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 ------- 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., ------- 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 ------- 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. ------- |