United States
                                 Environmental Protection
                                 Agency
                       Office of
                       Solid Waste and
                       Emergency Response
                 Directive: 9355.3-11FS
                 September 1990
                                                            unicipal   Landfill  Sites
    Office of Emergency and Remedial Response
    Hazardous Site Control Division
                                                     Quick Reference Fact Sheet
   Approximately 20 percent of the sites on the National Priorities List (NPL) are municipal landfills which typically share similar
 characteristics. Because of this similarity the Superfund Program anticipates that their remediation will involve similar waste management
 approaches. As stated in the National Contingency Plan, EPA expects that containment technologies will generally be appropriate for waste
 that poses a relatively low long-term threat or where treatment is impracticable (Sec. 300.430(a)(l)(iii)(B), 55 FR 8846 (March 8,1990)).
 In addition, EPA expects treatment to be considered for identifiable areas of highly toxic and/or mobile material that constitute the principal
 threat(s) posed by the site (Sec. 300.430(a)(l)(iii)(A)). The similarity in landfill characteristics and the NCP expectations make itpossible
 to streamline the RI/FS for municipal landfills with respect to site characterization, risk assessment, and the development of remedial action
 alternatives. This fact sheet outlines available streamlining techniques for each of these three phases of an RI/FS. Additional information,
 including tools to assist in scoping activities, will be included in the document Conducting Remedial Investigations/Feasibility Studies for
 CERCLA Municipal Landfill Sites (November 1990, Directive No. 9355.3-11). This document will be available from  the Center for
 Environmental Research Information (FTS 684-7562 or 513-569-7562).
 Landfill Site

 Characteristics

   For the purpose of this  fact sheet,
 CERCLA municipal landfills are those
 facilities where a combination of princi-
 pally municipal and to a lesser extent haz-
 ardous  wastes  have been  co-disposed.
 Because of the volume and heterogeneity of
 waste within these landfills, treatment of the
 entire contents is often impracticable. Po-
 tential threats to human health and the envi-
 ronment resulting from municipal landfills
 may include:  (1) leachate generation and
 groundwater contamination; (2) soil  con-
 tamination; (3) landfill contents; (4) landfill
 gases; and (5) contamination of surface
 waters, sediments, and adjacent wetlands.
 A conceptual model of the potential path-
 ways of exposure to hazardous substances
 that may exist at municipal landfill sites is
 presented in Figure 1. Affected media and
 their pathways of exposure that are unique
 to landfills are the subject of this fact sheet;
 other media are discussed in the forthcom-
 ing guidance.

 Streamlining Site

 Characterization

  The characterization of a municipal
landfill site can be  expedited by focusing
field activities on the information needed to
(1) sufficiently assess risks posed  by the
site, and (2) evaluate practicable remedial
actions. Additionally, site characterization
 may be streamlined by conducting a limited
 field investigation during scoping of the RI/
 FS to assist  in identifying necessary
 fieldwork. Examples of limited field inves-
 tigation activities may include evaluating
 usefulness of an existing monitoring well
 network or verifying that the landfill was
 constructed as designed.

 Leachate/Groundwater
 Contamination
   Characterization of a site's geology and
 hydrogeology are necessary to adequately
 assess the design of extraction and  treat-
 ment systems for leachate and groundwater
 as well as capping options. Groundwater
 contamination at municipal landfill sites
 may vary in composition from that at other
 types  of sites in that it often contains high
 levels of organic matter and metals. Data
 gathered during the hydrogeologic investi-
 gation, however, are similar to those gath-
 ered at other types of NPL sites.

   Leachate generation is of specific con-
 cern when characterizing municipal landfill
 sites.  The main factors contributing to
 leachate quantity include precipitation as
 well as recharge from groundwater and
surface water. Information to  be gathered
during characterization of leachate gener-
ally may be limited to:

• Surface water drainage patterns

• Climatological characteristics (e.g., pre-
  cipitation and evapotranspiration)

                 1
 • Leachate characteristics (e.g., TCL or-
  ganics,  TAL metals, BOD, COD, pH,
  TDS, TSS, phosphorus, nitrogen, and oil
  and grease)
 • Identification of Class I and II aquifers
  and their associated water levels, flow
  rates, and chemistry
   In many  landfills, leachate is perched
 within the landfill contents, above the water
 table. The placement of a limited number of
 leachate wells in the landfill is an efficient
 means of gathering information regarding
 the depth, thickness, and types of waste, the
 moisture content and degree of decomposi-
 tion of the waste, leachate head levels, the
 composition of the leachate, and the eleva-
 tion  of  the underlying natural soil layer.
 Additionally, leachate wells provide good
 locations for landfill gas sampling. It should
 be noted that, without the proper precau-
 tions, placing wells into the landfill con-
 tents may create health and safety risks.
 Additionally, installation of wells through
 the landfill base may create conduits through
 which leachate can migrate to lower geo-
 logic strata. The installation of wells into
 landfill contents may also make it difficult
 to ensure  the reliability  of the sampling
 locations.

 Landfill Contents/Hot Spots
   Characterization of a municipal landfill's
contents generally is not necessary because
containment, which is often the most prac-
 ticable technology, does  not require such
information. Certain  data, however, are

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                                                          Figure 1
                              Potential Exposure  Pathways for Municipal  Landfills
CONTAMINANT
  SOURCE
                        CONTAMINANT
                     RELEASE/TRANSPORT
                                                                  SECONDARY
                                                                   RECEPTOR
Terrestrial
Wildlife


People Who
Consume Wildlife
 necessary to evaluate containment alterna-
 tives. These include:
 •  Contour maps
 •  Fill thickness, lateral extent, and age
 •  Estimate of landfill settlement rate
 •  Estimate of raleof landfill gasproduction
   and landfill gas composition
 •  Soil characteristics, including permeabil-
   ity, grain size, Atterbcrg limits, and ero-
   sion rates
 •  Climaticconditions.includingfrostdepth,
   and the appropriate storm event creating
   the potential for significant erosion
• Geologic and hydrogeologic characteris-
  tics, particularly the permeability of the
  layer underlying the landfill; the depth to
  groundwater; thickness of waste below
  the water table; and groundwater flow
  through the waste, if applicable
• Physical  characteristics cf any existing
  cap including thickness, area, slope sta-
  bility, evidence of freeze-thaw protec-
  tion, and soil characteristics as well as its
  ability to reduce surface gas emissions
  and odors, prevent oxygen intrusion into
  the refuse, prevent surface water infiltra-
  tion,  provide erosion control, and im-
  prove site aesthetics
• Potential future uses of the site (e.g.,
  residential or recreational use)

   More extensive characterization activi-
ties and development of remedial alterna-
tives (such as thermal treatment or stabiliza-
tion) may be appropriate for hot spots. Hot
spots consist of highly toxic and/or highly
mobile material and present a potential prin-
cipal threat to human health or the environ-
ment (see NCP Sec. 300.430 (a)(l)(iii)(C)).
Excavation or treatment of hot spots is
generally practicable where the waste type
or mixture of wastes is in a discrete, acces-
sible location of a landfill. A hot spot should
                                                                              be large enough  that its remediation will
                                                                              significantly reduce the threat posed by the
                                                                              overall site, but  small enough  that it is
                                                                              reasonable to consider removal and/or treat-
                                                                              ment.  It may generally be appropriate to
                                                                              excavate and/or treat the contents of a landfill
                                                                              where a low to moderate volume of toxic/
                                                                              mobile waste (e.g., 100,000 cy or less) poses
                                                                              a principal threat to human health and the
                                                                              environment.

                                                                                 Hot spots should be characterized if docu-
                                                                              mentation and/or physical evidence exists
                                                                              to indicate their presence and approximate
                                                                              location. Hot spots may be delineated using
                                                                              geophysical techniques or soil gas surveys
                                                                              and typically are confirmed by excavating
                                                                              test pits or drilling soil borings. When chnm
                                                                              acterizing hot spots, soil samples should^
                                                                              collected to  determine hot spot waste char-
                                                                              acteristics,  including  TAL metals,  TCL
                                                                              organics, RCRA waste characteristics (e.g.,

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TCLP), total Btu content, and bulk weight
of the material. Treatability or pilot testing
Biay be required to evaluate treatment alter-
natives.

Landfill Gas
   Several gases typically are generated by
decomposition of organic materials  in  a
landfill. The composition, quantity, and
generation rates of the gases depend on such
factors as refuse quantity and composition,
refuse placement characteristics, age of the
disposal unit, landfill depth, refuse mois-
ture content, and amount of oxygen present.
The principal gases generated by volume
are carbon dioxide, methane, trace thiols,
and occasionally, hydrogen sulfide. Vola-
tile organic compounds are also present in
         landfill gases, particularly  at co-disposal
         facilities.  Data generated during the site
         characterization of landfill gases should
         include:

         • Contour drawings and rate of settlement

         • Geologic and hydrogeologic characteris-
           tics, including permeability, moisture
           content, geologic strata, pH, depth  to
           bedrock, and depth to groundwater

         • Presence of offsite, subsurface migration

         • Surface emissions

         • Ambient air monitoring
         • Landfill gas characteristics, including
           composition, moisture content, quantity,
           temperature, and methane content
                                     Figure 2
                Technologies Frequently Implemented for
            Remedial Action at CERCLA Municipal Landfills
       REMEDIAL ACTION
         OBJECTIVE
REMEDIAL TECHNOLOGY
                                       Cap
                                      Disposal

                                   Thermal Treatment
                                   Physical Treatment
                                     Vertical Barrier
PROCESS OPTION
                                                              Soil Cover
                            Single Barrier
                                                             Double Barrier
                                   Leachate Collection
                                  Groundwater Collection
                                                             Consolidation
                             Incineration
                                                           Solidification/Fixation
                             Slurry Wall
                                                          Vertical Extraction Wells
                                                           Subsurface Drains
          Treat
       Contaminated
       Groundwater
       & Leachate a
                                  Chemical Treatment
                                  Biological Treatment
  Physical Treatment
                                    Offsite Treatment
                                    Passive Systems
                                    Active Systems
                                   Thermal Treatment
                                                           Metals Precipitation
                                                              Aerobic
                                                             Anaerobic
                             Adsorption
                                                             Air Stripping
                                                              POTW
                                                             RCRATSD
                                                              Pipe Vents
                                                             Trench Wells
                                                            Extraction Wells
                                                               Flaring
     • Other treatment technologies may be appropriate
Streamlining

The Baseline Risk

Assessment

   The purpose of the baseline risk assess-
ment is to determine whether a site poses
risks to human health and the environment
that are significant enough to warrant reme-
dial action. Because options for remedial
action at municipal landfill sites are limited,
it may be possible to streamline or limit the
scope of the baseline risk assessment by:
1.  Using the conceptual site model and RI-
    generated data, to perform a qualitative
    risk assessment that identifies contami-
    nants of concern in the affected media,
    their concentrations, and their hazard-
    ous properties which may pose a risk
    through the routes of exposure.
2.  Identifying  all pathways that are an
    obvious threat to human health or the
    environment (see Figure 1) by compar-
    ing Rl-derived contaminant concentra-
    tion levels to standards that are potential
    chemical-specific ARARs for the ac-
    tion. These may include: (1) Non-zero
    MCLGs  and MCLs for groundwater
    and leachate  and  (2) State air quality
    standards for landfill gases.
    When potential ARARs do not exist for
    a specific contaminant, risk-based
    chemical concentrations should be used.
3.  Where established standards for one or
    more contaminants in a  given medium
    are clearly exceeded, the basis for tak-
    ing remedial action is warranted (i.e.,
    quantitative assessments that consider
    all chemicals, their potential additive
    effects, or additivity of multiple expo-
    sure pathways are not necessary to initi-
    ate remedial action).
4.  In cases where clear exceedance of stan-
    dards does not occur, a more thorough
    risk assessment will be necessary prior
    to initiating remedial action.
   This streamlined approach may facili-
tate early action on the most obvious landfill
problems—groundwater  and  leachate,
landfill gas, and the landfill contents—while
analysis continues on other  problems such
as affected wetlands and stream sediments.
However, the effect of early action on obvi-
ous problems should be factored into any
ongoing risk assessment. For example, if
leachate seepage that had been contaminat-
ing surface water and wetlands is stopped as
a result of an early action, then the risk
assessment developed subsequently for the

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stream sediments and wetlands should as-
sume no further loading. Any early actions
also need to be designed for flexibility so
that they will be consistent with subsequent
actions. For example, it may be necessary to
adjust a groundwater pump-and-treat early
action designed to attain MCLs so that even
lower levels, determined  to be  necessary
under a subsequent risk  assessment,  are
achieved in the interest of protecting envi-
ronmental  receptors in  the  wetlands into
which the groundwater discharges.

   Ultimately, it will be necessary to dem-
onstrate that the final remedy, once imple-
                                        mented, will in fact address all pathways and
                                        contaminants of concern (including envi-
                                        ronmental risks), not just  those  that trig-
                                        gered the remedial action. The  approach
                                        outlined above facilitates rapid implementa-
                                        tion of protective, remedial measures for the
                                        major problems at a municipal landfill site.

                                        Streamlining
                                        The Development
                                        Of Alternatives

                                           Figure 2 identifies remedial technologies
                                        and process options for achieving various
                                     Figure 3
                       Landfill Cover Selection Guide
     LANDFILL CHARACTERISnCS
Minimal Hazardous Substances In
Landfill and Minimal Contamination
of Groundwater
 Significant Percentage of Hazardous*
 Substances In Fill Are Below the
 Water Table, And Lowering the
.Water Table Is not Practicable    J
  /Leaching of Hazardous Substances
  I to Groundwater Is Expected to
  I Contribute to Unacceptable Human
  I Health or Environmental Risks, and
  I Reliability of Single Barrier Is
  I Considered Adequate c
                                      REMEDIAL OBJECTIVES
:Prevent Direct Contact;^
                                       Minimize Erosion a    I
                                                            C
                                                                   COVERTYPE
    Native Soil Cover
                                    Prevent Direct Contacts
                                    Minimize Erosion;
                                    Minimize Infiltration   )
C
                                                                  Single Barrier Cap b 1
    Significant Contaminant Mass
    In Fill, and Risks of Hazardous
    Substances Leaching to
    Groundwater Are Great
                                       Prevent Direct Contact; |
                                       Minimize Erosion;     |
                                       Prevent Infiltration    J
                                                            C
   Double Barrier Cap
    High Degree of Reliability Needed
    In Method of Minimizing Leaching
    of Hazardous Substances to
    Groundwater
     Primary objective )• to prevent direct contact, although the soil cover can be designed to reduce
     intltlratlon.

     Single barrier cap< may Include additional layers that provide protection to that barrier.

     Examples Include iltuatlon* where Infiltration Is not the primary concern and may Include sites
     containing • small volume of contaminant mass, regions with low annual precipitation, or sites
     where groundwater Is not being used as a source of drinking water.
 remedial action objectives pertaining to mu-
 nicipal landfill sites. The following points
 should be considered in order to streamline
 the development of remedial action altern^
 lives:

 •  The most practicable remedial alternative
   for  landfills is generally containment.
   Figure 3 is a simplified decision tree for
   identifying the appropriate type of cap.

 •  Treatment of soils  and wastes may be
   practicable for hot spots. Consolidation
   of hot spot materials under a landfill cap
   is a potential alternative in cases when
   treatment is not practicable or necessary.

 •  Extraction and treatmentof contaminated
   groundwaterandleachatemay be required
   to control offsite migration of wastes.
   Collection and treatment may be neces-
   sary for an  indefinite  amount of time
   because of continued contaminant load-
   ings from the landfill.

•  Constructing an active landfill gas collec-
   tion and treatment system should be con-
   sidered in the following situation: (1)
   when existing or planned structures may
   be adversely affected through either ex-
   plosion or inhalation hazards, (2) when
   final  use  of  the site includes  allowirj
   public access,  or  (3) when the land
   produces excessive odors. Most landfills
   will require at least a passive gas collec-
   tion (i.e.,  venting) system  to  prevent
   buildup of pressure below the cap and to
  prevent damage to the vegetative cover.

   Onsite remedial  actions at municipal
landfill sites must comply with all ARARs
of other environmental statutes, unless a
waiver can be justified. The most signifi-
cant ARARs for municipal landfills include:
• RCRA closure requirements (Subtitle D
  requirements will be applicable unless
   Subtitle C is determined to be applicable
  orrelevantand appropriate; see CERCLA
   Compliance  with  Other Laws Manual,
   August 1988, for information on how to
   make these determinations.)

•  More stringent state closure requirements
•  Federal or state requirements pertaining
   to landfill gas emissions
                                                                                                                         wind
                                                                                                                         ndfH
  NOTICE: The policies and procedures set out in this document are intended solely for the guidance of response personnel. They are not intended,
  nor can they be relied upon, to create any rights, substantive or procedural, enforceable by any party in litigation with the United States. EPA of-
  ficials may decide to follow this guidance, or to act at variance with these policies and procedures based on an analysis of specific site circum-
  stances, and to change them at any time without public notice.

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