PB97-964403
EPA/541/R-97/193
January 1998
EPA Superfund
Record of Decision:
F E Warren Air Force Base, OU 8
Cheyenne, WY
11/21/1997
-------
RECORD OF DECISION
INTERIM ACTION
OPERABLE UNIT 8: LANDFILL 5A
F. E. WARREN AIR FORCE BASE, WYOMING
OCTOBER 3, 1996
U. S. AIR FORCE
FINAL DOCUMENT
-------
TABLE OF CONTENTS
PAGE NO.
DECLARATION FOR THE RECORD OF DECISION
1.0 SITE NAME AND LOCATION 1
2.0 STATEMENT OF BASIS AND PURPOSE 1
3.0 ASSESSMENT OF THE SITE 1
4.0 DESCRIPTION OF THE SELECTED REMEDY 1
5.0 STATUTORY DETERMINATIONS 2
6.0 SIGNATURE OF AGENCY ACCEPTANCE (EPA) 3
SIGNATURE OF AGENCY ACCEPTANCE (WDEQ) 4
SIGNATURE OF AGENCY ACCEPTANCE (USAF) 5
DECISION SUMMARY FOR THE RECORD OF DECISION
1.0 SITE NAME, LOCATION AND DESCRIPTION 1
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 5
4.0 SCOPE AND ROLE OF OPERABLE UNIT 6
5.0 SITE CHARACTERISTICS 6
6.0 SUMMARY OF SITE RISKS 7
7.0 DESCRIPTION OF ALTERNATIVES 9
8.0 MONITORING WELL CONSTRUCTION 10
9.0 SUMMARY OF COMPARATIVE ANALYSIS 12
10.0 DESCRIPTION OF SELECTED REMEDY 14
11.0 STATUTORY DETERMINATIONS 15
12.0 EXPLANATION OF SIGNIFICANT CHANGES 16
RESPONSIVENESS SUMMARY
INTRODUCTION 1
A. OVERVIEW 1
B. BACKGROUND ON COMMUNITY INVOLVEMENT 1
C. SUMMARY OF COMMENTS RECEIVED 1
D. STATE CONCERNS 2
ATTACHMENT A, COMMUNITY RELATIONS ACTIVITIES
APPENDIX A, FEDERAL AND WYOMING STATE ARARs
APPENDIX B, TEMPORARILY WAIVED ARARs
FIGURES
Figure 1 F. E. Warren AFB 2
Figure 2 Location of Landfill 5 A 5
FNLROD4.DOC : 03 October 1996
-------
DECLARATION FOR THE RECORD OF DECISION
INTERIM ACTION
OPERABLE UNIT 8 : LANDFILL 5A
1.0 SITE NAME AND LOCATION
F. E. Warren Air Force Base
Cheyenne, Wyoming
2.0 STATEMENT OF BASIS AND PURPOSE
The selected interim action (remedy) for Operable Unit 8 (OU8), Landfill 5A (LF5A), at F. E.
Warren Air Force Base (Base), in Cheyenne, Wyoming includes CAPPING and an active gas venting
system. The selected action, the fifth at the Base, was chosen in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA), and the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). The selected remedy addresses only source control at
LF5A, a portion of OU8. This decision is based on the Administrative Record for the site. The United
States Environmental Protection Agency (EPA) and State of Wyoming Department of Environmental
Quality (WDEQ), as oversight agencies, concur with the selected remedy. The United States Air
Force is the lead agency for the site.
3.0 ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the remedy selected in this Record of Decision (ROD), may present a current or potential
threat to public health, welfare, or the environment.
4.0 DESCRIPTION OF THE SELECTED REMEDY
The selected remedy for LF5A is a source control action that includes capping, an active gas
venting system, and if needed, a gas control system for VOCs. OU8 is one often operable units to be
investigated under terms of the Federal Facility Agreement (FFA). The others are: OU1 - Spill Sites
1 through 7; OU2 - Facility Ground Water (except at OUs 3, 6, 7 and 8); OU3 - Landfills 3 and 6;
OU4 - Acid Dry Wells; OU 5 - Fire Protection Training Area 2; OU 6 - Open Burning/Open
Detonation Area; OU7 - Firing Ranges; OU9- Landfills 2 and 4; and OU10- Landfill 7 and Fire
Protection Training Area 1. The ground water contamination associated with OUs 3, 6, 7, and 8 will
be investigated and remediated as part of those OUs, separate from OU2. All of the investigations are
being conducted in accordance with the FFA.
9
The function of the interim action is to control the LF5A site as a source of ground-water
contamination by reducing infiltration and the downward movement of contaminants to the ground
water, and to reduce the risks associated with exposure to contaminated materials. While the remedy
FNLROD4.DOC : 03 October 1996
-------
addresses one of the principal threats at the site, the final remedial alternative will address remediation
of the down-gradient contaminant plume.
The major components of the selected remedy include:
Capping Landfill 5 A in accordance with relevant and appropriate Resource Conservation
and Recovery Act Subtitle D landfill closure requirements;
Installing an active venting system to control methane production and a control system if
required for VOCs;
Installing erosion and surface water controls;
Conducting environmental monitoring to ensure the effectiveness of the interim action.
5.0 STATUTORY DETERMINATIONS
The United States Air Force (USAF) has determined, with the concurrence of the
Environmental Protection Agency, and the State of Wyoming, that this interim action is protective of
human health and the environment, complies with Federal and State applicable or relevant and
appropriate requirements directly associated with this action, satisfies the requirements for a waiver of
any standards that won't be met, and is cost-effective. This action utilizes permanent solutions and
alternative treatment technologies to the maximum extent practicable for this site. However, because
treatment of the principal threats of the site was not found to be practicable, this remedy does not
satisfy the statutory preference for treatment as a principal element of the remedy. The size of the
landfill and the fact that there are no apparent on-site hot spots that represent the major sources of
contamination preclude a remedy in which contaminants could be excavated and treated effectively.
Because this action does not constitute the final remedy for LF5A, the statutory preference for
remedies that employ treatment that reduces toxicity, mobility, or volume as a principal element will be
addressed at the time of the final response action. Subsequent actions are planned to address fully the
principal threats posed by LF5A.
CERCLA Section 121(c), 42 U.S.C. Section 9621(c), requires five-year reviews in the event
that hazardous substances, pollutants or contaminants remain on site. The USAF will conduct reviews
every five years after issuance of this ROD.
FNLROD4.DOC : 03 October 1996
-------
6.0 SIGNATURE OF AGENCY ACCEPTANCE OF REMEDY (EPA)
The undersigned representative concurs with this Record of Decision for Interim Action, Operable
Unit 8: Landfill 5A, at F. E. Warren AFB, Wyoming.
JACK W. MCGRAW DATE
ACTING REGIONAL ADMINISTRATOR
U. S. ENVIRONMENTAL PROTECTION AGENCY
FNLROD4.DOC : 03 October 1996
-------
6.0 SIGNATURE OF AGENCY ACCEPTANCE OF REMEDY (WDEQ)
(Intentionally left blank)
-------
6.0 SIGNATURE OF AGENCY ACCEPTANCE OF REMEDY (USAF)
The undersigned representative concurs with this Record of Decision for Interim Action, Operable
Unit 8: Landfill 5A, at F. E. Warren AFB, Wyoming.
PATRICK P. CARUANA, LT. GEN., USAF
VICE COMMANDER, AIR FORCE SPACE COMMAND
PETERSON AFB, CO
DATE
FNLROD4.DOC : 03 October 1996
-------
DECISION SUMMARY FOR THE RECORD OF DECISION
INTERIM ACTION
OPERABLE UNIT 8 : LANDFILL 5A
1.0 SITE NAME, LOCATION, AND DESCRIPTION
F. E. Warren Air Force Base (Base), occupies approximately 5,866 acres immediately adjacent
to the west side of the City of Cheyenne, Wyoming (Figure 1).
The Base was placed on the National Priorities List on February 21, 1990. Historically, the
Base has served a number of military functions, including; cavalry outpost, quartermaster depot and
intercontinental ballistic missile operations base. Operations began at the U. S. Army outpost named
Fort D. A. Russell in 1867. The name was changed to Fort F. E. Warren in 1930. The Base was a
major training facility during and after World War H Fort F. E. Warren was transferred to the newly
formed U. S. Air Force in 1947 and was subsequently named F. E. Warren Air Force Base. The Base
underwent extensive renovation after World War n. The majority of the Army training facilities were
torn down and not replaced. Construction since that time has centered on facilities for Air Force
operations. Beginning in 1958, F. E. Warren Air Force Base became a Strategic Air Command
(SAC) base. Since then, F. E. Warren Air Force Base has served as an operations center for, first, the
Atlas Intercontinental Ballistic Missile (ICBM), followed by the Minuteman I and En and finally, the
Peacekeeper (MX) ICBMs. The Base was part of Air Combat Command (ACC) from 1992 to 1993,
and in July 1993, became part of Space Command.
F. E. Warren Air Force Base is bordered by agricultural land and rural or suburban residential
areas. The Base contains 831 residential housing units and several unaccompanied personnel housing
units (barracks), along with the services required by residents. The nearest residences to Landfill 5A
(LF5A), are off- Base, approximately 750 feet to the south.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
LF5A is an area of about 15 acres located directly south of the Weapons Storage Area (WSA),
north of Military Road, and west of Cheyenne Road as shown on figure 2. The estimated volume of
fill at landfill 5 is 16,200,000 cubic feet, but the exact depth and thickness of landfill contents, and
whether the other landfill units were included as part of this estimated volume are unknown. The
landfill has a thin soil and grass cover. Depth to the water table in the LF5 area ranges from 8 to 37
feet below land surface. The 1985 records search indicated that landfill 5 operated from 1960 until
1970, and consisted of three burn pits and a series of trenches. The operation was a burn, trench-
and-fill, and cover operation. Refuse from the Base shops and housing areas was transported
daily to the landfill. The refuse was deposited in one of the pits and burned for volume reduction;
the residue was removed and placed in a trench, and covered with soil.
FNLROD4.DOC : 03 October 1996
-------
104-53'
104-52'
104°51'
41-ir -
41MO* -
41'W -
RE. WARREN
AIR FORCE BASE
EXPLANATION
LANDFILL, NUMBER,
AND SUBUNITS
BOUNDARY OF F.E. WARREN
AIR FORCE BASE
41-08' -
2.500
I
5.000 FEET
I
I
I
I
500 1.000 1.500 METERS
Figure 1.-Location of landfill 5, operable unit 8, F.E. Warren Air Force Base, Wyoming.
-------
£578.000
104'52'50"
£582.000
Ml 70.000-1
800
1 _ I _ I
200
1,600
2.400 FEET
600
800 METERS
14
EXPLANATION
APPROXIMATE LANDFILL BOUNDARY
F.E. WARREN AIR FORCE BASE BOUNDARY
UNDERGROUND UTILITY LINES
Communications
Electrical distribution
Natural gas
Str««t lighting
Water distribution
MONITOR WELL AND NUMBER
Rgure 2.Operable unit 8 area, F.E. Warren Air Force Base, Wyoming
ifS-uBOwc uc
-------
E579.000
104'52'30"
E581.000
N172.000--
7>
5
30
3
a
i
csi
3
400'
100
800'
1,200 FEET
200
300 METERS
EXPLANATION
APPROXIMATE LANDFILL BOUNDARY
- F.E. WARREN AIR FORCE BASE BOUNDARY
19MO
4.4 HP-14
DESTROYED TEST WELL AND ASSOCIATED TCE
CONCENTRATIONS IN MICROGRAMS PER
LITER
MONITOR WELL AND ASSOCIATED TCE
CONCENTRATIONS IN MICROGRAMS PER
LITER
i
TCE CROUNDWATER PLUME
Figure 3 Landfill 5a TCE Groundwater Plume
F.E. Warren Air Force Base, Wyorrvr.g
-------
Aerial photograph interpretations indicated that landfill 5 A may have operated from 1959
to 1961, that operations may have been switched from landfill 5 A to landfill 5B about 1961, that
operations primarily were at landfill 5B between 1961 and 1966, that in 1966 operations
decreased at landfill 5B and increased at landfill 5A, that in 1970 operations continued at landfill
5 A but landfill 5B was re-vegetating and by 1976 re-vegetation was occurring at both landfill 5A
and SB. The Base refuse disposed of in landfill 5A was reported as domestic waste and shop
wastes such as solvents, waste oils, ethylene glycol, silicone oil, hydraulic fluid, waste JP-4,
batteries, battery acid, expired pesticides, old paint, asbestos insulation, and incinerator ash. Field
reconnaissance observed the presence of ash, cinders, and construction debris on the surface.
Extensive surface subsidence was observed in the area of the landfill 5 A trenches. Water lines,
sanitary sewers, natural gas lines, electrical power lines, communications lines, and cable-
television lines are throughout the area, including within the boundaries of landfill 5 A.
On September 26, 1991, a Federal Facility Agreement (FFA) was signed between the USAF,
EPA, and WDEQ. The FFA is required by Section 120 of CERCLA The FFA provides the
framework for EPA and WDEQ oversight of continuing remedial investigations at the Base and
further identifies USAF investigation activities and schedules. The Base provides documents to EPA
and WDEQ for review and concurrence, in accordance with the FFA.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The USAF has prepared and implemented a community relations plan (CRP) in accordance
with CERCLA requirements, and the FFA. The CRP describes community involvement activities the
USAF will undertake during remedial activities at F. E. Warren Air Force Base. The USAF has
followed the requirements of the CRP, including issuance of periodic fact sheets, holding public
meetings, and providing the opportunity for public comment throughout the LF5 A investigation.
The Administrative Record has been established at an on-Base location and at the Laramie
County Public Library. The USAF has prepared and distributed fact sheets to all persons or groups
identified on the CRP mailing list.
The announcement of the commencement of the public comment period was made on October
8, 1995, through advertisements in the Wyoming Tribune-Eagle and in the Casper Star-Tribune.
Additional announcements and articles on the public meeting and proposed plan were run in the
Wyoming Tribune-Eagle on 21 and 31 October, 1995. These advertisements announced and outlined
the public comment period and public meeting. The public comment period was scheduled from
October 23 to November 21, 1995. A public meeting was held at Cheyenne, Wyoming on November
7, 1995. An official transcript of the meeting has been prepared and placed in the Administrative
Record.
In addition to the newspaper announcements, the USAF also issued a press release and an
article appeared in the Base Sentinel newspaper on October 13, 1995. The public meeting was also
announced during the "Military Minute" on Cheyenne radio station KRAE on November 7, 1995.
Channel 5, KWGN television carried a report on the public meeting on November 7, 1995.
FNLROD4.DOC : 03 October 1996
-------
Responses to all comments on the Proposed Plan are presented in the Responsiveness
Summary of this ROD.
4.0 SCOPE AND ROLE OF OPERABLE UNIT
The selected interim action (remedy) for LF5 A is a source control action that includes capping,
an active gas venting system and, if needed, a gas control system for VOCs. Other Operable Units
(OU's) at the Base are: OU1 - Spill Sites 1 through 7; OU2 - Facility Ground water (except at OUs 3,
6, 7 and 8); OUS - Landfills 3 and 6; OU4 - Acid Dry Wells; OU 5 - Fire Protection Training Area 2;
OU 6 - Open Burning/Open Detonation Area; OU7 - Firing Range(s); OU9- Landfills 2 and 4; and
OU10- Landfill 7 and Fire Protection Training Area 1. The ground water contamination associated
with OUs 3, 6, 7, and 8 will be investigated and remediated as part of these OUs, separate from OU2.
All of the investigations are being conducted in accordance with the FFA. It is anticipated that the
ROD for OU2 will be issued after the RI has been completed for the other operable units.
5.0 SITE CHARACTERISTICS
LF5 is the source of several chemicals found in ground water at concentrations in excess of
Federal drinking water standards. The chemical most frequently detected is trichloroethylene (TCE),
considered to be a suspected carcinogen.
No specific characterization has been performed for the landfill contents. Based on the EPA
guidance on presumptive remedies for landfills, the source of contamination is considered to be the
entire landfill area.
At LF5A, cores from 14 shallow-soil boreholes were sampled and analyzed for volatile organic
compounds (VOCs), semi-volatile organic compounds (SVOCs), organo-chlorine pesticides,
polychlorinated biphenyls (PCBs), metals, anions, and moisture content. No target analyte SVOCs
were detected; however a number of SVOC tentatively identified compounds (TICs) were found in the
soils. The pesticides 4,4'-DDT and 4,4'-DDE were detected in one of the 14 samples. Surface
samples from four selected boreholes at LF5A were analyzed for polychlorinated dibenzo-p-dioxins
(PCDDs) and polychlorinated dibenzofurans (PCDFs). None were detected at LF5A.
Soil-gas samples were analyzed from 14 sites corresponding to the soil boreholes. Methane
was not detected, however, because only 5 of the sample locations were within the LF5A boundary,
the presence of methane could not be ruled out. Samples from two of the 14 sites showed detectable
vinyl chloride, one of the two sites also had detectable TCE.
A series of 29 test wells were installed and sampled for field screening purposes. Ground-water
samples were collected and analyzed for vinyl chloride, trans-1,2-dichloroethene, cis-1,2-
dichloroethene, benzene, TCE, chloride, nitrate, and sulfate. Tetrachloroethene was analyzed for in
four of the LF5A samples. TCE was detected in seven of the samples, with a maximum concentration
of 4.4 ug/L. Vinyl chloride was detected in 23 of the samples, with five having concentrations in
excess of the Maximum Contaminant Level (MCL) of 2 ug/L and with a maximum concentration of
4.4 ug/L. Nitrate was detected in one well at a concentration above the MCL of 10 mg/L. A high
FNLROD4.DOC : 03 October 1996
-------
sulfate level and high specific conductance (a measure of total dissolved solids) were detected in the
same well as the maximum TCE concentration.
None of the base wide surface-water and bed material sample sites are considered to be
associated with LF5 A.
Based on the potential pathways that exist at landfill 5 A, as well as the current state of the
landfill, there are two primary pathways by which contaminants can migrate to potential receptors.
Leachate generation and subsequent migration to the underlying soil and ground water is the
most significant pathway at landfill 5A. This mechanism may occur as the result of rain water
infiltration and reaction with landfill contents to generate leachate, or by the leakage of non-aqueous
phase liquids (NAPLs) from the landfill to ground water. This mechanism is evident at LF5A by the
development of a TCE plume emanating from the landfill. During transport by ground water,
contaminants may undergo degradation and transformation reactions that produce additional
contaminants over time. Plume size is a function of the mass of the contaminants released to the
ground aquifer, the rate of ground-water flow, and the retardation of the contaminants within the
plume relative to ground-water flow. Given the characteristics of a typical landfill, it is possible that a
near-continuous source is present, which would result in continued development of the plume down
gradient of the landfill.
Contaminant transport by overland flow of surface water is considered a potential migration
pathway, although it is probably minor due to the semiarid climate and the relatively flat topography of
the site. However, contaminant transport may occur during periods of heavy rainfall or rapid snow
melt.
Airborne dispersion of volatilized organic compounds and fugitive dust emissions are aspects
of the second pathway. Organic contaminants in soil at LF5A consist of SVOCs that are readily
sorbed to particulates and susceptible to transport. Inorganic contaminants consist of metals that also
exist primarily in the solid phase and thus are readily transported by wind. Although the landfill has a
soil and grass cover, without knowledge of the design, depth, and condition of the cover, future direct
contact with the landfill contents cannot be precluded, if the selected remedy is not implemented.
6.0 SUMMARY OF SITE RISKS
A streamlined risk assessment (SRA) was conducted for LF5 to determine the potential human
exposures and risks from chemicals under baseline conditions. The ground-water indicator
contaminants of concern (ICOCs) are: Trichloroethylene (TCE), cis-l,2-dichloroethene, and vinyl
chloride.
Landfill 5 is the source of several chemicals found at concentrations in excess of Federal
drinking water standards. The most prevalent is trichloroethylene (TCE), considered to be a suspected
carcinogen. The carcinogenic risk from exposure to TCE in ground water is within the target risk
range of 10"4 to 10"6 (1 in 10,000 to 1 in 1,000,000). Vinyl Chloride, a known carcinogen, accounted
for the highest risk of 6.8 x 10"4, at LF5A.
FNLROD4.DOC : 03 October 1996
-------
Potential carcinogenic health effects were identified on the basis of the reasonable maximum
exposure (RME) calculations for both the residential and occupational scenarios. The risk-based
equations used to compute the preliminary remediation goals (PRGs) were derived to reflect the
potential risk from exposure to a single chemical, given a specific pathway, medium, and land-use
combination.
The use of the PRGs serves a two-fold purpose for risk characterization. First, the
comparison of the site and COC-specific RME concentration with the corresponding PRG gives an
immediate indication that a potential risk may exist when the PRG concentration is exceeded. Second,
the risk corresponding to the site and COC-specific RME can be calculated. Both of these functions
are useful when performing a risk screening. Also, as part of the risk characterization phase of this
SRA, the highest potential cumulative risks associated with ground water were determined on the basis
of a one acre residential plot exposure unit area. The following is a summary of the SRA findings:
Residential Carcinogenic Ground Water Risk: The residential carcinogenic ground water risk was
estimated to range from 1.2 x 10"6 to 6.8 x 10"*
Vinyl Chloride accounted for the four highest potential risk estimates at LF5 A.
Occupational Carcinogenic Ground Water Risk: The occupational carcinogenic ground water risk
was estimated to range from 1.0 x 10"6 to 3.5 x 10"*.
Potential non-carcinogenic health effects were identified on the basis of the RME calculations
for both residential and occupational exposure scenarios. No ICOC demonstrated a Hazard Quotient
exceeding 1.0.
Although an ecological investigation was conducted, an ecological risk assessment was
determined to not be necessary since the remedy (capping the landfill) will mitigate any ecological risks.
The selected interim action will:
Decrease the potential for contamination of ground water by reducing the movement of
contaminants from the landfill.
Provide protection against direct contact with the landfill contents.
Control surface water (both run on and run off) and erosion.
Provide protection to human health by eliminating exposure to contaminant vapors and
contaminated dust particulate.
FNLROD4.DOC : 03 October 1996
-------
Eliminate direct contact with the landfill contents by constructing a cap over the landfill,
meeting RCRA landfill closure requirements, and implementing deed restrictions to prohibit
residential development of the site.
Reduce the potential for landfill gas migration by installing an active landfill gas venting and
control system. The number of gas vents and/or controls shall be determined during the
remedial design. The landfill gas venting system shall meet ARARs.
The function of this interim action is to control LF5A as a source of ground-water
contamination by reducing infiltration and the downward movement of contaminants to the ground
water and to reduce the risks associated with exposure to contaminated materials.
Actual or threatened releases of hazardous substances from the landfills, if not addressed, may
present a current or potential threat to public health and the environment.
7.0 DESCRIPTION OF ALTERNATIVES
Three alternatives for the interim remedial action were evaluated as part of the detailed analysis
in the focused feasibility study. All three alternatives are summarized in this section. None of the
alternatives are expected to be the final remedy for LF5A. Institutional controls are included for all
alternatives. The purpose of these institutional controls is to limit direct exposure to landfill contents
and contaminated soils and to protect the integrity of the remedy. Deed restrictions will not allow
subsurface development (excavation) or excessive vehicular traffic at LF5 A. Implementing institutional
controls will include:
A continuing order of the Base Commander requiring implementation of the landfill
restrictions as long as the property is owned by F. E. Warren AFB.
Upon completion of construction at LF5A, the Air Force will file notice of these
restrictions in the real- property records of the county in which the landfill is located.
Before transfer of the property, the Air Force will provide a deed covenant notifying the
transferee of the locations and the restrictions on the use of the areas.
Fencing the landfill area and placing warning signs for the duration of the remedial action.
Additional deed restrictions may be required for effective implementation of other
technologies.
Alternative 1 is no action. Evaluation of the "no action" alternative is required by the National
Contingency Plan to be used as a baseline comparison for other alternatives. Under this alternative the
Air Force would take no action at the landfill to prevent exposures to contamination.
Alternative 2 consists of a simple compacted soil cap with a gas venting and control system.
This cap would be designed to meet Resource Conservation and Recovery Act (RCRA), subtitle D,
landfill closure requirements, so as to reduce infiltration of water from the ground surface to the landfill
FNLROD4.DOC : 03 October 1996
-------
contents, provide protection against direct contact with the landfill contents, and eliminate exposure to
contaminant vapors and contaminated dust paniculate.
The exact construction specifications of the cap will be determined during the Remedial Design
stage. A typical single-barrier compacted-soil cap consists of a compacted clay layer overlain by a
gravel drainage layer. A final soil layer and vegetative soil layer would be placed as a top cover to
protect the cap from erosion and other weather effects. Surface water diversion and erosion and
ponding prevention would be included as an integral part of the topsoil grading design. Methane gas
would be controlled with an active venting system, where pumped gas vent wells are used to provide
positive reduction of gas pressures. The potential of VOCs to be in the soil gas will be investigated
during the remedial design. Uncontaminated cap and topsoil materials would be hauled to the landfill
from a borrow source. Long-term periodic monitoring of ground water would be performed.
Alternative 3 is a composite cap with a gas venting and control system. This alternative
consists of the construction of a multiple-barrier cap to cover the surface of the landfill. This landfill
cap would be designed to meet the landfill closure requirements of RCRA subtitle C, so as to reduce
infiltration of water from the ground surface to the landfill contents, provide protection against direct
contact with the landfill contents, and eliminate exposure to contaminant vapors and contaminated dust
p articulates.
A typical composite barrier consists of a compacted clay layer covered by a synthetic liner.
This, in turn, is overlain by a drainage layer. A final soil layer and vegetative soil layer placed as a top
cover serves to protect the cap from erosion and other weather effects. Surface water diversion and
erosion and ponding prevention would be included as an integral part of the topsoil grading design.
Any liquid that percolates through the top soil cover is collected by the drainage layer.. Methane gas
would be controlled with an active venting system to provide positive reduction of gas pressures. The
potential of VOCs to be in the soil gas will be considered during the remedial design. Uncontaminated
cap and topsoil materials would be hauled to the landfill from a borrow source. Long-term periodic
monitoring of ground water would be performed.
8.0 MONITORING WELL CONSTRUCTION
This section memorializes the agreement between the State and the Air Force, concerning
appropriations of groundwater for on-base monitoring wells constructed, operated, and abandoned
incident to clean-up activities undertaken by the Air Force at Operable Unit 8: Landfill 5 A (OU8,
LF5A). The State and the Air Force disagree on whether the Air Force is required to obtain permits
from the State Engineer's Office pursuant to State law, whether the Air Force has a federal reserved
water right covering groundwater at F. E. Warren Air Force Base (the Base), and whether Wyoming
statutes, rules, and regulations pertaining to groundwater are ARARs. Despite these disagreements,
however, the parties believe that the procedures described below will enable the Air Force to
appropriate water for the required monitoring wells, while preserving the parties' legal and
jurisdictional positions. By employing these procedures, the parties intend to avoid the necessity for
protracted dispute resolution and/or legal action to resolve their legal and jurisdictional differences.
The parties do not anticipate that the legal and jurisdictional issues will need to be resolved in the
context of OU8 or in the context of the CERCLA clean-up at the Base. Consistent with this
FNLROD4. DOC : 03 October 1996 ] Q
-------
background, the purpose of these procedures is to effectuate the parties' desire that progress at OU8
continue, while ensuring that the legal and jurisdictional positions of the State and the Air Force are
preserved in the event of a future dispute relating to appropriation of groundwater at OU8.
These procedures, and the reservation of jurisdictional and legal arguments, are only applicable
within the context of water appropriation incident to construction, operation, and abandonment of
monitor wells at the Base for the Air force's on-base CERCLA clean-up activities. The procedures set
forth herein shall not be relied upon as precedent for any activities or water use or development outside
the narrow context of the dispute concerning the Air Force's CERCLA clean-up, unless otherwise
agreed to in writing by the parties.
By employing these procedures the parties are not waiving any arguments they may raise
concerning the legal applicability of State law permitting requirements, or the designation of State law
requirements as ARARs. In particular, but not by way of limitation, the parties each preserve their
legal positions concerning: (1) Whether the Air force has a federal reserved water right covering use of
water at the Base; (2) Whether Wyoming Statutes and the Regulations and Instructions of the State
Engineer's Office are ARARs; and (3) Whether the permitting exemption contained in Section
9621(e)(l) of CERCLA applies to State permits for the appropriation of groundwater. In the event
that a dispute or disagreement arises between the parties in the implementation of the procedures
described herein; the parties expressly agree that any and all legal arguments and/or defenses are fully
preserved and may be raised in any proceeding relating to the disputed issue.
The Air Force and the State agree to the following procedures relating to the appropriation of
groundwater incident to the construction, operation, and abandonment of monitor wells at the Base
during the CERCLA clean-up:
a. Prior to the construction of any wells, the Air Force will complete and submit to the
State Engineer's Office, the State's standard form "Application for Permit to Appropriate
Groundwater."
b. The Air Force will comply with all requirements for appropriating groundwater
contained in Wyoming Statutes and Parts 2 and 3 of the Regulations and Instructions of the
State Engineer. The Air Force further agrees to submit a "Statement of Completion" on the
standard State form, providing the information required therein.
c. The Air Force maintains that in providing information to the State on the State's forms
and complying with State law procedures that it is not making application for a permit under
State law, and further, that it is not required to follow State law for the appropriation of
federally reserved groundwater. It is the Air Force's position that it is only providing
information to the State in the most usable and efficient format to enable the State to properly
maintain its water records system, and cooperating with the State as a matter of comity. As
provided in Paragraph II, above, by submitting information on the State's forms and otherwise
complying with State law, the Air Force does not waive its right to claim that no State permit is
necessary or that the Air Force is not bound to follow State law in appropriating Groundwater
for the CERCLA clean-up at the Base.
FNLROD4.DOC : 03 October 1996 ] j
-------
d. The State Engineer will treat the forms and information received from the Air Force as
permit applications, and will issue permits in the name of the Air Force. The State Engineer
will, in all respects, and in the same manner as for any private water appropriator, maintain its
records and administer the permits in accordance with all applicable State law. As provided in
Paragraph n, above, by following these procedures, the State does not waive its right to claim
the Air Force is required to obtain State permits and follow State law in the appropriation of
groundwater at the Base.
e. The parties agree to work in good faith to resolve any disputes or disagreements that
may arise in the implementation of these procedures.
In the event that a dispute or disagreement arises from these procedures, and the parties are
unable to resolve the matter through informal negotiation, the parties agree that an action to resolve the
underlying jurisdictional and legal issues pertinent to appropriations of groundwater at OU8, may be
maintained pursuant the FFA, Section 9621(e)(2) of CERCLA, or through any another applicable
remedy provided for by law.
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Alternatives 2 and 3 are protective of human health and the environment because the cap will
reduce the rate at which contaminants move to the water table and prevent direct exposure to surface
contaminants. A reduction in the rate at which contaminants reach the water table will decrease the
concentrations of those contaminants in the shallow aquifer. Compliance with Federal and State
applicable or relevant and appropriate requirements (ARARs) relevant to the landfill cap will be
assured.
Each of the alternatives has been evaluated against nine criteria established to provide a
uniform basis for comparison.
1. Overall Protection: The "no action" alternative will not treat, remove, or provide any barrier other
than the minimal existing cover to landfill contents. With no impediment to infiltration of precipitation,
leaching and downward movement of contaminants will continue through the soil toward the water
table if no action is taken. Airborne dispersion of volatilized organic compounds and fugitive dust
emissions would remain a problem. The "no action" alternative does not guarantee overall protection
of human health and the environment. This alternative is not considered further in this analysis as an
option for the landfills. Both capping alternatives will prevent direct contact with landfill contents and
contaminated dust. Both capping options will also prevent the transport of volatile organic compounds
to the atmosphere and will reduce the rate at which chemicals move to the water table and are
therefore protective.
2. Compliance with ARARs: Alternative 2 would comply with the relevant and appropriate RCRA
subtitle D cap requirements but not subtitle C cap requirements. Alternative 3 would comply with
RCRA subtitle C landfill closure requirements. RCRA subtitle C requirements are not considered
FNLROD4.DOC : 03 October 1996 12
-------
applicable or relevant and appropriate for LF5A. Both capping alternatives would comply with other
applicable or relevant and appropriate State and Federal environmental laws and regulations, except for
ground water chemical-specific ARARs which are temporarily waived using the interim measures
waiver.
The Wyoming Water Quality Rules and Regulations (WWQRR), Chapter XVH, Appendix A,
risk assessment, and fate and transport procedures were considered by the State during the Feasibility
Study and in selection of a remedy for this interim action. The State has determined that the selected
remedy meets the intent of this regulation. The parties to this ROD agree that they will not raise non-
inclusion of Chapter XVII of the WWQRR as an ARAR here as basis for an inconsistent application
finding under 42 U. S. C. section 9621 (d) (4) (E) in any subsequent action where Chapter XVII is
considered an ARAR.
A complete listing of the ARARs may be found at Appendix A Waived ground water ARARs
may be found at Appendix B.
3. Long-Term Effectiveness and Permanence: The capping alternatives leave the landfill contents
in place. Both alternatives require the same institutional controls and regular maintenance to ensure
that the caps will continue to provide an appropriate level of protection against direct contact, air
transport, and erosion, as well as maintaining a barrier to infiltration. Transport of contaminants to the
ground water is diminished by either cap since the reduction of infiltration lessens the amount of
leachate produced. The composite cap is potentially more reliable than the compacted-soil cap because
of the addition of the synthetic membrane liner.
4. Reduction of Toxicity, Mobility, and Volume through Treatment: Because no treatment
technology is proposed under any of the alternatives, the considerations pertaining to treatment
technologies are not relevant.
5. Short-Term Effectiveness: The initial preparation for placement of either cap on the landfills
would cause disturbance of the existing ground surface. During this operation dust could be generated
and volatiles may be released to the air which would pose a minor, but temporary, risk to both workers
and the surrounding community. These risks will be minimized by following health and safety
procedures. Air monitoring will be used to assess the requirement for temporary control measures
during construction.
6. Implementability: The two capping options have no serious implementability problems, and from
a technical standpoint, implementation of either alternative should be fairly straightforward. Other than
adhering to site safety requirements, no special techniques, materials, or labor would be required to
prepare the site and place the compacted soil (single-barrier) cap. All materials and equipment can be
obtained locally. The geosynthetics involved in the composite (multiple-barrier) cap require special
handling techniques and labor for proper placement of the layers to ensure integrity. Contractors with
the appropriate specialized experience are available.
7. Cost: The capital cost differences between the two capping alternatives is due entirely to the larger
number of materials and special handling required for the composite cap. Yearly operation and
FNLROD4. DOC : 03 October 1996 ] 3
-------
maintenance costs are estimated to be the same for both alternatives. The comparison of the estimated
project design and implementation costs is as follows:
Alternative 2, Compacted Soil Cap
w/ gas venting system, Landfill 5A $ 4,342,000
ALTERNATIVE 2, 30 YEAR
PRESENT WORTH TOTAL $5,546,000
Alternative 3, Composite Cap
w/ gas venting system, Landfill 5A $ 5,814,000
ALTERNATIVES, 30YEAR
PRESENT WORTH TOTAL $7,023,000
8. State Acceptance: The State of Wyoming supports the preferred alternative as a partial remedy,
but has expressed concerns regarding the potential for landfill contents to be in contact with ground
water and for liquid wastes to be present in the landfill. These issues are more fully discussed in
Section D., STATE CONCERNS, of the Responsiveness Summary for the Record of Decision.
9. Community Acceptance: The general community, consisting of the residents of the City of
Cheyenne, Laramie County, and F. E Warren AFB support the preferred alternative based on
comments received during the public comment period.
10.0 DESCRIPTION OF SELECTED REMEDY
The Air Force's selected interim remedy for OU 8, Landfill 5A is alternative number 2. This
remedy involves the construction of a simple compacted soil cap that will meet RCRA subtitle D
landfill closure requirements. The actual design will be determined during the Remedial Design. A
typical cap would include a compacted clay layer overlain by a gravel layer. A final surface layer
consisting of soil and vegetation would be used to protect the clay and gravel layers from erosion and
other affects. Surface water diversion and ponding prevention would be included as an integral part of
the topsoil design. Gas migration will be controlled by an active venting system. Long-term periodic
monitoring of ground water would also be performed. Environmental monitoring to ensure the
effectiveness of the interim action will be implemented. Institutional controls to limit direct exposure to
landfill contents and contaminated soils, and to protect the integrity of the remedy will be implemented.
Institutional controls that will be implemented include:
A continuing order by the Base Commander requiring implementation of landfill restrictions as
long as the property is owned by F. E. Warren Air Force Base;
Filing notice of landfill restrictions in the real-property records of the county in which the
landfill is located;
Before transfer of the property, providing a deed covenant notifying the transferee of the
locations and restrictions on the use of the areas and;
FNLROD4. DOC : 03 October 1996 14
-------
Fencing the landfill area and placing warning signs for the duration of the remedial action.
The estimated capital expenditure for this remedy as described in this ROD, including the
design and construction of the proposed cap is approximately $4,342,000. The total operations and
maintenance costs (O&M) over 30 years is estimated at $2,351,000. The present value of total
estimated costs is $5,546,000. The actual cost are expected to be less than these amounts and will
depend on the final design and performance of the cap.
The selected remedy for Landfill 5A is a source control action that includes capping and an
active gas venting system. The selected remedy is designed to control the site as a source of ground
water contamination by reducing infiltration and the downward movement of contaminants to the
ground water, and to reduce the risks associated with exposure to contaminated materials.
Construction of a cap on Landfill 5 A would begin within 15 months of the signing of this
ROD. As an interim action, the preferred alternative is expected to be consistent with the final remedy
for OU 8.
11.0 STATUTORY DETERMINATIONS
The Air Force's selected remedy for Operable Unit 8, Landfill 5 A is alternative number 2. The
selected remedy meets the statutory requirements of Section 121 of CERCLA as amended by SARA
These statutory requirements include protectiveness of human health and the environment, compliance
with ARARs, cost effectiveness, utilization of permanent solutions and alternative treatment
technologies to the maximum extent practicable and preference for treatment as a principal element.
However, because treatment of the principal threats of the site was not found to be practicable, this
remedy does not satisfy the statutory preference for treatment as a principal element of the remedy.
The size of the landfill and the fact that there are no apparent on-site hot spots that represent the major
sources of contamination preclude a remedy in which contaminants could be excavated and treated
effectively. The selected remedy does comply with Section 300.403(a)(iii)(B) of the National
Contingency Plan (NCP) which states that engineering controls, such as containment, should be used
for wastes that pose a relatively low long-term threat or where treatment is impracticable. The
preamble to the NCP identifies CERCLA municipal landfills as a type of site where treatment of the
waste may be impracticable because of the size and heterogeneity of the contents. Subsequent
remedial actions are planned to address ground water contamination associated with Landfill 5 A
Since ground water chemical-specific ARARs will not be met by this action, these requirements
are temporarily waived using the interim measures waiver, granted through the signing of this Record
of Decision. The interim measures waiver will not cause additional movement of contaminants,
complicate the site response, present an immediate threat to public health or the environment, or
interfere with or delay the final remedy. The ground water chemical-specific ARARs will be met in the
final cleanup action for Operable Unit 8, Landfill 5.
FNLROD4.DOC : 03 October 1996 15
-------
12.0 EXPLANATION OF SIGNIFICANT CHANGES
The Proposed Plan was released for public comment in October, 1995. The preferred
alternative was for a source control action that includes capping and an active gas venting system, and
that this action is protective of human health and the environment. The USAF, EPA, and WDEQ
reviewed all written and verbal comments submitted during the public comment period. It was
determined that no significant changes were necessary to the preferred alternative.
FNLROD4.DOC: 03 October 1996
-------
RESPONSIVENESS SUMMARY
RECORD OF DECISION
INTERIM ACTION
OPERABLE UNIT 8: LANDFILL 5A
INTRODUCTION
The responsiveness summary is organized into sections as follows:
A, Overview
B. Background on Community Involvement
C. Summary of Comments Received
D. State Concerns
Attachment A: Community Relations Activities at F. E. Warren Air Force Base
A. OVERVIEW
At the time of the public comment period, the preferred alternative for the interim action at
Operable Unit 8, Landfill 5A at F. E. Warren Air Force Base, had been selected by the Air Force, with
EPA and Wyoming DEQ concurrence and was presented in the Proposed Plan. The preferred
alternative is a source control action that includes capping and an active gas venting and control
system.
Based on the public's response and comments received during the public comment period,
there are no significant objections to the preferred alternative.
B. BACKGROUND ON COMMUNITY INVOLVEMENT
Community interest in CERCLA/IRP (Installation Restoration Program) activities at F. E.
Warren Air Force Base has waxed and waned over the years since the records search and interviews
conducted for the Air Force in September 1985. No specific individuals or organizations have been
consistently involved over this period, although numerous groups and persons have been involved from
time to time. There were no concerns expressed during the OU8, Landfill 5 A Remedial Investigation,
prior to the public comment period.
C. SUMMARY OF COMMENTS RECEIVED
i
The public comment period on the Proposed Plan for the Operable Unit 8: Landfill 5 A interim
action at F. E. Warren Air Force Base was held from October 23, 1995 to November 21, 1995. A
public meeting was held on November 7, 1995. Comments received during the meeting are
summarized below. Similar comments have been combined where possible to prevent duplication of
responses. There were no specific legal or technical questions.
A few questions were asked about why the remedial action was being done on the
landfill first rather than on the associated ground water plume. It was explained that the
FNLROD4.DOC : 03 October 1996
-------
proposed action will help stop further contamination of the ground water beneath the landfill
and that the remediation of the ground water will follow this action.
Another question was asked about what contaminants are found in the ground water.
These compounds were identified as: trans-1,2-dichloroethene, cis-l,2-dichloroethene,
benzene, trichloroethene, chloride, nitrate, and sulfate. It was noted that this may not be a
complete list because the investigation is continuing.
A final question was asked about the funding of the project. It was explained that this
is a Superfund/CERCLA funded project using DOD environmental funds.
One comment was received by mail. The Wyoming Game and Fish Department wrote to
support the selected alternative and made two suggestions. The first suggestion was ground water
monitoring should be done no less than bi-monthly. The second was the need for setting contaminant
levels that would trigger additional remedial action. The Air Force will consider their suggestions
D. STATE CONCERNS
The State of Wyoming is concerned that waste materials contained in Landfill 5A may be
residing in ground water at times when the water table is elevated. As has been described in the
Record of Decision (ROD), the installation of a cap will significantly reduce the potential for
precipitation to infiltrate the landfill contents and contribute to ground water leachate. However, the
cap will not prevent the ongoing contamination of ground water if the landfill materials are in contact
with ground water. Additionally, the potential for liquid wastes to be present in the landfill exists which
would also constitute a source of ground water contamination not addressed by the installation of the
cap. For these reasons, the State of Wyoming supports the construction of the cap as a partial
solution. The outstanding issues of direct contact between the landfill materials and ground water, and
possible liquid wastes within the landfill are to be investigated and addressed during the remaining
investigations and comprehensive ROD at the completion of investigation and feasibility studies for the
site.
FNLROD4.DOC : 03 October 1996
-------
ATTACHMENT A
COMMUNITY RELATIONS ACTIVITIES
At
F. E. WARREN AIR FORCE BASE
OVERVIEW
The unique community involvement needs of F. E. Warren Air Force Base IRP/CERCLA
activities are addressed in the Community Relations Plan (CRP). In late 1990, during plan
development, interviews were held with 56 people representing F. E. Warren Air Force Base, other
Federal agencies, State, city and county agencies, community groups, well owners, and other
individuals. The most significant issues identified in the interviews were concerns about potential
drinking water contamination and about the community involvement process.
OU 8: LANDFILL 5A RELATED ACTIVITIES
Operable Unit 8 : Landfill 5 (includes subunits) has been addressed in Fact Sheets, Status
Reports, newspaper advertisements and articles since Fact Sheet 1 was prepared, by the Air Force, in
October 1990 for the initial interviews. Fact Sheet 1 was mailed in May 1991. After the Federal
Facility Agreement became effective, a Status Report update was distributed on December 12, 1991,
with information on all of the operable units. Since then, the quarterly status update reports have
informed the public about OU 8 and Landfill 5 activities on a regular basis.
The Proposed Plan for OU8 : LF5A was prepared in October 1995. A display advertisement
concerning the Proposed Plan and the public meeting was placed in the Wyoming Tribune-Eagle and
the Casper Star-Tribune on October 8, 1995. A copy of the Proposed Plan was sent to all persons on
the mailing list about the same time. A copy of the Proposed Plan was placed in the Administrative
Record and the Laramie County Library Records Repository in early October 1995. All of the
newspaper advertisements and the mailings were coordinated between the Air Force, EPA and
Wyoming DEQ before publication or distribution. In addition to the paid advertisements, the Air
Force issued press releases which resulted in articles published in the Wyoming Tribune-Eagle on
October 21 and 31, 1995, and the F. E. Warren Air Force Base Sentinel on October 13 and November
7, 1995. Radio announcements of the public meeting were made periodically in October and
November 1995. A television report was shown on November 7, 1995.
There were a few comments received at the public meeting and in the mail. These are
discussed in the Responsiveness Summary Section of this document.
The F. E. Warren AFB Restoration Advisory Board (RAB) was also briefed on and discussed
the preferred alternative for LF5A.
FNLROD4.DOC : 10/11/96
-------
ADMINISTRATIVE RECORD REPOSITORY
An Administrative Record Repository containing documentation of the ERP/CERCLA process
was established in October 1989 and is maintained at the following locations to insure accessibility.
Information Repository
Laramie County Library
Reference Section
2800 Central Avenue
Cheyenne WY 82001
Phone (307) 634-3561
Administrative Record
90 CES/CEVR
Environmental Restoration Section
300 Vesle Drive, Suite 600
F. E. Warren AFB WY 82005-2793
Phone (307) 775-3468
These records are maintained according to EPA guidelines, by the Environmental Restoration
Flight, and are updated at least quarterly. The Administrative Record Repository also functions as the
required information repository. A copy of the Administrative Record is housed in the Laramie County
Library reference section to insure public access.
RESTORATION ADVISORY BOARD
In an effort to improve public participation in environmental cleanup activities at F. E. Warren
Air Force Base, a Restoration Advisory Board (RAB) has been formed to replace the Technical
Review Committee. The RAB consists of community volunteers and representatives from the Base,
EPA and WDEQ. It is chaired by a community member and a senior base official.
The board offers community members the opportunity to provide input to the decision making
process used by the base to clean up contaminated sites.
MAILING LIST
A major part of the public relations activities is the mailing list. In an attempt to proactively
contact the 2,300 well owners identified in the EPA Superfund ranking, F. E. Warren sent a general
mailing to well owners within a 3-mile radius. The Wyoming State Engineer's Office provided the
mailing list of well owners. The mailing included a brief status report and a coupon to be mailed back
if the well owner wanted to be added to the mailing list for distribution of later status reports. This
activity resulted in the current list that has about 600 names on it. The mailing list is maintained in the
F. E. Warren Air Force Base Public Affairs Office. Status Reports or Fact Sheets are mailed on a
quarterly basis. Anyone who desires to be included on the list should contact either of the following
offices.
90 CES/CEVP
300 Vesle Drive, Suite 600
F. E. Warren AFB WY 82005-2788
Phone (307) 775-4154
90 CES/CEVR
300 Vesle Drive, Ste 600
F. E. Warren AFB WY 82005-2793
Phone (307) 775-3468
FNLROD4.DOC: 10/11/96
-------
INFORMATION CONTACT
An information contact person has been designated within the F. E. Warren Air Force Base
Environmental Restoration Section to maintain regular contact with the community. This person is
responsible for responding to requests for information and planning and scheduling activities included
in the plan. The preparation of materials for public distribution will be coordinated with the Public
Affairs Office. General public information requests should be directed to (307) 775-3468. The media
contact for F. E. Warren Air Force Base is the Environmental Public Affairs office at (307) 775-4154.
FNLROD4.DOC : 10/11/96
-------
Appendix A
Federal and Wyoming State
Applicable, or Relevant and Appropriate Requirements (ARARs)
For Landfill SA at F.E. Warren AFB
FNLROD4.DOC: 10/11/96
-------
Table A-1 - Federal Chemical-Specific ARARs
[USC, United States Code; CFR, Code of Federal Regulations; Statute; Exec., Executive; DOT, Department of Transportation; FS, Feasibility Study]
Standard requirement,
criteria, or limitation
Clfiin Air Act
National Emission Standards fur Hazardous Air
Pollutants
Standards of Performance for New Stationary
Sources
Citations
42 USC
7401-7642
40 CFR 61,
SubpartA
40 CFR 60,
Subpart
WWW
Description
Establish regulatory standards for specific
hazardous air pollutants
Establish performance standards for venting of
landfill gases as a type of new stationary source
Applicable/
Relevant and
Appropriate
No/Yes
Yes/NA
Comments
Current assessments indicate regulation is not
relevant and appropriate, but venting of landfill
gases reaching regulatory thresholds could possibly
make this regulation relevant and appropriate.
Interim action remediation may involve venting or
treating of landfill gasses.
FNLROD4.DOC: 10/11/96
-------
Table A-2 - State Chemical - Specific ARARs
[USC, United States Codes; CFR, Code of Federal Regulations; P.L., Public Law; Stat., Statute; Exec., Executive; DOT, Department of Transportation]
Standard requirement,
criteria, or limitation
Citations
Description
Applicable/
Relevant and
Appropriate
Comments
Wyoming Environmental Quality Act
W.S. 35-11-101 to
35-11-1428
Wyoming Water Quality Rules and Regulations
W.S. 35-11-201 Discharge or emission of air contaminants
W.S. 35-11-301 Prohibits certain acts without a permit
Chapter I,
Section 18
Human health values
Chapter I, Protection of aquatic life
Section 21 (a-c)
Chapter I,
Section 22
Chapter I.
Section 23(a-b)
Chapter I.
Section 2-4
Radioactive material
Turbidity
Dissolved Oxygen
Yes/NA Compliance with state air quality numeric and other
substantive requirements identified as ARARs satisfies
all requirements .of this provision.
Yes/NA Although there is no federal counterpart which meets or
exceeds the requirement that there be no threat to pollute
the waters of the state, the selected remedy of a RCRA
subtitle D cap will comply with and meet the intent of
this requirement for this interim action. The selected
remedy will adequately reduce any threat to groundwater
or surface water quality from migration of landfill
contaminants resulting from infiltration or surface runolV
of precipitation. Further, compliance with state water
quality substantive requirements (permits are not
required) identified as ARARs satisfies all requirements
of this provision.
Yes/NA Not applicable unless affected waters upgraded to class
2.
Yes/NA Ammonia is not anticipated and monitoring is not
required.
Yes/NA Radioactive materials are not anticipated and monitoring
is not required.
Yes/NA Section 23(u) is not applicable unless allcclcd waters are
upgraded to class 2.
Yes/NA Nut applicable unless ullcctcJ waters upgraded to class
2.
FNLROD4.DOC: 10/11/96
-------
Table A-2 - State Chemical - Specific ARARs
[USC, United States Codes; CFR, Code of Federal Regulations; P.L.. Public Law; Stat., Statute; Exec., Executive, DOT, Department of Transportation]
Standard requirement, Citations Description
criteria, or limitation
Chapter I, Temperature, pH, fecal colitbrm bacteria
Sections 25-27
Chapter 1. Oil and grease
Section 29
Applicable/
Relevant and
Appropriate
Yes/NA
Ycs/NA
Comments
Primarily applicable during the construction of the
landfill cap, and although discharges are not anticipated.
Chapter XVII, Underground Storage Tanks
Appendix A,
Sections III and IX
No/No
may be applicable during any maintenance of the cap.
Please see discussion in Decision Summary, section 9.
FNLROD4.DOC: 10/11/96
-------
Table A-3 - Federal Action - Specific ARARs
[USC, United States Codes; CFR, Code of Federal Regulations; P.L., Public Law; Stat., Statute; Exec., Executive; DOT, Department of Transportation]
Standard requirement,
criteria, or limitation
Clean Water Act
NPDES Storm Water Regulations
Clc:in Air Act
National Emission Standards lor Hazardous Air
Pollutants
Citations
33 USC 1251-1376
40 CFR 122
42 USC 7-401-7642
40 CFR 61,
SubpartA
Description
Establishes requirements for discharge of
storm waterr
Establish
pollutants
regulatory standards for specific air
Applicable/
Relevant and
Appropriate
Yes/NA
No/Yes
Comments
Storm water runolTmay occur from the site
making substantive requirements applicable.
Current assessments indicate regulation is not
relevant and appropriate, but venting of landfill
Standards of Performance for New Stationary Sources 40 CFR 60,
SubpartWWW
Resource Conservation and Recovery Act
Criteria for Municipal Solid Waste Landfills
40 CFR 258
Establish performance standards for venting of
landfill gases as a type of new stationary
source
Establishes design and operational
requirements for municipal waste landfills
(RCRA Subtitle D)
gases reaching regulatory thresholds could
possibly make this regulation relevant and
appropriate.
Yes/NA Interim action remediation may involve venting or
treating of landfill gasses.
No/Yes Landfill 5 operation ceased before promulgation
of regulation. Closure requirements may still be
relevant and appropriate.
FNl.ROD4.DOC: 10/11/96
-------
Table A-4 - State Action-Specific ARARs
[USC, United States Codes; CFR, Code of Federal Regulations; P.L., Public Law; Stat., Statute; Exec., Executive; DOT, Department of Transportation)
Standard requirement,
criteria, or limitation
Citations
Description
Applicable/
Relevant and
Appropriate
Comments
Wyoming Environmental Quality Act
W.S. 35-11-101 to
35-11-1428
W.S. 35-11-201 Discharge or emission of air contaminants
W.S. 35-11-301 Prohibits certain acts without a permit
Yes/NA Compliance with state air quality numeric and other
substantive requirements identified as ARARs
satisfies all requirements of this provision.
Yes/NA Although there is no federal counterpart which
meets or exceeds the requirement that there be no
threat to pollute the waters of the state, the selected
remedy of a RCRA subtitle D cap will comply with
and meet the intent of this requirement for this
interim action. The selected remedy will adequately
reduce any threat to groundwater or surface water
quality from migration of landfill contaminants
resulting from infiltration or surface runoff of
precipitation. Further, compliance with state water
quality substantive requirements (permits are not
required) identified as ARARs satisfies all
requirements of this provision.
Wyoming Air Quality Standards »nd Regulations
W.S. 35-1 l-502(a) Solid Waste Management Facilities
Section 1-4 Control of particulute emissions
Section 16 (a, c) Odors
Section 19 Abnormal conditions and equipment
malfunctions
Yes/NA Only substantive standards upply, and permits are
not required.
Ycs/NA I'rinuirily applicable during the construction of the
lundlill cup, and although such emissions uru not
anticipated, may be applicable during any
maintenance of the cap.
Yes/NA No monitoring required.
Yes/NA Primarily applicable during the construction of the
landfill cap, and although such emissions are not
anticipated, may be applicable during any
FNLROD4.DOC: 10/11/96
-------
Table A-4 - State Action-Specific ARARs
[USC, United States Codes; CFR, Code of Federal Regulations; P.L., Public Law; Stat, Statute; Exec., Executive; DOT, Department of Transportation]
Standard requirement, Citations
criteria, or limitation
Section 21 (cXv) &
(I)
Wyoming Water Quality Rules and Regulations
Chapter I,
Section ll(a-b)
Chapter I, Section
15,16, I7(a-c)
Chapter III,
Section 4(e)
Chapter III,
Section 6(d), 7(c),
8(a-0
Chapter IV, Section
4(aXi, iii), (b-c), 5,
7 and 8
Description
Permit requirements for construction,
modification and operations
Flow conditions
Settleable solids, floating and suspended
solids, and taste, odor and color
Prohibition on discharge of wastes to
treatment works
Construction, Installation or Modification of
Facilities Capable of Causing or Contributing
to Pollution
Releases of oil and hazardous substances
Applicable/
Relevant and
Appropriate
Ycs/NA
Yes/NA
Yes/NA
Yes/NA
Yes/NA
Yes/NA
Comments
maintenance of the cap.
Applies if there are discharges if sedimentation
ponds are constructed.
Primarily applicable during the construction of the
landfill cap, and although discharges are not
anticipated, may be applicable during any
maintenance of the cap.
Substantive provisions apply, but no permits-
required.
Although there is no federal counterpart which
meets or exceeds the requirement that there be no
threat to pollute the waters of the state, the selected
remedy of a RCRA subtitle D cap will comply with
and meet the intent of Section 5 for this interim
action. The selected remedy will adequately reduce
any threat to groundwater or surface water quality
from migration of landfill contaminants resulting
from infiltration or surface runoff of precipitation.
Further, compliance with state water quality
substantive requirements (permits are not required)
identified as ARARs satisfies all requirements of
Section 5.
Wyoming Solid Waste Management Rules and
Regulations
FNLROD4.DOC: 10/11/96
Chapter 2, Section Sanitary Landfill Regulations
7
Yes/NA
Interim action qualities as part of the process of
-------
Table A-4 - State Action-Specific ARARs
[USC, United States Codes; CFR, Code of Federal Regulations; P.L., Public Law; Stat., Statute; Exec., Executive; DOT, Department of Transportation]
Standard requirement,
criteria, or limitation
Citations
Description
Applicable/
Relevant and
Appropriate
Comments
Chapter 8, Section
3(bXi & ii) and
4(cXiii-v)
Special Waste Management Standards
Chapter 15, Section Wyoming Solid Waste Management Rules
11 (d, I, m, p & q) and Regulations, 1975
closure.
Yts/NA Substantive requirements within this regulation
apply if landfill contains asbestos.
Yes/NA Requirements more stringent than 40 CFR 258
apply.
ITMI.ROD4.DOC: 10/11/96
-------
Table A-5 - Federal Location-Specific ARARs
[USC, United States Codes; CFR, Code of Federal Regulations; P.L., Public Law; Stat., Statute; Exec.. Executive; DOT, Department of Transportation]
Standard requirement, Citations Description Applicable/ Comments
criteria, or limitation Relevant and
Appropriate
FNLROD4.DOC: 10/11/96
-------
Table A-6 * State Location-Specific ARARs
[CFR, Code of Federal Regulations; P.L., Public Law; W.S., Wyoming Statute]
Standard requirement, Citations Description Applicable/ Comments
criteria, or limitation Relevant and
Appropriate
Wyoming Water Quality Rules and Regulations Chapter I, Appendix A Quality Standards for Wyoming Surface Yes/NA Classifications of Diamond Creek, Crow Creek and
Waters unnamed tributary apply. ARARs tor upgraded
stream classifications apply.
FN LK^HOC : IO/11 /96 | (]
-------
Appendix B
Temporarily Waived Federal and Wyoming State
Applicable, or Relevant and Appropriate Requirements (AJRARs)
FNLROD4.DOC: 10/11/96
-------
Table B-1 - Federal Chemical-Specific ARARs
[USC, United States Codes; CFR, Code of Federal Regulations; Statute; Exec.. Executive; DOT, Department of Transportation; FS, Feasibility Study]
Standard requirement,
criteria, or limitation
Citations
Description
Applicable/
Relevant and
Appropriate
Comments
Safe Drinking Water Act
National Primary Drinking Water Regulations
442 USC 300g
40 CFR 141,
Subparts B and G
Maximum Contaminant Level Goals (MCLGs) 40 CFR, Subpart F
Establish health-based standards for the No/Yes
public water systems (maximum
contaminant levels)
Establish drinking water quality goals set No/Yes
at levels of no known or anticipated
adverse health effects, with an adequate
margin of safety
Groundwater is a potential or actual source of
drinking water. This interim action is due to
groundwater contamination. The cleanup of
groundwater will be addressed in subsequent
actions.
Gruundwater is a potential or actual source of
drinking water. This interim action is due to
groundwater contamination. The cleanup of
groundwuter will be addressed in subsequent
actions. Relevant und appropriate only for
constituents of concern with an MCLG greater than
zero.
FNLRJMfeDOC : 10/11/96
-------
Table B-2 - State Chemical-Specific ARARs
[USC, United States Codes; CFR, Code of Federal Regulations; Statute; Exec., Executive; DOT, Department of Transportation; FS, Feasibility Study]
Standard requirement,
criteria, or limitation
Citations
. Description
Applicable/
Relevant and
Appropriate
Comments
Wyoming Water Qualilv Rules and Regulations
Chapter VIII
Quality Standards for Wyoming
Ground water
Yes/NA Groundwater is a potential or actual source of
drinking water. This interim action is due to
groundwater contamination. The cleanup of ground
water will be addressed in subsequent actions.
Regarding Section 1, compliance with other state
water quality substantive requirements (permits are
not required) identified as ARARs satisfies all
requirements of this provision.
FNLROD4.DOC: 10/11/96
------- |