination of ground water, surface water, or ecological resources; and (2) examine whether
these environmental damages can be attributed to specific aspects of the site such as the types of waste
received, design and operating practices, and environmental setting/location.

        The remainder of this report comprises three chapters.

      .  •       Chapter 2 discusses the criteria and information sources used to select sites to include in
               the study;

        •       Chapter 3 presents 11 damage cases; and

        •       Chapter 4 summarizes the types of damages found at these landfills, discusses the possible
              .link between these damages and site operation, design, and location, and presents the
               conclusions of the study.  ...
                            *** January 5,1995 Draft Document ***

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CHAPTER 2.                             '•'.',    IDENTIFYING DAMAGE CASES
        To compile documentation of environmental impacts resulting from C&D waste landfills, the
Agency used four sources of information:

        •       Existing studies of C&D waste landfills;
        •       Materials available through the Superfund program;   .                       .
        •       Representatives of EPA regions; and    .                          ..-
        •       Representatives of state and county environmental agencies:          ;

In reviewing information available from these sources, EPA applied certain criteria to select sites to serve
as damage cases.  EPA's criteria for identifying damage cases are presented below, followed by a discussion
of each information source. Using these criteria and information sources, EPA identified 11 sites that
document the occurrence of environmental,contamination from C&D landfills.  These damage cases are
presented in Chapter 3.

CRITERIA FOR SELECTING DAMAGE CASES  .

        The Agency considered three major factors in judging whether a site is an appropriate damage  .
case'for this analysis. First, EPA included only those facilities that received predominantly C&D waste, '
with or without conditionally-exempt small quantity generator (CESQG) waste mixed in.  However, if
evidence suggested that the site also received significant quantities of municipal, industrial, or hazardous
wastes, it was.excluded.

        Second, the use of the site as a  C&D landfill had to be the only potential source of the observed
contamination.  The site was excluded if it was located near another potential source of contamination
(e.g., municipal solid waste landfill, leaking underground storage tank). The site was also excluded if it
had a previous use (e.g., mine) that could have contributed to the contamination.

        Finally, there had to be documented evidence of ground-water contamination, surface water
contamination, or ecological damage at the site. "Contamination" was defined as an increase' in constituent
levels above background, or an exceedance of an applicable regulatory standard or criterion attributable to
releases-from the site.  Ecological damage to aquatic communities was assumed  to have occurred if surface
water concentrations exceeded EPA's Ambient Water Quality Criteria, which are designed to be protective
of aquatic communities.  Terrestrial ecological damage would have been assumed to have  occurred if the
information source documented impacts to terrestrial flora or fauna at the site, but none of the source
documents provided that information.

EXISTING STUDIES

        EPA reviewed several, existing studies of C&D waste generation and management. Two of these
studies were particularly useful in providing background information  helpful to this effort, such as the
number of C&D waste landfills in .each state, whether or not C&D landfills are monitored, and whether or
not ground-water contamination has been documented. These two studies are:

        •       Construction and Demolition Debris Disposal Issues: An Alachua County Perspective
               (Hanrahan, 1994); and
                            *** January 5,1995 Draft Document ***

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 2-2  -               .       -           -                  .

        •      Construction and Demolition Waste Disposal: Management Problems and Alternative
               Solutions (Lambert and Domizio, 1993).

 These  reports helped to focus the Agency's search for documented damage cases.

 SUPERFUND PROGRAM

        Superfund databases were examined to determine whether they included any C&D waste landfills.
 This was performed in two steps, discussed below.

        National Priorities List

        The first step was to examine sites that have been listed (or are being proposed for listing) on the
 National Priorities List (NPL).  EPA performed a keyword search of the  [** to be added **] to identify all
 sites with "construction" as a site activity-waste source.  This resulted in the identification of 14 sites that
 were listed on the NPL as of February 1991, and 9 additional sites that have, been proposed for listing
 since then.                                          '      ,

        EPA obtained and reviewed Records of Decision (RODs) for each of the  14 sites on the NPL.
 Because RODs have not yet been written for most of the other sites, EPA obtained and reviewed the  sites'
 Preliminary Assessments (a preliminary review of available information performed on all sites investigated
 under the Superfund program) and other available documentation instead.

        Based on a review of the documentation for these sites, none were judged to be acceptable as
 damage cases for this analysis.  All of the sites have  received a wide variety of wastes in addition to C&D
 waste, including municipal, industrial, and/or hazardous wastes, and it was not possible to attribute the
 environmental contamination to the C&D component of the waste.

        CERCLJS Characterization Database

        Sites listed on the NPL represent only a fraction of sites investigated under the Superfund
 program.  Over 30,000 sites identified through various means have received Preliminary Assessments under
 Superfund. Some of these sites have been found to require no further  action, while others are being
 investigated in more detail for possible inclusion on  the NPL.  All sites that have received Preliminary
 Assessments are listed in the CERCLA Information System (CERCLIS).  To determine whether any sites
 in CERCLIS are C&D waste landfills, the CERCLIS Characterization Database1 was searched to identify '-
 sites with the following characteristics:

        •       The site contains a landfill associated with the construction industry in which C&D waste
               was disposed;

        •       Ground-water, surface water, and/or ecological damage has been documented at the site,
               and the site has not been deemed innocuous or low priority; and
    ^CERCLIS itself could not be searched because it does not identify the type of site; i.e., there was no
way to determine which sites are C&D debris landfills. The CERCLIS Characterization Database was used
instead; this database contains detailed information for eight percent of the approximately 30,000 sites in
CERCLIS.

                            **» January 5,1995 Draft Document ••*     •     *

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                                                '                    •   •             '    .     2-3

  . '    •      The landfill is not a municipal landfill ,or one that has received hazardous waste.

No facilities were found in the CERCLIS Characterization  Database that met all of these criteria.

EPA REGIONS
                                                                                     /
        All of the EPA regional offices were contacted to obtain information on contamination resulting
from C&D waste sites in their regions. Since C&D waste landfills fall under the purview of Subtitle D of
RCRA, and  Subtitle D programs are administered by the states rather than EPA, the regions were unable
to provide the needed information.  Instead, they identified state contacts to call directly. A list of the
EPA regional contacts is provided in Appendix A. Some of these contacts noted that because C&D
landfills are  not regulated or monitored in some states, information on damages is simply unavailable.

STATE AND COUNTY AGENCIES

        State and county environmental agencies in 32 states were contacted  to obtain information on
contamination from C&D landfills.  State contacts were originally identified from a list of participants
attending EPA's Industrial Subtitle D Workshop in March 1993, representing 11 states.  Additional state
and county contacts were added based on:                 •

        • .    Information from EPA regional contacts;          ,                        •    t.  '

        •      EPA's review of site-specific ground-water monitoring data provided by states to the
               National Association of Demolition Contractors (NADC); and
                                                                 /
        •      A list of state agencies surveyed by the Alachua County  Environmental Protection
               Department (Hanrahan, 1994) regarding C&D waste disposal.

A list of state and county contacts who provided relevant information to  EPA is presented in Appendix A.

     1  Although a large number of states were contacted, only three -- New York, Virginia, and
Wisconsin ~ identified C&D waste landfills that met the criteria listed above, for a total of 11 damage
cases:                                         >

       •      Prior to 1988, C&D disposal facilities in New York State were exempt from solid waste
               permitting requirements if they operated less than one year.  The New York State
               Department of Environmental Conservation (NYSDEC) investigated nine C&D sites,
               prompted by public suspicion of hazardous waste disposal,  probability of significant
               environmental or public health impacts, and levels of public .concern.  Preliminary Site
               Assessments (PSAs) were conducted to determine (1) if wastes at the site included
               hazardous wastes (as defined by the New York Code of Rules and Regulations (NYCRR)
               Part 371) and  (2) the impact of the site on  human health and the environment.  NYSDEC
               used the information obtained from the PSAs in revising/enhancing the New York Code
               (6 NYCRR Part 360) on solid waste management facilities in 1988. PSAs were ultimately,
              written for only eight sites, because an ongoing investigation  prevented a site assessment
          >   at the ninth. Four of the eight investigated C&D sites met the criteria listed above and
              were used as damage cases.
                            *** January 5,1995 Draft Document ***

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2-4              '                             •

        »       Virginia has conducted ground-water monitoring at C&D landfills since 1988.
                Downgradient wells (as close to the waste management unit boundary as feasible) are
                compared to initial background levels (pre-1988) and to upgradient wells.  If a statistically
                significant elevation (or decrease, in the case of pH) in a target parameter is observed
                during Phase I, Phase II monitoring is triggered. Nine target parameters are monitored
                for Phase I: chloride, hardness, iron, lead, pH, sodium, specific conductance, total organic
                carbon (TOC), and total organic halides (TOX). The Virginia Department of
                Environmental Quality (DEQ) provided EPA with a list of 10 C&D facilities for which
                Phase II monitoring has been triggered. EPA reviewed the available information for all
                10 sites, but only 5 sites both.met the criteria listed above and had sufficient information'
                available to serve as damage cases.

        •       The Wisconsin Department of Natural Resources document, Investigation of Groundwater
                Impacts at Demolition Landfills (1994), provided information on contamination at two
                demolition landfills sufficient to identify those sites as damage cases.  Wisconsin has
                required ground-water monitoring at  C&D sites since 1988.

        Very few damage cases were found for potentially four reasons.  First, about half of the SO states
do not have sufficient documentation to identify damage cases.  In some of these states, ground-water
monitoring is not conducted at C&D  landfills (Hanrahan, 1994). In some cases, ground-water monitoring
is conducted only on a case-by-case basis, so information is  not available for all C&D landfills (Hanrahan,
1994). In a few  cases, monitoring that might provide information on damages is underway, but has begun
so recently that results are not yet available.

        Second,  in approximately one fourth of the SO states, potential damage cases could not be
specifically attributed to C&D waste because of one or more of the following reasons:

        •       C&D wastes are disposed of in municipal landfills rather than in separate C&D landfills;
                                                                       /
        •       C&D landfills  are located near other  possible sources of contamination (e.g., leaking
                underground storage  tanks, municipal landfills);                              •'
                                       . v.
        •       Site history information indicates a previous use of the site that could have contributed to
             .  the damage (e.g., use as an asphalt plant, a mine, etc.), or the state may have no
                information on the history of the site; and/or

        •       Sites have been in  existence since the 1940s or SOs, and it is possible that non-C&D
               wastes were dumped in large quantities  in the early years, when the sites were
                unregulated.                -                  -'

        Third, other states identified sites where damages may have been  attributable to C&D wastes, but
unusual circumstances existed, and these cases were not  used. For example, damages at one site resulted
from pumping water through a landfill to extinguish a landfill fire, and the state representative did not
believe it was representative of a typical site.

        Lastly, in eight states that regulate C&D waste separately from other landfilled wastes, ground-
water monitoring is conducted at all C&D landfills and contamination has not been found (Hanrahan,
1994). In seven  of these eight states, liners are required while in six of the eight states, leachate collection
systems are required at some or all of the C&D landfills.
                            ***
                                January 5, 1995 Draft Document ***

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CHAPTER 3.
DAMAGE CASES
       This chapter presents a summary of each of the 11 damage cases identified using the methodology
and sources discussed in Chapter 2. The names and locations of the damage cases are given in Exhibit 3-1.
                     EXHIBIT 3-1. -C&D DEBRIS LANDFILL DAMAGE CASES
NAME
LOCATION
NEW YORK STATE
Fair Street C&D Site
Garofalo C&D Site
Moran C&D Site
Route 52-Hills Holding Corp,
Patterson
Islip
Philmont
Fallsburg
VIRGINIA
Cox's Darbytown.Road Landfill
Crippen Stump Dump ,
Furnace Road Debris Landfill
Qualla Road Landfill
Schuylkill Debris Landfill
Henrico County
Fairfax County
Lorton
Chesterfield County
Prince George County
WISCONSIN
Janesville Demolition Waste Landfill
Terra Engineering Demolition Waste Landfill
Janesville
Dane County
       The damage case summaries are arranged in a standard format.     „                   '

       "Media Affected" identifies whether the damages are associated with ground water, surface water,
       or ecological receptors.        ..                                                        '

       "Overview of Site/Site History" discusses the location and size of the site, its opening and (if
       applicable) closing date, any enforcement actions that have been taken, the purpose of the site
       investigation(s), and the number of people living near the site, if that information is available:

       "Facility Operations" discusses the types of waste received, plus any information available .on filling
       operations (e.g., use of daily cover).  In most cases, information on filling operations was
       unavailable.             .  •  ~  .
                           *** January 5,1995 Draft Document ***

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3-2
        "Facility Design" presents available information on the presence of engineered controls such as
        liners, leachate collection systems, run-on/ruh-off controls, and final cover.  Information on facility
        design was very incomplete for virtually all of the damage cases.

        "Site Environment and Hydrogeology" summarizes site characteristics related to the transport of
        contaminants in the environment. Factors addressed, when available, include soil and bedrock
        composition and hydraulic conductivity, depth to ground water, direction of ground-water flow,
        and use of the aquifer for drinking water supplies. Surface water resources are also discussed,
        including (where relevant) the location of on-site or off-site surface water bodies and the use of
        surface water for drinking water supplies and other uses. This section also  addresses the presence
        of wetlands, floodplains, and other sensitive environments.

        "Summary of Environmental Damages" discusses ground-water contamination, surface water
        contamination, and ecological damages at the site. Constituents that are detected in ground-water
        or surface'water, above applicable state and federal standards are identified, and their maximum
        detected concentrations are given. The following state and federal standards were used:

        *       Federal drinking water standards.  EPA compared ground-water contaminant   .
               concentrations to federal drinking water standards: maximum contaminant levels (MCLs)
               and secondary maximum contaminant levels (SMCLs).  MCLs are federally enforceable
               standards set by  EPA that apply to any water system in the U.S. that serves more than 25
               people. MCLs are set based both on human health considerations  and oh technological
               and .economic feasibility. SMCLs are based on aesthetic considerations (e.g., taste and
               odor), and are not federally enforceable.

        *       Ambient Water Quality Criteria.  EPA compared surface water contaminant concentrations
               to Ambient  Water Quality Criteria (AWQC)  for the protection of aquatic life. AWQC
               for .the protection of aquatic life are designed to protect aquatic communities  (excluding
               the benthic community, which can also be exposed through sediments).

        •       New York State Water Quality Standards.  For New York C&D sites, EPA compared
               ground-water and surface water contaminant concentrations to  New York State water
               quality standards. New York' State classifies its water bodies according to their "best uses"
               and provides a different set of water quality standards for each  classification.   Class B
               standards are designed to protect surface  waters for swimming,  fish survival, and fish
               propagation; Class C standards to protect for fish survival and propagation; and Class D
               standards to protect for fish survival (but not fish'propagation). In addition,, all non-  ,
               saline ground waters in New York State are classified as GA and are protected for use as
               drinking water.
                                                                       i
        This section also identifies whether the contamination was found in on-site or off-site  resources.
        This is of particular  importance because exceedances found on site may not indicate that off-site
        ground-waters or surface waters are at risk.  In the interest of brevity, "negative" monitoring results
        are not presented in this section (i.e., it does hot identify all of the constituents that were
        monitored for, but not detected, at the site).

        "Discussion" summarizes the environmental damages and discusses .whether a link might exist
        between the damages and attributes of the site such as the types of waste received, operation,
                            *** January 5, 1995 Draft Document ***

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       design, and location.  This section also identifies any corrective actions that have been
       recommended or taken at the site.

       "Source" simply identifies the information source(s) used to prepare the damage case summary.

       The remainder of this chapter presents the damage case summaries. The implications of these
damage cases are discussed  in Chapter 4.
                          *** January 5,1995 Draft Document ***

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3-4    -                                     •

FAIR STREET C&D SITE                                          Patterson, Neiv York


Media Affected:       Ground Water, Surface Water
                                           '  t

Overview of Site/Site History

       The Fair Street Site landfill comprises approximately 3 acres of a 19.5-acre plot in Patterson, New
York.  Unpermitted dumping of C&D waste began in late  1987  and lasted until mid-February.of 1988.
Complaints of odors from the site were received in 1988 and 1989. Judgments were issued against the landfill
operators to pay for closure.

       It is estimated that more than 10,000 people live'within three.miles of the site, with the nearest
residential community located approximately one-third of a mile away.  The majority of the Town of Patterson
is not on public water supply; instead, certain residential complexes operate private wells for their residents.

Facility  Operations                                   -

       The site was used primarily as a C&D dump from late 1987 until mid-February 1988.  -The landfill
consists of 40 to 80 percent wood and wood products, 10 to 40 percent ash, brick, tires, concrete, carpet, metal,
glass, and asphalt, and 10 to 20 percent oily silt and silty sand.  An estimated five percent of the waste is non-
C&D material, including household hazardous wastes such as  furniture polish  and engine degreaser.
               i •
       C&D material was used  to level the existing topography, which included filling a natural drainage
channel that formerly connected two wetlands on the northeastern and southwestern portions of the property.
The landfill operator installed a culvert pipe beneath the landfill, allowing surface water to flow between these
two wetlands.                                                          ,
                                            '
Facility  Design

       A thin layer of clayey-silt soil averaging about one foot in thickness was  placed as cover material. The
PSA reported that the cover was inadequate in many sections of the landfill.

       The landfill has no liner system and does not appear to have run-on or run-off controls. Surface water
runoff was found to be percolating below the ground surface at the landfill, and a malodorous pond containing
leachate was found near the landfill.. Discharge from the buried culvert was foamy and discolored.

Site Environment and Hydrogeology          .                                              ,

       Three small wetlands are located on the property. As discussed above, wetlands on the northeastern
and southwestern portions of the property are connected by a culvert pipe that runs beneath the landfill. The
southwestern wetland is topographically the lowest point on the property. It is connected to a wetland located
off site, across Interstate 84, by a second culvert pipe  that runs beneath  the  highway.  Surface  water and
sediment from  the site ultimately flow  through this road culvert, discharging into  a series of wetlands
connected to Middle Branch Reservoir.
                                                                   ;

       A very  thin layer of soil and  residual glacial till material  overlie bedrock at  the Fair Street site.
Overburden soils are 25 percent gravel, 40 percent sand, 33 percent silt, and  2  percent clay. The shallow
bedrock is strongly fractured and faulted.  The nature of the discontinuities greatly influences the direction
of local ground-water flow.  The average hydraulic conductivity was determined to be 3.1 x 10"4 centimeters
per second, (cm/sec).  The ground water in  the shallow bedrock is an unconfined water table  and likely
discharges to the local wetland areas west and southwest of the site.
                            *** January 5, 1995 Draft Document ***

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                                                                                               3-5
  Summary
  Damages
of   Environmental
TABLE 1
SURFACE WATER CONTAMINANTS EXCEEDING NYS
. CLASS D STANDARDS AND/OR FEDERAL AWQC












Contaminant

antimony
cadmium
copper
cyanide
iron
zinc

Highest
Detected Level

56a
12
: '1993
61a
- 195,000
591 ,

Class D
Standard
0*grt)
—
23C
. 76C .
22
300
1,152C>
Fresh •
Chronic
AWQC
0*8/1)
30^
•' 4d
44d
5
1,000
390d










a The value was estimated in the source document.
b Antimony AWQC is proposed.
c Class D value was calculated in the source document
based on formula (6NYCRR 703.5) using an estimated
hardness value of 466 ppm.
d EPA calculated the AWQC value using an estimated
hardness value of 466 ppm. '
         Surface  water  and sediment
 samples were taken at a drainage ditch
 northeast of the site, at a point near
 the effluent of the landfill culvert, and
 at wetlands at the northeastern and
 southwestern parts of the site. Surface
 water samples showed the presence of
 inorganics  at  levels  above the New
 York State Class D standard for surface
 water and/or EPA's Ambient  Water
 Quality  Criteria   (AWQC)  for  the
 protection  of aquatic  life; these are
 shown  in Table 1.  Some  unidentified
 semivolatile organics were detected in
 the surface water samples.        ^-

        Numerous semivolatile organics
 were found at parts-per-million levels
 in  sediment samples,   most  notably
 polynuclear  aromatic   hydrocarbons
 (PNAs) and alkanes.

        Ground-water  samples  taken
 downgradient of the landfill, but within
 the property boundary, revealed the
r presence  of inorganic  compounds at
 levels above New York State Class GA ground-water standards and/or  EPA's drinking water standards
 (primary or secondary MCLs).  These are shown in Table 2.  (Note:  Aluminum and iron also exceeded
 standards in the downgradient wells. .These are not shown on the table because their concentrations were
 i highest in the upgradient well.)  In addition, some unidentified semivolatile organics were detected in many
 of the wells.  No off-site ground-water samples were taken, so it could not be determined whether or not
 contamination migrated off site.      >             ,                     >                 '    •

 Discussion  •
                ^          • -•'
        According to the preliminary site assessment (PSA), contamination of surface water, sediments, and
 ground water on the property of this site is possibly attributable to migration of constituents from the landfill.
 The PSA found oil and hazardous constituents in  the fill but was unable to document the presence of
 hazardous waste as  defined by New York State.  Household hazardous waste was present, however.

        The landfill cap was inadequate in many places, and there was no liner  or leachate collection system.
 Surface water runoff percolated below the ground surface at the landfill, and runoff and leachate flowed into
 an interconnecting system of wetlands. The aquifer is characterized by fractured and faulted bedrock, possibly
 facilitating movement of constituents in ground water.

        The PSA  recommends that  the landfill be (1) property closed, in  accordance with New York
 regulations, and (2) capped, to limit infiltration and provide surface water drainage control.
                            *** January 5, 1995 Draft Document ***

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3-6
- . .<
TABLE 2
GROUND-WATER CONTAMINANTS EXCEEDING
NYS AND/OR FEDERAL DRINKING WATER STANDARDS
Contaminant
magnesium
manganese
sodium
TDS
Highest
Detected Level
0*8/1)
128,000
46,700
276,000
2,850,000
Class GA
Standard
0*8/1)
35,000*
300
20,000
500,000
MCL
0*g/l)
—
. — .
—
-
SMCL
0*8/1)
--
50
—
500,000
a Value is New York State "guidance value."
i

Source
       Final Preliminary Site Assessment:   Fair Street C&D Site;  New  York State Department of
       Environmental Conservation (NYSDEC); November 1991.
                          *** January 5,1995 Draft Document ***

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                                                                                              3-7

 GAROFALO C&D SITE                          _                       Islip, New York


 Media Affected:       Ground Water              .                   '  '                     ,

 Overview of Site/Site History                             -

        The Garofalo C&D landfill was operated illegally by, the Garofalo Carting Company (the Company)
 on land owned by Pilgrim State Psychiatric Center (PSPC) in Islip, New York.  In  1978 the Company was
 confronted by the New York State Department of Environmental Conservation (NYSDEC) concerning illegal
 dumping and excavating on.land owned by the PSPC.  The Company has been fined and repeatedly ordered
 to clean up the site, but has not complied with the sanctions.

        The Garofalo site is located in a densely populated section of Long Island.  Approximately 10,000
 people reside within three miles of the landfill, including 1,200 people at the PSPC located immediately south
 of the site.  Several schools are located within one mile of the site.

 Facility Operations  .                  •

        The Garofalo C&D landfill was cited for violations under the New  York State Environmental
 Conservation Law, Article 27, in 1986. Testing found the landfill .material to be comprised of 10 to 60 percent
 sandy soil with lesser amounts of silt, and mechanically crushed wood, metal, plastic, bricks, concrete, whole
 trees and brush, large  timbers,  pilings,  railroad ties, chain link fencing, rugs, plastic,  and  fiberglass sheeting.
 In 1989, approximately 100 syringes with needles and some intravenous tubing were found on PSPC property,
 near the landfill site.

 Facility Design

        Five test pits excavated at the site revealed no engineered cover material. We assume that there is
 no liner or leachate collection system, but the PSA did not specifically discuss these features.

 Site Environment and Hydrogeology

        The landfill is  located in the Upper Glacial geologic unit, which extends to at least 90 feet below the
 land surface. The unit is comprised of coarse to fine sand and medium to fine gravel,  with less than five
 percent silt. The soils are highly permeable, with hydraulic conductivities ranging from 1.46 x  10'1 to 6.55 x
 10"1 centimeters per second (cm/sec). Average annual precipitation for the region is 43.4 inches per year, 21
 inches of which is available for infiltration.        .

       • The landfill is  located in a primary recharge area to the Upper Glacial aquifer, which is hydraulically
 connected to two other aquifers (the Magothy Formation and the Lloyd Sand of the Raritan Formation).
 Both the Upper Glacial and the Magothy aquifers are pumped for domestic and industrial1 uses in the vicinity
 of the site.  Two municipal well fields are located about  1.25 miles and 3 miles from the site. The aquifer
system has been designated a "Sole Source Aquifer", by the U.S. EPA under the provisions of the Federal Safe
 Drinking Water Act.            '                                    •

        Although wetlands are located near,the site, they are isolated from the landfill by road systems.  It
 is not likely that surface water run-off will reach any rivers or creeks due to topographic and human-built
 borders.

 Summary of Environmental  Damages                                     <

        Ground-water  monitoring at the perimeter of the landfill detected seven inorganic  contaminants at
elevations that exceed the New York  State  Class  GA standards for ground water.  The levels of these


                            *** January 5,1995.Draft Document ***

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    3-8
    contaminants, as well as the level of total dissolved solids (TDS), are compared to Class GA standards and
    EPA drinking water standards (MCLs and SMCLs) in Table 1.
TABLE 1
GROUND-WATER CONTAMINANTS EXCEEDING
NYS AND/OR FEDERAL DRINKING WATER STANDARDS
•
Contaminant
chromium
iron
lead
magnesium
manganese
sodium
zinc
TDS
Highest
Detected
Level
(Mg/1)
134
130,000
90
94,900
33,200
178,000
391
1,630,000
Class GA
Standard
0*grt)
50
300
25
35,000
300
20,000
300
500,000
MCL
(Ag/l)
, 100
, —
15a
-
—
~
.
-
SMCL
(MS/I)

300,
'• —
-
50
—
500
-500,000
a Value is action level for lead at the tap.
\
   Discussion                                                               ...

           Ground water at the perimeter of the landfill was found to contain several contaminants at levels
   above their drinking water standards.

           Municipal well fields are located about 1.25 to 3 miles from the site. Off-site ground-water monitoring
 '  was not conducted as pan of this study. According to the investigators, data from this one round of sampling
   do not conclusively determine whether or not the C&D landfill is affecting ground-water quality near the site.

           No disposal of hazardous waste (as defined in 6NYCRR Part 371) was documented during the PSA.
(   The  PSA recommended closing the Garofalo C&D site, and capping it to  reduce infiltration and provide
  ' surface water control.              :      ,                                       •  •    •
   Source
          Final Preliminary Site  Assessment:   Garofalo  C&D  Site; New York State Department of
          Environmental Conservation (NYSDEC); November 1991.
                               *** January S, 1995 Draft Document ***

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                                                                                               3-9

 MORAN C&D SITE                                                 Philmont, New York


 Media Affected:       Ground Water, Surface Water                    ,

 Overview of Site/Site History

        The Moran C&D site is a landfill comprising 1.75 acres of a 12-acre lot in Philmont, New York. The
 landfill received processed C&D waste from April 1988 until November 1988. From the summer of 1988 until
 its closure, there were numerous complaints of noise and illegal dumping.  A New York State Department
 of Environmental Conservation (NYSDEC) inspection of the site indicated that approximately 10,000 tires
 were buried at the bottom of the'valley. The site caught fire in April 1989.  The fire was controlled but not
 extinguished due to high internal temperatures.  During the fire fighting efforts, a temporary impoundment
 was constructed along the southern edge of the Moran property to contain  the fire water run off. In March
 1990 the fire broke out again.  Once again the fire was controlled but not extinguished. As of November 1991,
 the site was still smoldering.

        The site is located in close proximity to the most populated section of the Village of Philmont. The
 population within a one-mile radius is estimated to be 1,875.  There are five residences in close proximity to
 the landfill.'                                               '                                   .

 Facility Operations

       The landfill consists primarily of C&D waste with a low percentage of solid waste and non-hazardous
 industrial waste. The filled materials are approximately 70 percent charred, partially decomposed wood pallets
 and construction lumber.  Other materials included  armored electrical cable, steel and copper pipes, thin
 plastic sheeting, concrete rubble,  carpet, and a crushed drum.. The fill materials are in a sand, silt, and clay
 matrix that comprises  15  percent of the fill by volume.   Additional solid waste at the  site includes
 approximately 10,000 tires.
                           - ' f
       NYSDEC site inspections noted numerous violations of Departmental rules and regulations during
 the landfiiling operation. The improper operation of the site also resulted in several complaints from citizens
 regarding odors, additional  traffic, noise, etc.                   '           .
           /
 Facility Design

       The site was originally a narrow valley or gorge between two north-south oriented ridges.  This valley
was about 100 feet deep and bounded by a steep bank on the west side and a vertical rock cliff on the east
side. The average thickness of the fill in the central portion of the site is 50 feet with a range from 10 to 95
 feet. The fill is covered by  18 inches of soil cover that generally supports grass..

       A three- to four-foot "leachate control berm" composed primary of soil materials separates the flat
section of the Moran property from the broader base of the valley to  the south.; Run off (not leachate}
accumulates on the site behind this berm and ultimately infiltrates into the ground.

Site Environment and Hydrogeology

       The geologic units at the site consist of a glacial till, an alluvial sand and gravel unit, and shale/phyllite
and greywacke bedrock. The glacial till is comprised of 41  percent sand, 24 percent gravel, and 35 percent silt
and clay. Its average hydraulic conductivity is  9.3 x 10"6 centimeters per second (cm/sec).  The alluvial unit
is 80 percent sand, 2 percent gravel, and  18 percent silt and clay, and its average hydraulic conductivity is 6.95
x 10   cm/sec.  The bedrock is intensely folded and tilted and has an average hydraulic conductivity of 1.1 x
 10'3 cm/sea                                         =
                            *** January 5, 1995 Draft Document ***

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 3-10                                                                .      s

         Ground water occurs in both the glacial till and bedrock, both of which are sources of drinking water
 for the residents  of Columbia  County.  Both units typically have low yields that, can only satisfy small
 requirements such as those needed for domestic supplies.  The overburden recharges the bedrock.  The
 presence of two ponds on the adjacent property south of the site also suggest that these may also receive
 recharge from the overburden system.

         Pooriy drained glacial till, which is found in many flat areas in this region, has created many wetlands.
 Two freshwater wetlands exist within one mile of the site. As mentioned.above, there are also two small ponds
 on private property immediately south of the site.                                      ,

 Summary of Environmental Damages
                                              '        J
         Three sediment samples and two surface water samples were taken during the PSA. Sediment samples
 were taken at the northern property boundary in an area frequently characterized by seeps, and both sediment
 and surface water samples were  taken from the on-site run-off pond next  to the  leachate control berm, and
 a pond located  beyond  the leachate control berm on an adjacent property south  of the site.

         Sediments sampled in the off-site pond contained a pan per billion (ppb) concentration of di-n-octyl
 phthalate, and sediments in the on-site run-off pond contained six polynuclear aromatic hydrocarbons (PNAs)
 below the reporting limit. Sediment metal concentrations of lead and mercury'exceeded the sediment criteria
 used by the NYSDEC Division of Fish and Wildlife in the northern seep area; zinc and arsenic exceeded these
 criteria  in  two locations (the  northern seep area and,the on-site and off-site pond, respectively); and
 manganese exceeded the sediment criteria in all three locations.

TABLE 1
SURFACE WATER CONTAMINANTS
EXCEEDING NYS CLASS C STANDARDS
AND/OR FEDERAL AWQC
Contaminant
aluminum
iron
zinc
Highest
Detected
Level
0*g/I)
1,670
2,720
51
NYS
.Class C
Standard
0*g/l)
100
300
30
AWQC
(M8/1)
__a'
1,000
220
a We are unable to calculate the AWQC for
aluminum because it is pH-dependent and the
source document did not provide a pH value for
- the surface water sampled.

         Both surface water  locations  had
 concentrations of inorganics above NYSDEC
 water quality standards  for Class C surface
 water and/or federal Ambient Water Quality
 Criteria   (AWQC)   (see   Table    1).
 Concentrations  were highest  in the off-site
 pond.

         Ground-water samples were taken at
 bedrock  (deep) and  overburden  (shallow)
 wells  at  two upgradient  locations  and four
 downgradient locations (two within the fill and
• two downgradient of the fill but within the
 property boundary). According to the source
 document, comparing metals results in one of
 the upgradient  wells to the  on-site shallow
 wells  indicates  that  the site  contributes
 dissolved   metals   to   ground   water.
 Constituents whose concentrations  exceeded
 NYS  Class  GA ground-water standards or
 federal drinking water standards (primary or
 secondary MCLs) are shown in Table 2.   "

         It is also noteworthy that area residents complained of a rotten egg odor as well as a variety of
 symptoms (e.g., eye and  respiratory  irritation) similar  to the known health effects of hydrogen sulfide.
 Ambient air quality samples found hydrogen sulfide levels up to 11 parts per billion.

 Discussion                         |

        The PSA found contamination of on-site and off-site surface water and sediments with metals at
 concentrations exceeding  applicable  standards.  The site was. also found to contribute dissolved metals to
                             *•• January 5, 1995 Draft Document ***

-------
                                                                                           3-H
 ground  water.     Many  metals
 exceeded applicable standards in on-
 site ground-water monitoring wells;
 no  off-site   monitoring   was
 conducted.     Area   residents
 complained of a rotten egg odor as
 well as  as variety  of  symptoms
 similar to the known health effects
 of hydrogen sulfide.

        Based  on  the  PSA and
 previous   sampling,   the   site
 investigators recommended that the
 site  be closed,  and  that  ground-
water quality and flow direction be
 monitored  to  identify  seasonal
variations and long-term trends in
ground-water quality.
Source

TABLE 2
GROUND-WATER CONTAMINANTS EXCEEDING,
NYS AND/OR FEDERAL DRINKING WATER STANDARDS
Contaminant
aluminum
iron
lead
magnesium
manganese
sodium
Highest
Detected
Level
(Mg/l)
13,500
24,200
24a
127,000
20,300
167,000
Class GA
Standard
0*8/1)
—
300
25
35,000
300
20,000
MCL
(M8/I)
--
— '
15"-
~ '
~

SMCL
.frtgfl)
50-200 ,
300
—
«
50
~
a Value is reported as estimated value in source document.
b Value is action level for lead at tap.

       Final Preliminary Site Assessment: Moran C&D Site; New York State Department of Environmental
       Conservation; November 1991.                               '   .       -
                           *** January 5,1995 Draft Document ***

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 3-12                                                          .

 ROUTE 52 - HILLS HOLDING CORPORATION SITE       Fallsburg, New York


 Media Affected:       Ground Water, Surface" Water

 Overview of Site/Site History                  .            ,    r   '
                                                    /
        The Route 52 - Hills Holding Corporation Site is a landfill comprising 8 acres of a 26.4-acre lot
 located in Fallsburg, New York.  The landfill began C&D operation in the summer of 1988 as an exempt C&D
 debris site.  The debris was deposited on a hillside between a pond and the Neversink River. The landfill was
•closed by the New York State Department of Environmental Conservation (NYSDEC) in October 1988.

        There are 12 public wells within a 3-mile radius of the site that supply water to approximately 12,000
 people year round, with as much as a fivefold increase in the summer months.  A house is located  on the
 property east of the pond and west of the landfill, and another residence is located adjacent to the site about
 200 feet to the north.

 Facility Operations                   '

        The waste present in the landfill is composed mainly of oily-appearing soil, wood and lumber products,
 concrete,  brick, steel re-bar, carpet, glass,  plastic sheeting, wires, rags, telephone  cable, and steel pipes.
 Disposal of refuse and unpermitted burning were noted at the site.  In September 1988, the disposal of four
 five-gallon pails with roofing compound was observed at the site. The compound was referred to as a New
 York State  hazardous waste by  the source document.  The pails were removed from the landfill and placed
 in an overpack drum.
                \  .
 Facility Design                        ,    '  "

        The PSA revealed a one-foot-thick silty sand and gravel cover material. There does not appear to be
 any liner or leachate collection system at the site. Leachate was observed by state officials to be emanating
 from the northeast corner of the  landfill into the Neversink River. Berms have been constructed at some areas
 of the landfill.

 Site Environment and Hydrogeology             ' '   '

        The Neversink River, a major tributary to the Delaware River,  flows, southward past the site about
 100 feet from the eastern side of the landfill. The Neversink River is classified as a Class B waterway. A five-
 acre pond exists along the western side of the landfill. An area of approximately 10 feet by 20 feet of shallow
 standing water with wetland vegetation lies between .the Neversink River and the landfill's southeast corner.

        Surface drainage is poor and flows to the Neversink River.  Surface water run-off and associated
 sediments from all but the'northern third of the landfill area are bounded by natural levees or man-made
 berms on the site.  Surface water and sediments from the northern third of the site enter the Neversink River
 via intermittent streams or a drainage ditch on an adjacent residential property. A small quantity of run-off
 enters the on-site pond.                         .

        Two unconsolidated units overlie weathered bedrock at the site.  The lower'unit is a glacial till
 comprised of 35 percent gravel,  40 percent sand, 20 percent silt, and 5 percent clay. The average hydraulic
 conductivity is 2.9 x 10"4 centimeters per second.  The upper unit is comprised of alluvial soils, described as
 loose brown fine silty sand.  These overburden materials overlie highly weathered and fractured bedrock at
 depths ranging from 6 inches to 12 feet. The bedrock has a hydraulic conductivity of 9.0 x 10"3 to 7.5 x 10"4
 cm/sec. The ground-water movement within the overburden and. shallow bedrock is affected by the on-site
 pond, which causes a local radial  flow pattern eastward toward the Neversink River. The shallow ground water
                             *** January 5, 1995 Draft Document ***

-------
                                                                  -                             3-13

  in the bedrock is believed to be hydraulically connected to the overburden.  Therefore, landfill leachate can
  potentially recharge the local aquifer system.

  Summary of Environmental Damages

         Surface  water  samples  were taken
  from  the Neversink River upstream of the
  site, adjacent to the site, and  in a public
  access fishing area downstream of the site;
  from  the on-site pond  west  of the landfill;
  and from an effluent stream south of the
  landfill. •   Concentrations  of   inorganic
  constituents in the Neversink River adjacent
 ,to  the  site were elevated compared  to
 samples taken upstream. Many inorganics
 exceeded* their  Class  B   surface water
 standard or EPA's Ambient Water Quality
 Criteria  (AWQC)  in   the  river" .sample
 adjacent to  the site  (Table  1).   Only
 vanadium exceeded its  Class B standard in
„ the pond surface water samples. Polynuclear
 aromatic   hydrocarbons   (PNAs)   were
 detected  in -sediment  samples   in   the
 Neversink River and in a wet area southwest
 of the landfill.

         Six ground-water monitoring wells
 were installed, one background well and the
 remainder positioned around the landfill at
 locations likely to intercept ground-water
 contamination. Concentrations of inorganics
 were  significantly higher in  samples from
 three  downgradient wells compared to  the
 upgradient well.  Many inorganic  constituents exceeded Class GA ground-water standards and/or "federal
 drinking water standards (primary or secondary MCLs) in downgradient wells.  These are shown in Table 2.

         Prior to the PSA, a private laboratory sampled the adjacent residence's well water and found low levels
 of contamination from, carbon tetrachloride.

 Discussion

         Elevated concentrations of inorganics were detected in an adjacent river and in ground water; many
 of the samples exceeded applicable standards. Although off-site ground-water samples were not taken, the
 PSA noted that municipal well fields are vulnerable to contamination due to their proximity to the site and
 the nature of the hydrogeology.                                                        .          '
                 '                      *         r "                                       /
               The PSA recommends that the landfill be (1) properly closed, in accordance with New York
, regulations, and (2) capped, to limit infiltration and provide surface water drainage control.
TABLE 1. NEVERSINK RIVER SURFACE WATER
CONTAMINANTS EXCEEDING NYS CLASS B
STANDARDS AND/OR FEDERAL AWQC











Contaminant

copper
iron
lead
vanadium
zinc
Highest
Detected
Level
0*8/1)
' 30
24,000
70C
26
156

Class B
Standard

-------
3-14
- 1 '
TABLE 2
GROUND-WATER CONTAMINANTS EXCEEDING .
NYS AND/OR FEDERAL DRINKING WATER STANDARDS
Contaminant
aluminum
barium
beryllium
chromium
iron
lead
magnesium
manganese
nickel
sodium
zinc
TDS
Highest
Detected Level
0*8/1)
5l,200a
1,290
: 5
151a
90,500
90
55,200
36,300
157a
73,200
364
"812,000
Class GA
Standard
0*g/l)
—
1,000
3b
50
300
' 25
• 35,000b
300
~
20,000
. 300
- 500,000
MCL
Vg/i)
—
2,000
4
100
— •
15C
-
T-
100
. —

-
SMCL
(Mg/1)
50 to 200
—
-
•
300
—
—
50
~
' —
5,000
500,000
f .
a The value was reported in the source document as "estimated."
b New York State Guidance Value.
c Value is action level for lead at tap. ' '

••
Source
       Final Preliminary Site Assessment: Route 52 - Hills Holding Corp. Site; New York State Department
       of Environmental Conservation; November 1991.
                          *** January 5, 1995 Draft Document ***

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                                                                                       ' .  -   3-15

 COX'S DARBYTOWN ROAD LANDFILL                   Henrico County, Virginia


 Media Affected:      Ground Water

 Overview of Site/Site History

        The 100-acre site is located in Henrico County, Virginia, adjacent .to a road and two miles from the
 Richmond International Airport runway.  According to an engineering company working for the landfill, the
 shallow aquifer in the area of the landfill receives only limited use. Although the exact opening date of the
 landfill is unknown, the landfill received a permit on June 20, 1989 for its third parcel (a 34-acre area) to
 accept wastes; the other two parcels had already been receiving demolition wastes. According to the source
 documents, the landfill has accepted only construction, demolition, and debris wastes.

 Facility Operation's                                  .                                   •        •

        The site is permitted to accept only construction, demolition, and debris wastes, including construction
 debris,  demolition debris,  broken brick, block, concrete rubble, brush, tree trimmings, stumps, and leaves.
 Excluded are municipal solid waste (any putrescible waste), industrial waste, liquid waste, and hazardous waste.
 According to the 1989 site  investigation, the site apparently also accepted tires.

 Facility.. Design                                                   '

        The design of the landfill required a one-foot liner of on-site soil with a permeability of less than 1
 x 10"6 centimeters/second, a leachate collection system of PVC pipe for each cell, a collection manhole for each
 cell, and a  pump and haul process to a treatment facility.   A 1988 memo from the Wiley and Wilson
 engineering firm noted that where existing sand pits were located, the pits would be filled with non-organic
 waste material consisting of broken concrete, bricks, broken pavement, and soil up to an elevation of one foot
 below the bottom of the landfill and then covered with a one-foot liner layer. The design included a 100-foot
 wide buffer strip around the perimeter of the entire landfill with a 50-foot buffer strip on the inside boundaries
 of the adjoining sections of the landfill. Ground-water monitoring is conducted at one upgradient and three
.downgradient wells.

 Site Environment and Hydrogeology
                                                                                              /

         The shallow aquifer lies 1 to 14 feet below the ground surface in the area of the landfill, but the
 landfill  design required at least 3 feet between the seasonal high ground-water elevation and the bottom of
 the landfill, including a one-foot liner.  It is  unclear whether the  landfill design is in violation of  this
 requirement A nearly impermeable marl layer serves as a confining layer to the deeper aquifer.  The site
 apparently has gently sloping topography.                                                 *

        In the  shallow aquifer, the dominant ground-water flow direction at the site is northward.  The
 ground-water velocity ranges from 5.6 x'10"6 cm/sec at the eastern portion of the site to 8.8 x  10"6 cm/sec at
 the western portion of the  site. The hydraulic gradient ranges from 0.012-0.019 ft/ft at  the site.  Little is
 known about the deeper aquifer except that it is virtually confined by an overlaying marl.

 Summary of Environmental Damages              -

     ,  A 1989 site inspection revealed waste slopes exposed due to lack of sufficient cover, a breach of the
 50-foot buffer zone between wastes and the edge of the property, and leachate seeps that did not leave the site.

        1993 monitoring results indicated statistically significant increases in specific conductance and total
 organic carbon (TOC) in downgradient on-site wells when compared to an upgradient well. In addition, pH
 was found to be unusually low during the 1991 monitoring.


                            *** January 5,1995 Draft Document .***

-------
3-16

Discussion

       According  to  the  1993
Annual Report, data gathered from
ground-water monitoring  indicate
that  contamination  .may   be
occurring in the ground water at,
Cox's Darbytown Road Landfill.
The facility  was moved into the
Phase  II   monitoring  program
because  specific  conductance  and
TOC  were  significantly higher in
downgradient wells  than  in  the
upgradient/background well.  The
source documents do not address
whether or  not the contamination
extends off site.

Sources

TABLE I. GROUND-WATER PARAMETERS EXCEEDING
BACKGROUND LEVELS AND FEDERAL DRINKING
WATER STANDARDS
Parameter
TOC Ogfl)
conductance
(umhos/cm)
Parameter
PH
Highest
Detected
Level
57,000
2758
Lowest
5.98
Background .
Level
21,200 '
170
/
Background
6.6'
MCL
—
-
MCL
, „
SMCL
—
-
SMCL
6.5-8.5
-

       1993 Annual Report/Cox's Darbytown Road Landfill, Inc.  Prepared by Joyce Engineering, Inc., June
       1994.                                     -

       1st Quarter Phase I Sampling Event Results, Cox's Darbytown Road Landfill, Inc.  Prepared by Joyce
       Engineering, Inc., May 1994.

       2nd Quarter Water Monitoring Analyses, Cox's Darbytown Road Landfill, Inc. Prepared by Joyce
       Engineering, Inc., July 1990.       -                           .                 '
                                                  •                                     /
       Chemical Analytical Report, Central Virginia Laboratories and Consultants, May 1994.

       Commonwealth of Virginia, Solid Waste Disposal Site Inspection .Report of Darbytown Landfill,
       September 5, 1989.

       Commonwealth of Virginia, Department of Health Permit to M & M Wrecking Company, Inc., for
       a Sanitary Landfill, July 3, 1975.

      ' Commonwealth of Virginia, Department of Waste Management, Application for Permit to M & M
       Wrecking Company, Inc., October 28, 1987.                                     /

       Memorandum from  Linda  K. Lightfoot  to  Berry F. Wright,  Virginia Department of  Waste
       Management, November 20, 1987.

       Memorandum from  Wiley  & Wilson  to  Berry F. Wright, Jr., Virginia Department of  Waste
       Management, January 13, 1988.

       Memorandum from  Wiley  & Wilson  to  Berry F. Wright, Jr., Virginia Department of  Waste
       Management, January 20, 1988.

    „  Memorandum from John F. Deal to Dr. W. Gulevich, Virginia Department of Waste Management,.
       August 19, 1987.

       Memorandum from S.B. Cox, Inc. to Hassan Vakili, Virginia Department of Waste Management,
       January 8, 1993.
                          *** January 5, 1995 Draft Document ***

-------
           •     .  •           •            •               f         '                3-17

Memorandum  from Edward Hollos,  Joyce .Engineering,  Inc.,  to Howard Freeland,  Virginia
Department of Environmental Quality, June 30, 1994.

Memorandum from Harry Gregori, Virginia Department of Waste Management,  to S. B. Cox, Inc.,
June 21, 1991.                       • •    •

Solid Waste Facility Permit, June 20, 1989.              '   -  ,
   /             •               .              -•                "
Solid Waste Facility Permit, July 26, 1988.                         .
                    *** January 5,1995 Draft Document ***

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 3-18                                                              -

 CRIPPEN STUMP DUMP                                     Fairfax County, Virginia


 Media Affected:       Ground Water, Surface Water
                    .    •   '     ,'  '  f
 Overview of Site/Site History

        The Crippen Stump Dump is located in a residential area in the Dranesville District of Fairfax County.
 The site consists of 66 acres and is separated from the surrounding residences by 50-foot fire breaks and rows
 of white pine trees acting as screens. The landfill is divided into two areas, separated by Green Branch.  The
 main area, in the northwest portion  of the site,  is accessible by a bridge  over  Green Branch, and the
 supplementary area, in the southeast, is used when the northwest portion is inaccessible.  Sixty-seven homes
 are located within 1,000 feet of the landfill and rely on private ground-water wells for drinking water.

        A landfill fire broke out on December 19, 1986, and had not yet been extinguished as of April 1987.

 Facility Operations

        The Crippen Stump  Dump accepts inert debris such as C&D debris, large stumps, boards, and scrap
 metat.  Loads may not contain more than  10 percent paper and cardboard. Asbestos, household trash; and
 hazardous materials are prohibited.  An on-site operator is supposed, to inspect material after it has been
 dumped, and place unacceptable wastes in a separate bulk container for proper disposal.  However, a site
 inspection in 1987 found that asbestos had been illegally accepted, and the landfill was cited for not having
 a spot checker to inspect loads.  Also, trucks have been stored on site  in violation of the landfill's zoning
 permit.                         ''         ,                                                  •

        Daily cover is applied to minimize litter and scavenging.  .

 Facility Design                      .

        The Crippen Stump Dump.is unlined and we assume that there is no leachate collection. Local soil
 and subsoil are used as cover.  Ground-water and surface water monitoring are conducted.'
                       t-
 Site Environment and Hydrogeology

        The landfill is underlain by brown silty sand to depths of 0 to 8 feet, and brown sand silt  to depths
 of approximately 15 to 30 feet, where decomposed rock lies.  Uncompacted permeabilities were not found in
 the source documents. Silty sand stockpiled at the site for use as cover has a permeability of 1.3 x 10"6 cm/sec
when recompacted to 93.6 percent.                                        '

        The ground water is used for drinking water by local residents. Ground water is an average of 5  feet
 from the ground surface, ranging from  1 to 3 feet near the stream, and 55 feet at one monitoring well.  The
source documents note that the flow from the northwest portion of the site appears to be south or east toward
 Green Branch, which bisects  the property in a southwest to northeast direction.

 Summary of Environmental  Damages   '

        In 1986 the landfill was found to be in noncompliance with its permit due to steep slopes. A 1990
 inspection found erosion had exposed solid waste and created leachate seeps flowing into Green Branch. The
landfill received a Notice of Violation for (1) failing to provide proper maintenance of erosion controls and
 (2) failing to protect county and state waters from pollution.
                                                   ~N
        According to a source document, stream monitoring opportunities exist in Green Branch, above and
below the landfill, and in two conduit systems. Two surface water samples were reported. Their location was
                i
                            *** January 5, 1995 Draft Document ***

-------
               "'.'•'                                                         3-19

 not specifically stated, but it seems likely that the samples were from Green Branch, above and below the
.landfill.  Whether the samples were on or off site is unknown.  A 1988 source document noted that .the
 surface water data indicate "no apparent problems," but that the pH and alkalinity of the already acidic stream
 was low, and that the stream is losing the ability to buffer  itself.  The pH was 6.2 at sampling site Si
 (apparently the background sample) and the pH was 4.4 at sampling site S2.
        Four wells, apparently on site, are used for
ground-water monitoring.  In 1985, elevated levels"
(above MCLs) of cadmium, iron, and lead, as well as
low pH, were reported in ground-water,monitoring
wells (Table 1).

Discussion      -            '

        Elevated levels of inorganics and low pH
have been found in  the ground water, probably on
site, but the source  documents noted the potential
for off-site migration of ground  water  from the
northeast  portion of the  landfill.   It  is  unclear
whether the landfill is further reducing the alkalinity
of an already-low-alkalinity stream that bisects the
Crippen property.

TABLE 1. GROUND-WATER .
CONTAMINANTS EXCEEDING FEDERAL
DRINKING WATER STANDARDS
Contaminant
/Parameter
cadmium
iron
lead
manganese
Parameter
PH
Highest
Detected
Level
0*Sfl)
28
15,000
54
'540
Lowest
5.1
MCL
0*8/1)'
5
.
15a
--
MCL
-
SMCL
0*g/i)

300
-
50
SMCL
6.5-8.5
a Value is action level for lead at tap.
Sources
       Closure Plan Narrative .for Stump Dump Inc., Debris Landfill, by Draper Aden Associates, Inc.
       October 20, 1988.   -

      . "Great Falls Dump Gets a Temporary Reprieve on Operation," The Washington Post, October 27,
       1988. '

       Letter from C.G. Cooper, Department of Environmental Management, County of Fairfax, to M.S.
       Crippen, Jr., Stump Dump, Inc. November 17, 1987.

       Letter from C.G. Cooper, Department of Environmental Management, County of Fairfax, to M.S.
       Crippen, Jr., Stump Dump Inc. April 28, 1987.

       Letter from Janine Durbecq, Landfill Administrator, Department of Environmental Management, to
       Lock Crippen, Stump Dump Inc., October 26, 1987.

       Letter from Joseph Beben, Department of Environmental Management, County of Fairfax, to M.S.
       Crippen, Jr., Stump Dump, Inc., February 27, 1990.

       Letter from Robert Forman, Bureau of Solid and  Hazardous Waste, Department of Health,
       Commonwealth of Virginia, to M.S. Crippen, Jr., June 13, 1985.

       Letter from Robert Forman, Bureau of Solid and  Hazardous Waste, Department of Health,
       Commonwealth of Virginia, to M.S. Crippen, Jr., July 16, 1985.
                           *** January 5, 1995 Draft Document ***

-------
3-20
       Letter from C.G. Cooper, Department of Environmental Management, County of Fairfax, to M.S.
       Crippen, Jr., Stump Dump Inc., March 2, 1987.

       Letter from C.G. Cooper, Department of Environmental Management, County of Fairfax, to Douglas
       Davis, November 17, 1987.          -

       Letter from Mack Crippen, Jr., Stump Dump Inc., to Robert Formari, Bureau of Solid and Hazardous
       Waste, Department of Health, Commonwealth of Virginia, November 17, 1986.

       Letter from Fred Miller, Law Engineering Testing Company, to Stump Dump, Inc., May 16, 1986.

       Letter from Randy McFarland, Regional Geologist, to Robert Forman, State Department of Health,
      , Commonwealth of Virginia, January 31", 1985.

       Letter from Lock  Crippen, Stump  Dump,  Inc., to Kenton  Chestnut, Bureau of Solid  Waste
       Management, Commonwealth of Virginia, March 25, 1986.

       Letter from Robert Forman, Bureau of Solid Waste Management, Commonwealth of Virginia, to M.S.
       Crippen, Jr., June 11,  1986.

       Letter from Dean Starook, Department of Waste Management, Commonwealth of Virginia, to John
       Watt, The Crippen Companies, February 12, 1990.

       Letter and data summary from William Bukevicz, Dewberry and Davis  (engineering firm), to Lock
       Crippen, Stump Dump Landfill, December 21, 1988.

       Letter from John  Watt,  The Crippen Companies,  to  Dean  Starook, Department  of  Waste
       Management, Commonwealth of Virginia, February 16, 1990.

       Letter 'from Mary Holden, Stump  Dump, Inc., to Air Pollution Control  Division, Fairfax County
       Health Department, February 9, 1987.
                         *** January 5, 1995 Draft Document ***

-------
                                            .   •  .                                           3-21

 FURNACE ROAD DEBRIS LANDFILL                               Lorton, Virginia

 Media Affected:       Ground Water, Surface Water

 Overview of Site/Site History

        The Furnace Road Debris Landfill, also called the Lorton Landfill, is a 264-acre C&D landfill located
 off of Furnace Road near Shirley Memorial Highway in Fairfax County, Virginia. It has operated as a C&D
 landfill since it was originally permitted in 1981. The landfill is located in a "mixed use area" near the District
 of Columbia's Lorton Landfill, the Lorton Correctional Institution, and the Fairfax County Energy Recovery
 Facility.  It is also downgradient of a residential subdivision, which is separated from the landfill by vacant land
 and a gas line easement.

 Facility Operations

        The landfill accepts construction debris such as din, wood, and concrete, with small amounts of paper,
 plastic, and miscellaneous metal items such as reinforcing steel, strapping, structural steel, and piping. The
 landfill also accepts tires. Non-hazardous soil contaminated with petroleum products is disposed as daily cover
 at the landfill. This soil must be regularly sampled, and total petroleum hydrocarbon concentrations  must be
 less than 50 parts per million (ppm), total organic halides (TOX) less than 100 ppm, total benzene,  toluene,
 ethylbenzene, and xylenes (BTEX) less  than 10 ppm, and the Toxicity  Characteristic Leaching Procedure
 (TCLP) must result in less than 5 mg/1 of arsenic and lead.

 Facility Design

        There does not appear to be a liner for the landfill. Leachate is collected in a plugged siltation pond.
 Ground-water monitoring has been conducted since 1981, when the landfill was  originally permitted.

 Site Environment and Hydrogeology          ~        ,

        Shallow ground water in Coastal Plain sediments is underlain by a deeper bedrock aquifer. Depth to
 ground water is less than 13 feet in some places.  The flow direction and rate were not mentioned in the
 source documents.  Ground water in the area is naturally high in iron.
        Stormwater drains to Giles Run, a
tributary to  the  Occoquan  and  Potomac
Rivers.  Two smaller tributaries run from the
landfill to Giles Run.

Summary of Environmental Damages

        The main problem in surface water is
elevated  levels of  fecal  coiiform  bacteria,
which do not  appear to be related to the
landfill.    However,  hardness  and  total
dissolved solids (TDS) levels  in some oh-site
surface  water   samples  also   exceed
recommended  levels due to the influence of
leachate, according to a 1988 memo from the Dewberry and Davis engineering firm (Table 1).  There are no
AWQC for hardness or TDS.

        Four ground-water wells were used to monitor contamination, two wells that a source document
assumes to  be  background, and two apparently downgradient of the fill, but within the property boundary.
Elevated levels of iron, manganese, total organic carbon (TOC), TOX, and hardness and slightly elevated levels

TABLE L SURFACE WATER CONTAMINANTS
EXCEEDING RECOMMENDED LEVELS
Contaminant
hardness
TDS
Highest
Detected Level
0*g/D
500,000
1,125,000
Recommended
Level
0*gfl)
100,000
250,000


                            *** January 5, 1995 Draft Document ***

-------
 3-22
. Gl
* TABLE 2 '
ROUND-WATER CONTAMINANTS EXCEEDING
FEDERAL DRINKING WATER STANDARDS
Contaminant
iron
manganese
Highest
Detected
Level
0*8/1)
69,600
.1,980
MCL
0*g/D
•
~
SMCL
(MS/I)
• 300
50

>
 of, total dissolved solids (TDS) have been
 found in the ground water at various
 times.  Table 2 shows the contaminants
 that  exceeded  federal  drinking  water
 standards (MCLs or SMCLs).

 Discussion -

        According   to   the   source
 documents, leachate from the landfill is
 contributing   to   elevated  levels  of
 contaminants  in   ground  water  and
 surface water.   A 1985 memo  from
 Randy McFarland, Regional Geologist,
 to John Clayton noted that much of the
 leachate  generated   in  the   landfill
 probably migrates in shallow ground water, discharges at springs, and flows on the surface to Giles Run.  He
 also noted that some portion of the leachate probably migrates from the sediments down through the bedrock
 to the deeper aquifer.  According to McFarland, the main problem in the bedrock aquifer is that metals and
 hardness are elevated, probably because naturally-occurring metals (e.g., iron) are mobilized in dissolved forms
 by teachate-associated acids. McFarland also commented that the shallow ground water has the same problems
 as the bedrock ground water.  In addition, a 1988 memo from Dewberry and Davis to George Neal noted that
 hardness and total dissolved solids (TDS) in surface water were elevated above recommended levels due to
 influence of the leachate..

        Another source document noted that some of the ground-water contamination is directly attributable
 to specific C&D wastes.  According to a 1994 memo from Dewberry and Davis to Burwin Reed, TOC in the
 ground water is elevated due to the decomposition of wood buried in the landfill,  TOX levels are elevated
 probably due to the decomposition of construction debris such as asphalt, and hardness levels are elevated due
 to the breakdown  of wood and concrete in the landfill.   However,  EPA  believes  that  the  petroleum-
 contaminated soils permitted  for use as daily cover may contribute'to TOX levels in the ground  water.

        However, two other source documents indicate that the damage to the environment is not significant.
 A 1989 memo from Dewberry and Davis reported "no  significant problems,.overall." In 1993, a Professional
 Engineer certified that, based on his review of documents, drawings, and reports regarding the Furnace Road
 Landfill, "it is not an open dump and does not pose a substantial present or potential hazard to human health
and the environment" and "it appears that the leachate and residues from this solid waste facility do not pose
a threat of contamination or pollution of air, surface water, or groundwater in a manner constituting an open
dump or resulting in substantial present or potential hazard  to human health or  the environment." This
appears to be standard language used in a Petition for Variance to extend C&D landfill permits.

Sources
       Biospherics Incorporated, Table of surface water and ground-water sampling data for W.H. Gordon
       Assoc., Inc., October 26, 1984.

       Memorandum from William Bukevicz, Associate, Dewberry and Davis (engineering firm), to Burwin
       Reed, Lorton Landfill, January 14, 1994.

       Memorandum from William Bukevicz, Associate, Dewberry and Davis (engineering firm), to Burwin
       Reed, Lorton Landfill, July 7, 1993.

       Memorandum from William Bukevicz, Director, Environmental Laboratory, Dewberry and Davis
       (engineering firm), to Burwin Reed, Wiser Brothers, Inc., July 20, 1990.
                            *** January 5,1995 Draft Document ***

-------
     •   ,                      .                             •             •          3-23

Memorandum from William Bukevicz, Director, Environmental Laboratory, Dewberry and Davis
(engineering firm), to George Neal, Wiser Brothers, Inc., December 20, 1988;

Memorandum from Elaine Schaeffer, Director, Environmental Services, County of Fairfax, to Burwin
Reed, Lorton Landfill, March 17, 1988.

Memorandum from Ulysses B.  Brown, Jr., Solid Waste Compliance Manager, Office of Waste
Resource Management, Commonwealth of Virginia, Department of Environmental Quality, to Terre
Sulock, Production Manager, EnviroCraft Corporation, May 31, 1994.

Memorandum from Janice Durbecq, Landfill Administrator, Public Utilities Branch, Department of
Environmental Management, Commonwealth of Virginia, County of Fairfax, to Elmer Wiser, Wiser
Brothers, Inc., October 11, 1989.

Memorandum from Randy McFarland, Regional Geologist, Commonwealth of Virginia, State Water
Control Board, to John Clayton, Fairfax County Health Department, February 7, 1985.

Memorandum from William Bukevicz, Director,  Environmental Laboratory, Dewberry and Davis
(engineering firm), to  Burwin Reed, Wiser Brothers, Inc.; February 8, 1990.

Memorandum from Elmer  Wiser, Lorton Landfill, to William Woodfin, Department of Waste
Management, January 12, 1993.

Solid Waste  Management Permit, Commonwealth of Virginia, Department of Health, August 18,
1981.
                    "•January 5, 1995 Draft Document ***

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 3-24                           .                             '

 QUALLA ROAD LANDFILL                             Chesterfield County, Virginia


 Media Affected:       Ground Water, Surface Water .

 Overview of Site/Site History                                                 ,  "           .

        The Qualla Road Landfill is an active 33racre C&D landfill located in a mainly agricultural area in
 Chesterfield County, Virginia. The landfill opened in 1983 with an 11-acre area, and 22 acres were added in
 1988. To date, 16 of those 22 acres have received waste. The facility is owned by a private farmer and leased
 to Sanifill, Inc. The landfill capacity is estimated to'be 1.523 million cubic yards over a design life of 12 years.

       . Two fires  have been reported  at the landfill, one in 1990 and one in 1993.  Both were quickly
 extinguished.

 Facility Operations

        The Qualla Road Landfill accepts C&D waste, brick, concrete rubble, brush, tree  trimmings, and
 stumps. Approximately 40 percent of the waste at the site is land-clearing debris, which is currently disposed
 on approximately ten unlined acres.  The remaining 60 percent is building material and demolition waste and
 is disposed on  approximately six lined  acres.  Prohibited wastes include hazardous waste, liquids, garbage,
 refuse, agricultural waste, industrial waste, paper products, asbestos, fly ash, bottom ash, sludge, tires, white
 goods, leaves, and metal scrap.  According to the permit, six inches of daily cover must be applied.

 Facility Design

        The Qualla Road Landfill has been permitted in sections, and the facility design varies depending on
 when a  section was permitted.  The original 11 acres probably were unlined.  As of 1987, at least five feet
 between the cell bottoms^and the seasonal high ground-water table were required. Of the 22 acres, added in
 1988, 10 acres are unlined, 6 acres are equipped with a compacted soil bottom liner (permeability of 1 x 10"6
 cm/sec) and a-leachate collection system, and the  remaining 6 acres have not yet been put to use. As of 1994,
 leachate must be discharged to an underground storage tank to be ultimately pumped and hauled to a waste
 treatment plant. Run-on and run-off controls, and a ground-water interceptor were also described for portions
 of the landfill in the 1994 design.

 Site Environment and Hydrogeology

        Soils under the landfill consist of a 2-  to 4-foot  upper layer of lean  to fat  clays and elastic silt,
 underlain  by silty sand and sandy silt soils to depths of 20 to 50 feet.  Ground water in the area is found 10
 to 38 feet below the ground surface.  The general movement of ground water is to the west  (toward Reedy
 Branch), with a gradient of 0.03 to 0.08 feet/feet.  Lateral flow is about,3.5 x 10'5 to 3.8 x 10"* centimeters per
second (cm/sec) and vertical flow is about 9.7 x 10'5 cm/sec. Rainfall is estimated at 42 inches a year.

        The landfill drains- into Swift Creek (to the north) and Reedy Branch (to the west),  a tributary to
Swift Creek.  The original 11 acres were located within the 100-year flood plain of Swift Creek. A flowing
stream, possibly fed by discharge through the ground water from a pond at the southern edge of the site, was
 located on the site  prior to the 1987 proposed expansion.
                            *** January 5,1995 Draft Document ***

-------
                                                                                             3-25
 Summary of Environmental Damages

        In 1987, debris was protruding from  the original
 landfill adjacent to Swift Creek, and the relief was too steep
 to retain soil covering.  The source documents attested that
 the presence  of a stream  within the boundaries of the
 proposed landfill expansion was "unacceptable" and could
 present "erosion and sediment control problems."   A 1987.
 Request Analysis and  Recommendation  also noted  that
 "unless actions are taken to stabilize the existing fill area,
 siltation of Swift Creek itself may occur" and that  "due to
 the significant topographic relief of the  proposed  landfill
 area, the potential for siltation of the adjacent property and
 streams, including Swift Creek, appears to be even  greater
 than that of the existing landfill."  A 1993 inspection found
 leachate emanating from the landfill, that "had the potential
 for  discharging off-site."    The   leachate  break  was
 immediately repaired.

       .Surface water samples have been taken from two
 sampling sites, but it is unclear whether the sampling was
 conducted on or off site. Surface water monitoring found
 iron, lead, and acidity levels exceeding freshwater chronic
 AWQC protective of aquatic life (Table 1)..
TABLE 1
SURFACE WATER CONTAMINANTS
EXCEEDING FEDERAL AWQC








.

Contaminant
/Parameter
iron
lead
Parameter
PH
Highest
Detected
Level
(M8/1).
252,000
113
Lowest
5.6
Fresh
Chronic
AWQC
(Mg/l)
1,000
7a
AWQC
6.5-9








a EPA calculated the AWQC value
- using a reported measured
hardness value of 196 ppm.
        Ground-water monitoring has been conducted on site at one upgradient and three downgradient wells.
For each well, samples are compared to background data for that well (i.e., based on samples taken earlier).
In addition, samples from downgradient wells are compared to the background data from the upgradient welt.'
In 1992, ground-water monitoring found elevated levels of lead, manganese, and total organic carbon (TOC)
in a downgradient well compared  to the upgradient background level.. In addition, the lead, manganese, total
dissolved solids  (TDS), and specific conductance exceeded the background mean for that downgradient well.

TABLE 2. GROUND-WATER
CONTAMINANTS EXCEEDING VIRGINIA
PROTECTION LEVELS AND FEDERAL
DRINKING WATER STANDARDS
Contaminant
iron
manganese
Highest
Detected
Level
(MS/I)
103,000
4,600
MCL
(Mgfl)

-
SMCL
0*gfl)
300
50


                                                          Ground-water  monitoring  has also shown
                                                  iron and manganese levels to exceed federal drinking
                                                  water standards (secondary MCLs) (Table 2).

                                                  Discussion

                                                          Schnabel  Environmental   Services,   the
                                                  company that performs ground-water monitoring at
                                                  Qualla Road Landfill,  concluded in  1993 that the
                                                  data do not  indicate that the  landfill  poses  a
                                                  "substantial  threat  to  human  health  or  the
                                                  environment."   However, monitoring has indicated
                                                  exceedances of AWQC in surface water (whether on
                                                  or off site is unknown) and on-site exceedances of
                                                  federal drinking water standards in ground water.
Sources
       General Testing Corporation, Laboratory Reports, dated November 25,1992, February 12,1993, April
       13, 1993, July 21, 1993, and March 17, 1994.
                            *** January 5, 1995 Draft Document ***

-------
3-26
       Letter from  Kenton Chestnut, Jr., Division of Regulation,  Department of Waste Management,
       Commonwealth of Virginia, to Lane Ramsey, County Administrator, Chesterfield County, Virginia,
       February 5, 1990.

       Letter  from  William  Gilley  Division  of Regulation,  Department  of  Waste  Management,
       Commonwealth of Virginia, to Paul Robins, Qualla Road Landfill, January 12, 1990.

       Letter from Carl Benson, Schnabel Environmental Services, to Jim Leiper, Sanifill, October 5, 1993.

       Letter from Schnabel Environmental Services, to Chuck Hurt, J.K. Timmons & Associates, February
      , 27, 1992.                ','.-.

       Letter from Schnabel Environmental Services, to Jim Leiper, Sanifill, April 8, .1992.
                                                                                   /
       Letter from Stephen Werner, Hatcher-Sayre, Inc. .to  Paul Robins, Qualla Road Landfill, December
       11, 1990.           ,  '                              '

       Letter from AM. Tope, Hydrogeologist, State Water Control Board, Commonwealth of Virginia, to
       Berry Wright, Department of Waste Management, Commonwealth of Virginia, May 15, 1987.

       Letter from Scott Bullock, Department of Environmental Quality, Commonwealth of Virginia, to.
       Gregory Cekander, Sanifill, February 2, 1994.

       Memorandum from Scott Bullock, Department of Environmental Quality, Commonwealth of Virginia,
       to Timothy Torrez, Qualla Road Landfill, January 12, 1994.           ".

       Memorandum from Charles Plott, Landfill Manager, Qualla  Road Landfill, to Robert Timmons,
       Department of Environmental Quality, Commonwealth of Virginia, April 28, 1993.

       Memorandum to the file, from Berry Wright, Department of Waste Management, Commonwealth of
       Virginia, August 25, 1987.

       Memorandum from Charles Plott, Landfill Manager, Qualla  Road Landfill, to Robert Timmons,
     .  Department of Environmental Quality, Commonwealth of Virginia, May 10, 1993.

       Memorandum from J.A. Adams to Berry Wright, Department of Waste Management, Commonwealth
       of Virginia, July 23, 1987.,

       Qualla Road Landfill Design Report, March 31, 1994.

       Request Analysis and Recommendation, Linwood Belcher, Matoaca Magisterial District, January 20,
       1987.  .            .                                          ,

       Sanifill, Groundwater Monitoring  Data,, for Robert Timmons, Department of Waste Management,
       Commonwealth of Virginia, November 11, 1993.

       Solid Waste Facility Permit, Permit Amendment Number 516, February 1, 1988.

       Solid Waste Management Permit,  Department of Waste Management, Commonwealth of Virginia,
       January 14, 1988.
                          *** January 5,1995 Draft Document ***

-------
 SCHUYLKILL DEBRIS LANDFILL
                                                             '   .    '          3-27

                                               Prince George County, Virginia
 Media Affected:
          Ground Water
 Overview of Site/Site History

        The Schuylkill Debris Landfill comprises approximately seven acres near the western edge of the
 Appomattox River in  Prince George  County.  The landfill received its permit to accept C&D wastes in
 November 1984 and closed in 1988.  It was owned and operated by the U.S. Army Quartermaster Center and
 Fort  Lee.  A few leachate seeps were discovered in 1992, but they led  to  no obvious  visual  signs of
 contamination.                .

 Facility Operations

•'.       The landfill is a permitted debris facility. An October 1989 questionnaire revealed that  the facility
 has .accepted wood, stumps, brick, concrete, and other inert construction and demolition debris material.

 Facility Design

        The source document provides no information on facility design.              '

 Site. Environment and Hydrogeology           .                                             .

        The source document provides no information on site environment or hydrogeology,
Summary
Damages
of   Environmental
-
TABLE 1. GROUND- WATER CONTAMINANTS
EXCEEDING FEDERAL DRINKING WATER
STANDARDS
Contaminant
beryllium
iron
lead
sulfate
TDS
Parameter
PH
Highest
Detected Level
. 
-------
 3-28                                  '       •

 Discussion

        Ground-water contamination has occurred at the landfill, but the source documents do not specifically
 state whether the landfill is the cause of the contamination. Because no information is readily available on
 site geology or facility design and location, it is not possible to further evaluate the cause of damages at the
 Schuylkill Debris Landfill. It is also unknown whether off-site contamination has been documented, because
 the location of the monitoring wells was not presented in the source document.

 Sources

        Laboratory Report, Schuylkill, Montgomery Laboratories, December 16, 1992.

        Memorandum from Thomas  L.  Kowalski, Environmental  Inspector, to  Department of Waste
        Management File, December 8, 1992.

        Memorandum from Jonathan P. Adams, Lieutenant, U.S. Army, to Richard Burton, Department of
        Environmental Quality, April 7, 1994.

.        Memorandum from William M.  Munson, Lieutenant Colonel, U.S. Army, to Linda Lightfoot,
        Department of Waste Management; October 11,  1989.

        Solid Waste Management Permit, Commonwealth of Virginia, Department of Health, December 11,
        1984.       .                                                                       •

        1st Quarter Groundwater Analysis, Environmental Laboratories, Inc., April 30, 1992.

        2nd Quarter Groundwater Analysis, Environmental Laboratories, Inc., July 23, 1992.
                           ••'* January 5,1995 Draft Document ***

-------
 JANESVILLE DEMOLITION WASTE LANDFILL
                                                                  '   3-29

                                                 Janesville, Wisconsin
 Media Affected:
Ground Water
 Overview of Site/Site History
                                   f
        The Janesville Demolition Landfill is a six-acre site located in Janesville, Wisconsin, just east of the
 Rock River.  This site was never licensed and began to accept demolition waste in 1981 until its closure  in
 1992.  The site was open to the residents of Janesville and Rock County.

 Facility Operations               ,                                            ...

        The landfill received demolition waste from 1981 to 1992.  A sign at  the site identified concrete,
 broken pavement, untreated/unpainted wood, and brush as acceptable, materials, but a wide variety of waste
 may have been accepted. An attendant inspected all incoming loads to the landfill.

 Facility Design

        After the site was closed, two feet of compacted clay was placed on the site to mitigate infiltration of
 surface water  and precipitation.  Ground-water monitoring  is conducted using one  upgradient and  four
 downgradient wells.  The source document does not mention any other engineering controls such as liners,
 leachate  collection systems, or run-on/run-off controls.
          i
 Site Environment and Hydrogeology        .

       The landfill is located in the drainage basin of the Rock River, which flows south.  The landfill lies
 in a large sand and gravel quarry, which is still partly active. Logs from monitoring well installation indicate
 that the soils are comprised mostly of sand and gravel, with some clay and rock fragments as well.  Samples
 from the bottom of the deepest well were predominantly silt.                .               ;

       The underlying bedrock is St. Peter Sandstone, which is underlain by other sandstone layers.  These
 sandstones make up the principal aquifer in this area and provide residents with  potable water. The ground-
 water flow is generally from the northeast to the southwest with a strong westward component  due to the'
 influence of the Rock River, which is about 1,200 feet west of the site. The depth to ground water in the wells
 varies  from 37  to  75  feet.    The  large
 component.of sand and gravel in the area
 suggests that ground water could be moving
 rapidly.
       The total  annual precipitation  is
about 32 inches.

Summary of Environmental Damages

       Ground-water samples  were taken
periodically over a two-year period at one
upgradient,  one  sidegradient,  and  two
downgradient wells. The source document is
unclear as to whether the wells are inside or
outside of the  property line, but  both
downgradient wells appear to be within the
property  line.    Several  parameters  were
significantly higher in the two downgradient

TABLE 1. GROUND-WATER CONTAMINANTS
EXCEEDING FEDERAL
DRINKING WATER STANDARDS
Contaminant
chloride .
manganese
sulfate
total dissolved
solids (TDS)
Highest
Detected
Level 0*g/l)
430,000
710
1,900,000
3,780,000
MCL
G»g/0
.--
-
..
..
SMCL
0*g/i)
250,000
50
250,000
500,000
•

                            *** January 5,1995 Draft Document ***

-------
3-30 •                                    -

                                        '    "   -   '           '                      •"
wells compared to the upgradient well. Constituents that were found in downgradient wells at levels higher
than their federal drinking water standard (primary or secondary MCL) are shown in Table 1.  According to
the source document, levels of sulfate, chloride, and manganese were above the Wisconsin Public Welfare
Standards. The high sulfate levels were attributed to gypsum, a common component of wallboard. Phenolic,
a common constituent of tree and vegetative decay products, was detected once in one of the downgradient
wells slightly above reporting limits.                                "

Discussion                                  .                        ,.              •

       Adverse on-site ground-water quality impacts from demolition waste disposal were documented at this
landfill.  Off-site'ground-water monitoring was not conducted.
Source
       Investigation of Groundwater Impacts at Demolition Waste Landfills,  Wisconsin Department of
       Natural Resources, June 1994.
                           *** January 5,1995 Draft Document ***

-------
                                                                                           3-31
 TERRA ENGINEERING
 DEMOLITION WASTE LANDFILL
                                     Dane County, Wisconsin
. Media Affected:
Ground Water
 Overview of Site/Site History                                '>.,-'

        The Terra Engineering Demolition Landfill is about 4.1 acres in size. It is located in a drained marshy
 area in Dane County near the city of Madison/Wisconsin.  This site was licensed in 1971 for demolition waste
 only, and one owner has operated the site since 1972.  The company expects to be able to fill at the present
 rate for at least 10 more years.

 Facility Operations

        Since 1972, the site has been filled only with waste materials  from the company's construction and
 demolition projects. The main fill materials nave been reinforced and unreinforced concrete, wood, masonry,
 brick, asphalt pavement, glass,-steel and metal pieces, and brush.  Some asphalt and scrap metal has been
 sorted out for the company to sell or reuse.
                     /                                                        *
 Facility Design               ~

        No information is presented in the source document about the design of the landfill.

 Site Environment and Hydrogeology      '---•,

        The landfill is in a drained marshy area bounded on the north  and east by drainage ditches. Surface
 water is routed around the fill on the southern end of the site. The land slopes towards the southeast..

        The glacial material underlying the site is undifferentiated glacial deposits consisting  of ground
 moraine.  The unconsolidated material below the surface  includes layers of brown sand, silt, and clay, along
 with some sand seams and sand and gravel lenses. About 100 feet below these unconsolidated deposits lies
 Trempealeau and  Franconia  sandstone bedrock, which is underlain  by Cambrian  sandstone  down to
 Precambrian crystalline bedrock. The Cambrian
 sandstone acts as the principal aquifer for most
 Dane County residents.
        Ground water is close to the surface at
the site; the measured depth to ground water is
between 2.5 and 10 feet. Regional movement of
ground water deep in the sandstone aquifer is
southwest towards the Yahara River, which is
three miles away.  Locally,  there is a definite
eastward gradient.  The ground-water  flow is
very complex due to the heterogeneous nature
of the glacial deposits.

Summary of Environmental Damages

        Five  ground-water  monitoring wells
were installed  at the site, one  within  the
demolition debris and the others sidegradient to
the fill.  All wells were sampled periodically for
two  years.  One of the sidegradient wells had
TABLE 1. GROUND-WATER CONTAMINANTS
EXCEEDING FEDERAL DRINKING WATER
'' STANDARDS
,-
Contaminant
chloride
iron
manganese .
sulfate
TDS
Highest
Detected
Level
0*8/0
380,000
6,400
1,400
600,000
3,340,000
MCL
0*8/1)
—
~
—

~
SMCL
(M8/I)
250,000
300
50
250,000
500,000

-
                            *** January 5,1995 Draft Document .***

-------
3-32

elevated levels of manganese, sulfate, and total dissolved solids (TDS); the other three sidegradient wells were
generally unaffected.  The well installed within the demolition debris had elevated levels of many inorganics;
five were detected at levels above federal drinking waterstandards (primary or secondary MCLs). These are
shown in Table  1.  -                                     '

Discussion                                                 '

       Adverse on-site ground-water quality impacts from demolition waste disposal were documented at this
landfill.  Off-site ground-water monitoring was not conducted.
Source
       Investigation of Groundwater Impacts at Demolition Waste Landfills; Wisconsin Department of
       Natural Resources; June 1994.
                           *** January 5,1995 Draft Document ***

-------
 CHAPTER 4.                                                 FINDINGS AND CONCLUSIONS
        This chapter discusses the findings and conclusions of this study.  It begins by summarizing the
-ground-water, surface water, and ecological damages observed at the 11 case study sites, and discussing the
 factors that might have contributed to those damages.  The implications of these findings are then
 discussed.     .   •

 SUMMARY OF DAMAGES AND CONTRIBUTING FACTORS

        Exhibit 4-1 summarizes information pertaining to each damage case. Included on the exhibit are
 each site's operating dates, design and operating characteristics, environmental setting,  nature of the
 contamination, and any corrective actions that were recommended and/or taken.

        •       Operating dates are given when available.

        •       Information on design and operations was incomplete in most of the source documents.

        •       Many of the source documents were quite detailed with respect to environmental setting
                characteristics such as topography and hydrogeology, but they did not address the
                relationship between environmental setting and observed damages.  Exhibit 4-1  presents
                the site characteristics that are potentially relevant.                   .

        •      The environmental contamination column identifies the media  contaminated, whether the
               contamination was on site or off site, and the constituents involved.  If the source
               document was unclear as to whether the contamination was on or off site, it was assumed
               to be  on  site.  The exhibit focuses on contamination above applicable state or federal
               standards or criteria;  if contamination did not exceed standards or criteria, increases above
               background levels are reported. Terrestrial ecological damages are not included in this
               exhibit because none were reported at any of the sites.
                                                          I.

        •      Corrective actions listed in the last column include actions that have been recommended
               or implemented at the site.

The results are discussed  below.                      ,

Environmental Contamination

       This section summarizes the nature of the  ground-water and surface water contamination found at
the sites. Again, no terrestrial ecological damages were reported.

      , Ground  Water

       All 11 sites reported ground-water contamination within the property boundary; none reported
ground-water contamination off site.  This does not mean that there was no off-site contamination.
Rather, in most cases,  ground-water monitoring was not performed beyond the site boundary.

       Although most of the sites were monitored for a wide range of organic and inorganic constituents,
virtually all of the contamination was  associated with inorganics.  A small number of sites reported slight


                              *** January 5,1995 Draft Document •*•

-------
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4-6                                       ,                                 ,     •

contamination with phenolics, total organic carbon, and "unidentified semivolatile organics."  One site had
previously found low levels of carbon tetrachloride in a residential well, but" this was not confirmed during
later investigations.

        Many inorganic constituents were elevated in ground-water monitoring wells.  Constituents that
exceeded state ground-water protection standards or federal drinking water standards most frequently
were:1                                                •

        •       Manganese (9 sites)
        •       Iron (8 sites)                                          -       •     '
        •       Total dissolved solids (TDS) (6 sites)
       . •       Lead (5 sites) ,      •
        •       Magnesium (4 sites)  .                                                               .
        •       Sodium (4 sites)
        •  .     pH (acidic) (3 sites)          .
               Sulfate (3 sites)  '
                                                                    /
Two of these constituents - iron and manganese - were found to exceed applicable standards by a factor
of 100 or  more in at least one sample at many landfills (i.e., at 5 of the 11 sites for iron, and at 4 of the  11
sites for manganese):

        •       At nine sites, the highest detected levels of manganese were about 10 to 900 times higher
               than EPA's secondary drinking water standard (SMCL).

        •       The highest detected iron levels at eight sites were about 20 to 400 times higher than
               EPA's SMCL.                                                                •  .

It is noteworthy that for both constituents, the standard that was exceeded is a secondary, rather than
primary, MCL.  Secondary MCLs are set to protect  the water supply for aesthetic (e.g., taste) rather than
health-based reasons.                           .                                   .
                                                    f~           ^

       The only other constituent that exceeded  applicable standards^ by a factor of 100 or more in  at
least one sample was aluminum (secondary MCL). Constituents that exceeded applicable standards by a   ,
factor of 10 or more were sodium (New York State ground-water standard) and cadmium (primary MCL),
each at one site. It is also notable that lead  exceeded the federal drinking  water action level2 at five sites,
by two to  six times.

       Surface Water and Sediments
    !In reporting exceedances of state or federal standards, an attempt was made to exclude constituents
whose upgradient or background concentrations were as high as those in downgradient wells.

'    2    The action level for lead (15 /ug/1) is the concentration of lead in water measured at the tap that
    .    determines, in some cases, whether a water system •must install corrosion control, treatment,
        monitor source water, replace lead service lines, and undertake a public education  program.

                               •*• January 5, 1995 Draft Document ***.

-------
                                                                                                '4-7

         Six sites had surface water contamination; three of these sites also had some contamination of
 sediments.  At two sites, the surface water and sediment contamination was off site as well as on site. One
 off-site location was a pond on an adjacent property, and the other was a river flowing adjacent to the site.

         As with ground water, most of the contamination was associated with inorganic constituents.
 Constituents that exceeded state surface water standards or EPA's Ambient Water Quality Criteria
 (AWQC) for the protection of freshwater aquatic life most frequently were as follows:3

         •       Iron levels at four sites were about 10 to 650 times higher than applicable, standards or
                criteria.

         •       Zinc levels at three sites were 1.5 to 9 times  higher than applicable standards or criteria.

       •  •       Lead levels at two sites were about 15 and 300 times higher than applicable standards or
                criteria.

         •       Copper levels at two sites were 5 and 15 times  higher than applicable standards or  criteria:

         •  .    Surface water was too acidic at two sites.

 One site, which accepted-tires in addition  to C&D waste, also reported some unidentified semivolatile
 organics in surface water samples.  •
                                                                     '                          .  i
        Of the three sites reporting contamination of sediments, two had elevated levels of polynuclear
 aromatic hydrocarbons (PNAs); one  also had elevated levels of alkanes. The third site had elevated levels
 of di-n-octyl-phthalate, as well as exceedances of New York State sediment criteria for lead, mercury, zinc,
 arsenic, and manganese.

 Site Design, Operating, and  Location Factors

        As mentioned above, the source documents rarely examined the possible link between
 environmental damages observed at a site  and the design, operating, or location  attributes of the site.  This
 section summarizes the factors that might  have contributed to the damages at the 11 sites.
                        '„                         /
        First, although the damage case sites were restricted to  landfills receiving predominantly C&D
 debris, seven landfills contained other types of wastes that had been disposed of legally or illegally.  These
wastes include tires (three sites), household hazardous wastes, medical wastes, asbestos, roofing compound,
and other materials.  (Although roofing compound and asbestos are  components of C&D wastes, due  to
 their potentially hazardous nature, they are often restricted  from C&D landfills.) It is possible  that  these
other wastes contributed  to the contamination observed at the sites.
    3As above, these exceedances are based on the maximum detected level at each site, and attempt to
exclude constituents whose background levels were also above standards.

                              *** January 5, 1995 Draft Document ***

-------
  4-8   -                     .                                                            •

         Second, environmental controls were typically absent.4 Two landfills were equipped with partial
  bottom liners and leachate collection systems (LCSs), while, the remaining nine landfills apparently had
  none.  Run-on and/or run-off controls were mentioned in the source documents for only three sites, and at
  least two of them were incomplete or inadequate:  Six sites apparently had some type of final cover, but ..
  only two had more than a thin soil cover.  For four sites, no environmental controls were mentioned in
  the source documents.  '                                                                  -
                             i                                     ^
         Many of the landfills were characterized by environmental settings that could facilitate the release
.  and transport of contaminants, although there is no way of knowing whether these factors actually
  contributed to the damages. Four sites were characterized by shallow ground water, and four by complex
  ground-water flow conditions resulting from heterogeneity in the subsoils or folds or fractures in the
  bedrock. Two landfills were sited above highly permeable soils such as sand and gravel, facilitating the
  transport of leachate to the underlying aquifers.  Six landfills had ponds, streams, or wetlands either on
  site or within close proximity; one site was located in a 100-year floodplain.
                         "•                                 s
  Corrective Actions                      ,
                                             i
         Corrective actions at the 11 sites included closing the sites, capping the sites, and/or requiring
  additional groundrwater monitoring as follows:             .

         •      Four sites were closed;

         »      Two of those sites were capped; and

         •      . Additional ground-water monitoring was required at seven of the sites.

  Information on corrective actions at the  two Wisconsin sites was unavailable.

  CONCLUSIONS                 ,

         This report demonstrates that specific C&D waste landfills can lead to .the contamination  of
. ground-water and surface water resources, particularly with metals and other inorganics. Although this
 contamination may potentially pose a risk to human health and the environment, it is more likely  to affect
 the aesthetic quality of drinking water. Among the 11 damage cases reported here, manganese and iron
 appear to be the worst offenders in terms of the frequency and severity with which ground-water standards
 are exceeded   The significance of these exceedances in terms of human health effects is questionable,
 however, as the standards that were exceeded are based on protecting the aesthetic quality of drinking
 water rather than human health. Iron and other metals, such as zinc, lead, and copper.have exceeded
 surface .water criteria established for the  protection of aquatic life. However, no fish kills or other
 observable  impacts on aquatic life are reported in the documentation reviewed.

         Although this study demonstrates that individual C&D debris landfills can lead to ground-water
 and surface water contamination, there is no way to determine the degree to which these sites are
f representative of the universe of C&D debris landfills. There are believed to be approximately 1,800 C&D
 debris landfills operating in the U.S. today, and this report captures less than one percent of those sites.
 •   4This discussion assumes that if environmental controls were not mentioned in the source documents,
 they were not present.  Therefore, it might underestimate the use of these controls at the case study sites.

                                   January 5,1995 Draft Document

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                                                                                              4-9
        Overall, the limited number of damage cases and the limited amount of data on C&D facilities in
general  make it difficult to determine the degree to which C&D facilities threaten human health and the
environment. Because individual damage cases appear to he limited in occurrence, the Agency believes ,
that C&D facilities do not currently pose significant risks.   ,
                              *** January 5,1995 Draft Document ***

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PPENDIX A.
                                                                    CONTACTS
List of Contacts Who Provided Information on the Potential Existence of
           Damage Cases in Their Region, State, or County
1 State
Contacts and Information Highlights
Region I - Juan Perez (617) 223-5532 . -
Maine
Massachusetts
New
Hampshire
iRhode Island
Vermont
Carolyn Berger (207) .287-2651 (Augusta Region)
Maine does not compile info on C&D damages & she does not
fcnow of any
Most C&D landfills in Maine are not exclusively for C&D
Jim Roberts (617) 292-5983, Brian Holdridge (617) 292-5578, Department of
Environmental Protection
Only have 3 active dedicated C&D Lfs, 1 was MSWLF previously.
Only one' facility that might be useful and it is double-lined.
Sent NWMOA report (Lambert and DomizJo 1993)
Carl Woodbury, Department of Environmental Services (603) 271-2925
Most C&D landfills are adjacent to MSW landfills, so can't
determine that C&D is source of problems.
One C&D landfill (Salem; LL&S) had underground fire for 1'A
years in early/mid '80s; ground-water contamination resulted from
pumping water through to extinguish fire.
Gene Ashton (401) 277-2797, Division of Waste Management, Department
of Environmental Management
One C&D landfill in RI: Hometown Properties LF.
GW and SW are monitored extensively, but no evidence of
contamination.
Jim Surwillo (802) 241-3444, Department of Environmental Conservation
Two exclusively C&D landfills in Vermont.
Burgess Bros. LF has existed for 75 years, always as a C&D landfill,
but it is possible that other wastes were dumped there in the early
years.
Hartford C&D LF is downgradient from a MSW landfill.
1 Region II - Jenine Tankoos (212) 264-1369 .
New Jersey
Nelson Howsman, New Jersey Department of Environmental Protection
The majority of C&D landfills are closed.
C&D waste was previously sent to municipal landfills.
Some remaining C&D facilities but there are no records of
environmental damages resulting from these facilities.
C&D Landfills for Which Written
Materials Were Reviewed



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•A-2
State
New York
Contacts and Information Highlights
Tom Lynch, Dave Wilber, New York Department of Environmental
Conservation
C&D facilities had a one-year exemption that allowed the facilities
to accept any type of waste.
Most sites closed at the end of the exemption period.
Since 1993, C&D landfills are required to obtain a permit and have
liners. . .
State performed a preliminary investigation of the 8 worst sites
following the expiration' of the exemption. No hazardous wastes
were found at the sites although "constituents of concern" were
detected.
Region III - Charles Howard {215} 597-6197
Delaware
Maryland
•.
Pennsylvania
Virginia
West Virginia
Dennis Murphy (302) 739^506
Only have one C&D landfill in Delaware.
No "significant" effects or hazardous constituents, but some minor
effects. . . ' .
-. Recently required to have clay or HDPE liner.
Edward Dexter, Maryland Department of the Environment {410} 631-3318
Based on phone conversations with MD personnel, it was
- determined that non-C&D sources might be contributing to the
damage at possible damage case sites, or that insufficient site history
was available to exclude that possibility.
Dan Nguyen (717) 787-7381, Pennsylvania Department of Environmental
Resources
Suggested we contact the state regional offices.
Paul Farrell, Jr., Virginia Department of Environmental Quality (804) 527-
5111 ' .' ' '
No evidence of CESQG waste.
Phase I/Phase II system: if monitoring triggers, then do more
extensive monitoring.
Ground-water contamination exists. v
Charlie Capet (304) 558-6350, OSW, Div. of Env. Protection
Two C&D landfills operating and one proposed.
No monitoring and no indication of contamination.
C&D Landfills for Which Written
Materials Were Reviewed
Fair Street ' -
Garofalo
Moran '
Route 52
LaMunyan C&D Site
Ferro C&D Site
Kenilworth Lane Site
Suffolk Materials Mining
' '


J

Cox's Darbytown Road CDD LF
Crippen Stump Dump
Furnace Road (Lorton) Debris LF
Qualla Road Demolition LF
Schuylkill (Fort Lee) Debris LF
Campostella Landfill '
Elbow Farms (Thrasher)
Ingles Mountain Debris LF
Rainwater Debris LF
Shoosmith Debris LF
Allegany, Ballistics Laboratory
                             *** January 5,1995 Draft Document ***

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                                                                                                                      Ao
     State
                  Contacts and Information Highlights
 C&D Landfills for Which Written
     Materials Were Reviewed
 Region IV - Patricia Zweig (404) 347-2091
 Florida
 Chris McGuire (904) 921-9627; Florida Department of Environmental
 Regulation
         FL currently has a legal exemption from regulation for C&D debris.
         State is trying to overturn legal exemption.
 Mike Fitzsimmons (904) 448-4300, Florida Department of Environmental
 Regulation - Jacksonville Office
 Pegeen Hanrahan (904) 955-2442, Alachua County Environmental Protection
 Department
         Sent report and list of contacts.
 Paul Lasa, Dade County Environmental Protection Department (305) 372-
 6832
         Several C&D facilities are contaminated with ammonia/nitrogen.
         No hazardous constituents and no evidence of CESQG wastes.
         Dade County requires liners, caps, and ground-water monitoring. .
Plymouth Ave. LF
Kentucky
George Gilbert (502) 564-6716, Solid'Waste Permitting Branch, Div. of
Waste Management, Kentucky Dept. of Env. Protection
        Two operating C&D landfills, and one closed (Kramer's Lane).
        No monitoring nor any indication of contamination.
Mississippi
Conrad Stacks (601) 961-5339, Nonhazardous Waste Branch, Ground
Protection Div., Bureau of Pollution Control, Mississippi Dept. of Env.
Quality.
         Mississippi identifies two classes of landfills; C&D landfills fall into
     .    Class 2.
         Hoover Rubbish Site is a possible damage case, but GW monitoring
         has just been set up and no results are available yet.
North
Carolina
Bill Sessonis (919) 733-0692, Solid Waste Section, NC Dept. of Env., Health
and Natural Resources
        New C&D landfills are being built in compliance with new
        regulations.
        Old C&D landfills have no monitoring and no indication of
        contamination.
South
Carolina
Melissa King (803) 734-5200, Bureau of Solid & Hazardous Waste
Management, SC Dept. of Health and Environmental Control
        No monitoring is required at C&D sites.
        GW monitoring is set up at Barnwell Resources, but there are no
        results yet, and waste type prior to 1980 is unknown.
Tennessee
Frank Victory (615) 532-0780, Chief, Div. of Solid Waste Management, TN
Dept. of Environment and Conservation
        Mercury has been found at OA Green LF, but contamination is
        shown to be from previous waste.
      ,  No other C&D sites have monitoring.
                                     *** January 5,1995 Draft Document ***

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A-4
      State
                   Contacts and Information Highlights
  C&D Landfills for Which Written
      Materials Were Reviewed
  Region V - Susan Mooney (312) 886-3585
  liiinois
Mike Nechvatal (217) 782-6761, Illinois Environmental Protection Agency
         C&D wastes are managed in municipal landfills in Illinois.
•  .      Cannot place CESQG wastes in industrial landfills.
         Does not expect that any data exist in Illinois.
Johns-Manville
  Minnesota
Lanny Piezack, Minnesota Pollution Control Agency
         C&D waste facilities cannot accept CESQG waste in Minnesota.
         MN has demolition only landfills which cannot accept new
         construction wastes because this waste may contain some hazardous
         wastes/constituents.
         All new construction waste goes to sanitary landfills.
         No'demolition landfills in  MN have any contamination associated
         with them.
         All industrial D landfills are dedicated to a specific company and
      ,  waste type and are required to have secondary containment features
      -•'  based on the results of leachate tests.
         Began lining industrial D landfills in 1990.
         Have  documentation of contamination from old sites.
         No new sites (industrial or demolition) have any contamination due
         to the stringent requirements.
  Michigan
Pat Brennan (517) 780-7935, District Geologist, Jackson Office, Michigan
Department of Natural Resources
         C&D landfills are permitted with only 4 feet of clearance from
         ground water regardless of soil type.
         There are 2 potential'damage cases in his region.
        .Price Landfill (now called Phillip McGill Road Landfill) received
         Type II (non-C&D) waste and is next to a closed Type II landfill
         (upgradient, but possible halo upgradient).
         Liberty Landfill was previously an asphalt plant.  Metal
         contamination above background but not above  MCLs.
  Ohio
Don Slivka (614) 644-2771, Ohio EPA
        State has not historically regulated C&D facilities.
        C&D facilities have accepted wastes that they "should not nave,"
        which has resulted in contamination.
        Some data exists on uncontrolled C&D sites that have received
        several types of wastes.
North Sanitary LF
                                        *** January 5,1995 Draft Document ***


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                                                                                                                      A-5
    State
                  Contacts and Information Highlights
 C&D Landfills for Which Written
     Materials Were Reviewed
Wisconsin
Gene Mitchell, Department of Natural Resources (608) 267-7574
         State mixes C&D waste with industrial waste.
         Does not believe any data are available in the state.
Jack Connelly, Department of Natural Resources (608) 267-7574
         Sent report mentioned in Hanrahan's report (Svavarsson & Fauble
         (WDNR), Investigations of Groundwater Impacts at C&D Landfills).
         1988 regulation-exempts C&D landfills < 50,000 cubic yards from
         extensive requirements because Wisconsin has found that size and
         location are important factors affecting whether or not there are
         damages.
         Have ground-water monitoring data for 30-40 sites since 1988 with
         a good computer system to produce reports on sites.
Janesville Demolition Waste LF
Schmalz Dump
Terra Eng. Demolition Waste LF
Mid-State Disposal
Region VI - Andrew Tayrien (214) 665-8546
Arkansas
Mike Hood, Technical Manager, Solid Waste Division (501) 570-2858
        Class IV (C&D) landfills do not have ground-water monitoring and
        no damages have been documented.  .
West Memphis Dump (South 8th
Street LF)
New Mexico
Gerald Silva (505) 827-2775, Solid Waste Bureau Chief, Env. Protection Div.,
NM Environmental Dept.
        Two C&D landfills in NM.
        Currently there is no monitoring and no indication of
        contamination.
Oklahoma
Chris Varga (405) 745-7114, Waste Management Division, OK Dept. of
Environmental Quality
        Approximately ten C&D landfills in the state.
        Some of the landfills are monitored for pH, COD, and conductivity,
        but no. contamination has been found.
Texas
Anne Dobbs (512) 463-8410, Texas Water Commission
        Some facilities have had hazardous constituents contaminating
        ground water or surface water.
Region VII - Chet McLaughlin (913) 551-7666
        Ground-water monitoring is not routinely conducted in states.
        States delegate permitting to local governments, which often results in not much
        monitoring or oversight because no funding is provided along with the delegation.
        Many "C&D" landfills accept non-C&D wastes.
       . One damage case occurred in Kansas City when a fire broke out at an alleged C&D
        landfill.  Improper fire fighting flushed most of the contents of the landfill into the
        river resulting in a fish kill  "The landfill had been around for 40 years or so, and had
        accepted a lot of non-C&D waste, including tires.   .
        Fires are the biggest problem associated with their C&D landfills.
        It is possible that there are  damage cases associated with C&D-only facilities.
                                     *** January 5,1995 Draft Document ***

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   A-6
         State
                  Contacts and Information Highlights
  C&D Landfills for Which Written
     Materials Were Reviewed
     Region VlII - Bob Near (303) 293-1497
     Montana
Pat Crowley (406) 444-1430, Montana Department of Health &
Environmental Sciences
         In Montana C&D debris is regulated in the same "waste group" as
         household wastes and is sent to municipal landfills.
         No existing licensed commercial/industrial Subtitle D facilities.
         Industrial waste goes to municipal landfills.
     North Dakota
Kevin Solie (701) 221-5166, Div. of Waste Management, Dept. of Health &
Consolidated Laboratories
         ND has inert landfills that accept C&D waste.                  '
         No monitoring has been conducted.
     South Dakota
Dave Templeton {60S) 773-4222, Office of Waste Management, Department
of Environment & Natural Resources
        Two large (50-60,000 tons/yr) exclusively C&D landfills and several
        rubble sites that accept both C&D and other wastes.
        No monitoring is conducted, and there is no evidence of.
        contamination.
     Wyoming
Carl Anderson (307) 777-7752, Solid Waste Program, Dept. of Env. Quality
        One C&D landfill in Wyoming adjacent to closed MSW landfill.
        There is no monitoring at.the C&D portion of the site.
     Region IX - Jeannie Page - (415) 744-2073
    .Region X - Stephen Sharp (206) 553-6517
     Washington
James Knudson (206) 407-6110, Washington Department of Ecology
        Have separate regulations for "inert" (concrete, marble, masonry)
        and "demolition" wastes (everything but wallboard).
        Weak oversight  results in some wallboard getting into demolition
        landfills.
        No ground-water monitoring required.
John Keeling (Northwest  Region) (206) 649-7052
•   •    No damages.
Wyn Hoffman (Southwest Region) (206) 607-6393
        No verified damages from C&D landfills.
        Seattle's Midway Landfill (Superfund site; actually in the Northwest
        Region) had accepted MSW in addition to C&D waste.
Peter Monk (Central Region) (509) 454-7873
        Knows of no damages from the four C&D landfills in this region.
Doug Peters (Eastern Region) (509) 456-2995
        Do not accept construction wastes; these  are sent to recycling
        centers.
        Little information on environmental impacts; possibly some
        problems in Spokane and Clark Counties but no documented
        information.
Tulalip LF
                                         ***
401 M Street, SW
Washington, DC 20460

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