United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Directive No.9355.0-67FS
EPA/540/F-96/020
PB96-963314
December 1996
Application of the CERCLA
Municipal Landfill Presumptive
Remedy to Military Landfills
Federal Facilities Restoration and Reuse Office
Mail Code 5101
Quick Reference Fact Sheet
Presumptive remedies are preferred technologies for common categories of sites based on historical patterns of
remedy selection and the U.S. Environmental Protection Agency's (EPA's) scientific and engineering evaluation of
performance data on technology implementation. By streamlining site investigation and accelerating the remedy
selection process, presumptive remedies are expected to ensure the consistent selection of remedial actions and reduce
the cost and time required to clean up similar sites. Presumptive remedies are expected to be used at all appropriate
sites. Site-specific circumstances dictate whether a presumptive remedy is appropriate at a given site.
EPA established source containment as the presumptive remedy for municipal landfill sites regulated under the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) in September of 1993 (see the
directive Presumptive Remedy for CERCLA Municipal Landfill Sites). The municipal landfill presumptive remedy
should also be applied to all appropriate military landfills. This directive highlights a step-by-step approach to
determining when a specific military landfill is an appropriate site for application of the containment presumptive
remedy. It identifies the characteristics of municipal landfills that are relevant to the applicability of the presumptive
remedy, addresses characteristics specific to military landfills, outlines an approach to determining whether the
presumptive remedy applies to a given military landfill, and discusses administrative record documentation
requirements.
PURPOSE
This directive provides guidance on applying the con-
tainment presumptive remedy to military landfills.
Specifically, this guidance:
• Describes the relevant characteristics of munici-
pal landfills for applicability of the presumptive
remedy;
• Presents the characteristics specific to military
installations that affect application of the presump-
tive remedy;
• Provides a decision framework to determine appli-
cability of the presumptive remedy to military
landfills; and
• Provides relevant contacts/specialists in military
wastes, case histories, administrative record docu-
mentation requirements, and references.
BACKGROUND
Municipal landfills are those facilities in which a
combination of household, commercial and, to a lesser
extent, industrial wastes have been co-disposed. The
presumptive remedy for municipal landfills - source
containment - is described in detail in the directive
Presumptive Remedy for CERCLA Municipal Landfill
Sites. Highlight 1 outlines the components of the con-
tainment presumptive remedy. Highlight 2 lists the
characteristics of municipal landfills that are compatible
with the presumptive remedy of containment
Highlight 1
Components of the Containment
Presumptive Remedy
• Landfill cap
• Source area groundwater control to
contain plume
• Leachate collection and treatment
• Landfill gas collection and treatment
• Institutional controls to supplement
engineering controls
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Highlight 2
Appropriate Municipal Landfill
Characteristics for Applicability
of the Presumptive Remedy
Risks are low-level, except for "hot spots"
Treatment of wastes is usually impractical due
to the volume and heterogeneity of waste
Waste types include household, commercial,
nonhazardous sludge, and industrial solid
wastes
Lesser quantities of hazardous wastes are
present as compared to municipal wastes
Land application units.surface impoundments,
injection wells, and waste piles are not included
The presumptive remedy process involves streamlining
of the remedial investigation/feasibility study (RI/FS)
or, for non-time-critical removals, an Engineering
Evaluation/Cost Analysis (EE/CA) by:
• Relying on existing data to the extent possible rather
than characterizing landfill contents (limited or no
landfill source investigation unless there is informa-
tion indicating a need to investigate hot spots);
• Conducting a streamlined risk assessment; and
Developing a focused feasibility study that analyzes
only alternatives consisting of appropriate compo-
nents of the presumptive remedy and, as required
by the National Contingency Plan, the no action
alternative.
Several directives, including Presumptive Remedy for
CERCLA Municipal Landfill Sites, Conducting Remedial
Investigations/Feasibility Studies for CERCLA Munici-
pal Landfill Sites, and Streamlining the RI/FS for
CERCLA Municipal Landfill Sites, provide a complete
discussion of these streamlining principles.
USE OF THIS GUIDANCE
EPA anticipates that the containment presumptive
remedy will be applicable to a significant number of
landfills found at military facilities. Although waste
types may differ between municipal and military land-
fills, these differences do not preclude use of source
containment as the primary remedy at appropriate
military landfills.
Additionally, EPA continues to seek greater consistency
among cleanup programs, especially in die process of
selecting response actions for sites regulated under
CERCLA and corrective measures for facilities regu-
lated under the Resource Conservation and Recovery
Act (RCRA). In general, even though the Agency's
presumptive remedy guidances were developed for
CERCLA sites, they should also be used at RCRA
Corrective Action sites to focus RCRA Facility Investi-
gations, simplify evaluation of remedial alternatives in
the Corrective Measures Study, and influence remedy
selection in the Statement of Basis. For more infor-
mation, refer to the RCRA Corrective Action Plan,
the proposed Subpart S regulations, and the RCRA
Corrective Action Advance Notice of Proposed Rule-
making.
CHARACTERISTICS OF MILITARY
LANDFILLS
The size of the landfill and the presence, proportion,
distribution, and nature of wastes are fundamental to the
application of the containment presumptive remedy to
military landfills.
An examination of 31 Records of Decisions (RODs) that
document the remedial decisions for 51 landfills at
military installations revealed that no action was chosen
for 10 landfills and remedial actions were chosen at 41
landfills (see Appendix). Of these 41 landfills, contain-
ment was selected at 23 (56 percent). For the remaining
18 landfills where other remedies were selected, institu-
tional controls only were selected at three landfills,
excavation and on-site consolidation were selected at
four landfills, and excavation and off-site disposal were
selected for 11 landfills.
The military landfills examined in the 51 RODs men-
tioned above ranged in size from 100 square feet to 150
acres and contained a wide variety of waste types. Of
the 41 landfills for which remedial actions were chosen,
14 (34 percent) were one acre or less in size; containment
was not selected for any of these landfills. Containment
was chosen at 23 (85 percent) of the 27 landfills that
were greater than one acre in size. This information
suggests that the size of the landfill area is an important
factor in determining the use of source containment at
military landfills.
The wastes most frequently deposited at these military
landfills were municipal-type wastes: household, com-
mercial (e.g., hospital wastes, grease, construction
debris), and industrial (e.g., process wastes, solvents,
paints) wastes. Containment was the remedy selected at
the majority of these sites. Military-specific wastes (e.g.,
munitions) were found at only 5 of the 51 landfills (10
percent).
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Highlight 3 lists typical municipal and military wastes,
'. including:
(1) Wastes that are common to both municipal landfills
and military landfills;
(2) Wastes that are usually specific to military bases
but that do not necessarily pose higher risks man
other industrial wastes commonly found in mun-
icipal landfills (i.e., low-hazard military-specific
wastes), depending on the volume and heterogeneity
of the wastes; and
(3) High-hazard military wastes that, because of their
unique characteristics, would require special consi-
deration (i.e., high-hazard military-specific wastes).
The proportion and distribution of hazardous wastes in a
landfill are important considerations. Generally, muni-
cipal landfills produce low-level threats with occasional
hot spots. Similarly, most military landfills present only
low-level threats with pockets of some high-hazard
waste. However, some military facilities (e.g., weapons
fabrication or testing, shipbuilding, major aircraft or
equipment repair depots) have a high level of industrial
activity compared to overall site activities. In these cases,
there may be a higher proportion and wider distribution
of industrial (i.e., potentially hazardous) wastes present
than at other less industrialized facilities.
PRACTICAL CONSIDERATIONS
Sensitive Environments
Site-specific conditions may limit the use of the contain-
ment presumptive remedy at military landfills. For
example, the presence of high water tables, wetlands
and other sensitive environments, and the possible
destruction or alteration of existing habitats as a result
of a particular remedial action could all be important
factors in the selection of the remedy.
Land Use
Reasonably anticipated future land use is also an impor-
tant consideration at all sites. However, at military bases
undergoing base closure procedures, where expedi-
tiously converting property to civilian use is one of the
primary goals, land use may receive heightened atten-
tion. Thus, at bases that are closing, it is particularly
important for reuse planning to proceed concurrently
with environmental investigation and restoration activ-
ities. The local reuse group is responsible for developing
the preferred reuse alternatives. The Base Realignment
and Closure Team should work closely with the reuse
group to integrate reuse planning into the cleanup
process, where practicable (see the Land Use in CERCLA
Remedy Selection directive).
Highlights
Examples of Municipal-Type
and Military-Specific Wastes
Municipal-Type Wastes
Municipal landfills contain predominantly non-
hazardous materials. However, industrial solid waste
and even some household refuse (e.g., pesticides,
paints, and solvents) can possess hazardous
components. Further, hazardous wastes are found in
most municipal landfills as a result of past disposal
practices.
Predominant Constituents
Household refuse, garbage, and debris
Commercial refuse, garbage, and debris
Construction debris
Yard wastes
Found In Low Proportion
Asbestos
Batteries
Hospital wastes
Industrial solid waste(s)
Paints and paint thinner
Pesticides
Transformer oils
Other solvents
Military-Specific Wastes
The majority of military landfills contain primarily
nonhazardous wastes. The materials listed in this
column are rarely predominant constituents of
military landfills.
These types of wastes are specific to military bases
but generally are no more hazardous than some
wastes found in municipal landfills.
Low-ievef radioactive wastes
Decontamination kits
Munitions hardware
aT-Specific Wastes
These wastes are extremely hazardous and may
possess unique safety, risk, and toxicity character-
istics. Special consideration and expertise are
required to address these wastes.
Military Munitions
Chemical warfare agents
(e.g., mustard gas, tear agents)
Chemical warfare agent training kite
Artillery, small arms, bombs
Other military chemicals
(e.g., demolition charges,
pyrotechnics, propellants)
Smoke grenades
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Highlight 4
Decision Framework
Collect Available Information
• Waste Types
• Operating History
• Monitoring Data
• State Permit/Closure
• Land Reuse Plans
• Size/Volume
• Number of Facility Landfills
Consider Effects of Land
Reuse Plans on Remedy
Selection
Note: Site-specific
factors such as
hydrogeotogy, volume,
cost, and safety affect the
practicality of excavation
of landfill contents.
Do Landfill
Contents Meet
Municipal-Type
Waste
Definition?
Military-Specific Wastes
Are Present; Consult
With Military Waste Experts
Containment
the Most
Appropriate
Remedy?
DonfUse
Containment
Presumptive
Remedy
(A conventional
RI/FS is required.)
Note: Site investigation
or attempted treatment
may not be appropriate;
these activities may
cause greater risk than
leaving waste in place.
USE CONTAINMENT PRESUMPTIVE REMEDY
(A streamlined risk assessment and
focused feastoility study are used.)
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DECISION FRAMEWORK TO
EVALUATE APPLICABILITY OF
THE PRESUMPTIVE REMEDY
TO MILITARY LANDFILLS
This Section and Highlight 4 describe the steps involved
in determining whether the containment presumptive
remedy applies to a specific military landfill.
1. What Information Should Be Collected? Determine
the sources, types, and volumes of landfill wastes using
historical records, state files, closure plans, available
sampling data, etc. This information should be sufficient
to determine whether source containment is the appro-
priate remedy for the landfill. If adequate data do not
exist, it may be necessary to collect additional sampling
or monitoring data. The installation point of contact
(environmental coordinator, base civil engineer, or
public works office) should be contacted to obtain
records of disposal practices. Current and former em-
ployees are also good sources of information.
2. How May Land Reuse Plans Affect Remedy
Selection? For smaller landfills (generally less than
two acres), land reuse plans may influence the decision
on the practicality of excavation and consolidation or
treatment of landfill contents. Excavation is a remedial
alternative that is fundamentally incompatible with the
presumptive remedy of source containment.
3. Do Landfill Contents Meet Municipal Landfill-Type
Waste Definition? To determine whether a specific
military landfill is appropriate for application of the
containment presumptive remedy, compare the char-
acteristics of die wastes to the information in Highlights
2 and 3.
4. Are Military-Specific Wastes Present? Military
wastes, especially high-hazard military wastes, may
possess unique safety, risk, and toxicity characteristics.
Highlight 3 presents examples of these types of ma-
terials. If historical records or sampling data indicate
that these wastes may have been disposed at the site,
special consideration should be given to their handling
and remediation. Caution is warranted because site
investigation or attempted treatment of these con-
taminants may pose safety issues for site workers and
the community. Some high-hazard military-specific
wastes could be considered to present low-level risk,
depending on the location, volume, and concentration of
these materials relative to environmental receptors.
Consult specialists in military wastes (see Highlight 5)
when determining whether military-specific wastes at a
site fall into either the low-hazard or the high-hazard
military-specific waste category found in Highlight 3.
Highlights
Specialists in Military Wastes
The installation point of contact will notify the
major military command's specialists in military
wastes (Explosive Ordnance Disposal Team) for
assistance with regard to safety and disposal
issues related to any type of military items.
Army chemical warfare agents specialists:
• Project Manager, Non-Stockpile Chemical
Materiel, Aberdeen Proving Ground, Maryland
21010-5401, (410) 671-1083.
Navy ordnance related items specialists:
• The Navy Ordnance Environmental Support
Office, Naval Surface Warfare Center, Indian
Head, Maryland 20460-5035, (301) 743-4S34/
4906/4450.
Navy low-level radioactive wastes specialists:
• The Naval Sea Systems Command
Detachment, Radiological Affairs Support
Office, Yorktown, Virginia 23691-0260,
(804)887-4692.
Air Force ordnance specialists:
• The Air Force Civil Engineering Support
Agency, Contingency Support Division,
Tyndall AFB, Florida 32403-5319,
(904)283-6410.
Responsibilities for response are clearly spelled out in
the regulation Interservice Responsibilities For Explo-
sive Ordnance Disposal.
5. Is Excavation of Contents Practical? The volume
of landfill contents, types of wastes, hydrogeology, and
safety must be considered when assessing the practicality
of excavation and consolidation or treatment of wastes.
Consideration of excavation must balance the long-term
benefits of lower operation and maintenance costs and
unrestricted land use with the initial high capital con-
struction costs and potential risks associated with
excavation. Although no set excavation volume limit
exists, landfills with a content of more than 100,000
cubic yards (approximately two acres, 30 feet deep)
would normally not be considered for excavation. If
military wastes are present, especially high-hazard
military wastes such as ordnance, safety considerations
may be very important in determining the practicality of
excavation.
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If excavation of the landfill contents is being considered
as an alternative, the presumptive remedy should not be
used. Therefore, a standard RI/FS would be required to
adequately analyze and select the appropriate remedial
actions.
6. Can the Presumptive Remedy Be Used? The site
manager will make the initial decision of whether a
particular military landfill site is suitable for the presum-
ptive remedy or whether a more comprehensive RI/FS is
required. This determination must be made before the
RI/FS is initiated. This decision will depend on whether
the site is a potential candidate for excavation, and if
not, whether the nature of contamination is such that a
streamlined risk evaluation can be conducted.* A site
generally is eligible for a streamlined risk evaluation if
groundwater contaminant concentrations clearly exceed
chemical-specific standards or the Agency's level of risk
or if other conditions exist that provide a justification
for action (e.g., direct contact with landfill contents due
to unstable slopes). If these conditions do not exist, a
quantitative risk assessment that addresses all exposure
pathways will be necessary to determine whether action
is needed. Before work on the RI/FS workplan is
initiated, the community and state should be notified
that a presumptive remedy is being considered for die
site. It is important for all stakeholders to understand
completely how the presumptive remedy process varies
from the usual clean-up process, and the benefits of using
the presumptive remedy process.
TREATING "HOT SPOTS"
The presumptive remedy also allows for the treatment
of hot spots containing military-specific (or other) waste.
While the analysis, Feasibility Study Analysis for
CERCLA Municipal Landfill Sites, that justified the
selection of source containment as the presumptive
remedy for municipal landfill sites did not specifically
take into account high-hazard military wastes, the high-
hazard materials present in some military landfills may
be compared to the hazardous wastes at municipal
landfills and could potentially be treated as hot spots.
For further information and case studies on treatment of
hot spots, see the Presumptive Remedy for CERCLA
Municipal Landfill Sites directive.
CASE HISTORIES
The case histories below illustrate how use of the
municipal landfill presumptive remedy at military
landfills follows the decision framework in Highlight 4.
' See Role of the Baseline Risk Assessment in Superfiind Remedy
Selection Decisions, which states that if MCLs or non-zero
MCLGs are exceeded [a response] action generally is warranted.
The decision to use the presumptive remedy can be made
for one landfill or as a part of a site-wide strategy (as in
the Loring Air Force Base example below), depending
on factors such as the nature of the wastes, size of the
landfill, land reuse potential, and public acceptance.
The following case histories present examples of where
the containment presumptive remedy was or was not
applied, based on site-specific conditions.
Disposal of Municipal-Type Wastes
The Naval Reactor Facility (NRF) site in Idaho Falls,
Idaho, was established in 1949 as a testing site for the
nuclear propulsion program. The three landfill units at
the site received solid wastes similar to municipal
landfills. These wastes included petroleum and paint
products, construction debris, and cafeteria wastes.
Historical records do not indicate that any radioactive
wastes were disposed of in these landfill units. The
Delected remedy for the landfills at the site included the
installation of a 24-inch native soil cover designed to
incorporate erosion control measures to reduce the
effects from rain and wind. The remedy also provided
for maintenance of the landfill covers, including sub-
sidence correction and erosion control. Monitoring of
the landfills will include sampling of soil gas to assess
the effectiveness of the cover and sampling of the
groundwater to ensure that the remedy remains pro-
tective. Institutional controls will also be implemented
to prevent direct exposure to the landfill. The NRF site
is an example of where the streamlining principles of
die presumptive remedy process, including a streamlined
risk assessment and a focused feasibility study, were
successfully employed.
Co-Disposal of High-Hazard Wastes
At the Massachusetts Military Reservation, in Cape
Cod, Massachusetts, anecdotal information indicated
that munitions had been disposed of at an unidentified
location in a landfill that primarily contained municipal-
type waste. Ground penetrating radar was utilized to
determine if there were any discrete disposal areas
containing potential hot spots at this site and found none.
Because die munitions waste was not in a known discrete
and accessible area, it could not be treated as a hot spot.
Consequently, without excavating or treating the muni-
tions waste as a hot spot, the authorities decided to cap
the landfill. In this case, the streamlining principles of
the presumptive remedy process were applied. For
example, site investigation was limited and treatment
options were not considered.
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Land Reuse Considerations
At Loring Air Force Base, a closing base in Limestone,
Maine, base landfills 2 and 3 (9 and 17 acres, respective-
ly) consisted primarily of municipal and flightline
wastes. The selected remedy for these landfills included
a multi-layer cap, passive venting system, and institu-
tional controls. The RODs for the landfills, signed in
September 1994, required placing a RCRA Subtitle C
cap on the landfills. To construct the RCRA cap, the
designers estimated that 400,000 to 600,000 cyds of
material would have to be placed on the landfills prior to
construction of the cap to ensure proper drainage and
slopes.
At Loring, the streamlining principles of the containment
remedy, a focused feasibility study, and a streamlined
risk assessment were applied for landfills 2 and 3.
Additionally, the RODs signed for these landfills speci-
fied that excavated material from other parts of the base
would be used at the landfills to meet subgrade design
specifications. To date, more than 500,000 cyds of
contaminated soils have been excavated and used as sub-
grade for the landfills (after demonstrating compliance
with RCRA Land Disposal Restrictions). In addition to
cost savings realized by providing subgrade, other
benefits have been realized, such as limiting the number
of parcels requiring deed restrictions and minimising
locations requiring operation and maintenance. At this
base, the landfill consolidation efforts resulted in an
estimated total cost savings of $12-20 million while
incorporating future land use considerations into the
decision process.
The Brunswick Naval Air Station in Brunswick,
Maine, contained several landfill sites. One of the first
RODs signed, for Sites 1 and 3, called for construction
of a 12-acre RCRA Subtitle C cap and a slurry wall, as
well as for groundwater extraction and treatment.
Subsequently, during the remedy selection process for
Site 8, the public objected to containment as the proposed
remedy for this relatively small (0.6 acre) site on the
grounds that should the base eventually close, contain-
ment would create several useless parcels of land. After
public comment, the Navy reconsidered, proposing
instead to excavate Site 8 and consolidate the removed
materials (which consisted of construction debris and
soil contaminated with nonhazardous levels of poly-
cyclic aromatic hydrocarbons) as part of the necessary
subgrade fill for the landfill cap to be constructed at
Sites 1 and 3. In this case, land reuse considerations
preempted the selection of a containment remedy.
PRESUMPTIVE REMEDY
ADMINISTRATIVE RECORD
DOCUMENTATION REQUIREMENTS
As stated earlier, it must be determined whether the
military landfill in question contains military-specific
wastes, as described in Highlight 3. This should be
followed by a determination of whether anything about
these wastes would make the engineering controls
specified in the presumptive remedy for municipal
landfills less suitable at that site. These determinations
must be documented in the administrative record, which
supports the final decision. This information, in turn,
will assist the public in understanding the evaluation of
the site as a candidate for use of the presumptive remedy
and the advantage it provides. For further reference, the
administrative record requirements for all Superfund
sites including military landfills are explained in the
Final Guidance on Administrative Records for Selecting
CERCLA Response Actions.
The administrative record must contain the following
generic and site-specific information, which documents
the selection or non-selection of the containment pre-
sumptive remedy.
Generic Information
A. Generic Documents. These documents should be
placed in the docket for each federal facility site
where the containment presumptive remedy is
selected. Each EPA Regional Office has copies of
the following presumptive remedy documents:
• Presumptive Remedy: Policy and Procedures
• Presumptive Remedy for CERCLA Municipal
Landfill Sites
• Application of the Municipal Landfill Pre-
sumptive Remedy to Military Landfills
• Feasibility Study Analysis for CERCLA Muni-
cipal Landfill Sites
B. Notice Regarding Backup File. The docket should
include a notice specifying the location of and times
when public access is available to the generic file of
backup materials used in developing the Feasibility
Study Analysis for CERCLA Municipal Landfill
Sites. This file contains background materials such
as technical references and portions of the feasi-
bility studies used in the generic study. Each EPA
Regional Office has a copy of this file.
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Site-specific Information
Focused FS or EE/CA. Military-specific wastes need
to be addressed in site-specific analyses when determin-
ing the applicability of the containment presumptive
remedy to military landfills. High-hazard military-
specific waste materials (e.g., military munitions) require
special consideration when applying the presumptive
remedy.
As noted on pages 1 and 2 of this directive, the pre-
sumptive remedy approach allows you to streamline and
focus the FS or EE/CA by eliminating the technology
screening step from the feasibility study process. EPA
has already conducted this step on a generic basis in the
Feasibility Study Analysis for CERCLA Municipal
Landfill Sites. Thus, the FS analyzes only alternatives
comprised of components of the containment remedy
identified in Highlight 1. In addition, the focused FS or
EE/CA should include a site-specific explanation of how
the application of the presumptive remedy satisfies the
National Contingency Plan's three site-specific remedy
selection criteria (i.e., compliance with state applicable
or relevant and appropriate requirements, state accept-
ance, and community acceptance).
CONCLUSION
This directive provides guidance for the use of the
containment presumptive remedy at appropriate military
landfills. The remedies selected at numerous military
installations indicate that source containment is appli-
cable to a significant number of military landfills. These
landfills need not be identical to municipal landfills in
all regards. Key factors determining whether the con-
tainment presumptive remedy should be applied to a
specific military landfill include the size of the landfill;
volume and the type of landfill contents; future land use
of the area; and the presence, proportion, and distribution
of military-specific wastes.
REFERENCES
California Base Closure Environmental Committee, Inte-
grating Land Use and Cleanup Planning at Closing Bases,
December 1994.
Federal Register, 1996. Volume 61, No. 85, May 1,1996;
Corrective Action for Releases from Solid Waste Manage-
ment Units at Hazardous Waste Management Facilities,
Advance Notice of Proposed Rulemakuig.
Federal Register, 1990. Volume 55, No. 145, Jury 27,1990;
40 CFR Parts 264,265,270 and 271; Corrective Action for
Solid Waste Management Units at Hazardous Waste Facili-
ties; Proposed (proposed Subpart S regulations).
U.S. Environmental Protection Agency, OSWERDirective
93557-04, Land Use in the CERCLA Remedy Selection,
May 25,1995.
U.S. Environmental Protection Agency, OSWERDirective
9356.0-Q3,EPA/54Q/R-94/OBl, Feasibility Study Analy-
sis for CERCLA Municipal Landfill Sites, August 1994.
U.S. Environmental Protection Agency, OSWERDirective
99023-2A.EPA/520/R-94/004, RCRA Corrective Action
Plan. May 1994.
U.S. Environmental Protection Agency, OSWERDirective
9355.0-49FS, Presumptive Remedy for CERCLA Muni-
cipal Landfill Sites, September 1993.
U.S. Environmental Protection Agency, OSWERDirective
9355.0-47FS, EPA/540/F-93/047, Presumptive Remedy:
Policy and Procedures, September, 1993.
U.S. Environmental Protection Agency, OSWER Publi-
cation 9380.3-06FS, Guide to Principal Threat and Low
Level Threat Wastes, November 1991.
U.S. Environmental Protection Agency, OSWERDirective
9355.0-30, Role of the Baseline Risk Assessment in Super-
fimd Remedy Selection Decisions, April 22,1991.
U.S. Environmental Protection Agency, OERR, EPA/540/
P-91/001, Conducting Remedial Investigations/Feasibility
Studies for CERCLA Municipal Landfill Sites, February
1991.
U.S. EnvironmentalProtection Agency, OSWERDirective
9833.3 A.1, Final Guidance on Administrative Records for
Selecting CERCLA Response Actions, December 3,1990.
U.S. EnvironmentalProtection Agency, OSWERDirective
93553-11FS, Streamlining the RI/FSfor CERCLA Muni-
cipal Landfill Sites, September 1990.
U.S. Department of Navy, Interservice Responsibilities
for Explosive Ordnance Disposal OPNAVINST 8027.1G
(also known as MCO 8027. ID, AR 75-14; or APR 32-
3002), February 14,1992.
NOTICE
The policies set out hi this document are intended
solely as guidance to the EPA personnel; they are not
final EPA actions and do not constitute rulemaking.
These policies are not intended, nor can they be relied
upon, to create any rights enforceable by any party in
litigation with the United States. EPA officials may
decide to follow the guidance provided in this docu-
ment, or to act at variance with the guidance, based on
an analysis of specific site circumstances. EPA also
reserves the right to change this guidance at any time
without public notice.
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DATA SUMMARY TABLE FOR MILITARY LANDFILLS APPENDIX
ROD/Site Name, State,
Region, ROD Sign Date
Disposal Area, Size,
Volume of Waste
Type of Waste
Deposited
Contaminants of
Concern
Remedy
Brunswick NAS, Sites 1
and3(OU1), ME,
Region 1
6/16/92
Site 1,8.5 acres; Site 3,1.5
acres. Sites are in close
proximity and not easily
distinguishable; the
combined volume of Sites 1
and 3 Is 300.000 cy
Household refuse, waste
oil, solvents, pesticides,
paints, isopropyl alcohol
Metals, VOCs,
PAHs, RGBs,
pesticides
Remedy: Capping (permanent, low-permeability, RCRA Subtitle
C cap), of 12 acres with a slurry wall and pump and treat ground
water within cap and slurry wall.
Brunswick NAS, Sites 5
and6(OU3), ME,
Region 1
8/31/93
Site 5, 0.25 acres, 12 cy
Asbestos-covered pipes
Asbestos
Remedy: Excavation, containerization, and transport to landfill
Sites 1 and 3 for use as fill under cap.
Brunswick NAS, Sites 5
and 6 (OU3), ME,
Region 1
8/31/93
Site 6,1.0 acre, 8,800-
18,700 cy
Construction debris, and
aircraft parts, asbestos
pipes
Asbestos
Remedy: Excavation, containerization, and transport to Sites 1
and 3 landfill for use as fill under cap.
Brunswick NAS, Site 8
(OU4), ME, Region 1
8/31/93
Site 8,0.6 acres, 5,600 •
14,000 cy
Rubble, debris, trash, and
possibly solvents
Metals,
pesticides, PCBs1
Remedy: Excavation, containerization, and transport to landfill
Sites 1 and 3 for use as fill under cap.
Loring AFB, Landfills 2
and 3 (OU2), ME,
Region 1
9/30/94
Landfill 2, 9 acres
Domestic waste,
construction debris,
flightline wastes, sewage
sludge and oil-filled
switches
PCBs, VOCs,
SVOCs, metals,
DDT1
Remedy: Capping (low-permeability cover system which meets
RCRA Subtitle C and Maine hazardous waste landfill cap
requirements), passive gas venting system and controls, and
institutional controls.
Loring AFB, Landfills 2
and 3 (OU2), ME,
Region 1
9/30/94
Landfill 3,17 acres
Waste oil/fuels, solvents,
paints, thinners, and
hydraulic fluids
VOCs, SVOCs,
DDT, PCBs,
metals1
Remedy: Capping (low-permeability cover system which meets
RCRA Subtitle C and Maine hazardous waste landfill cap
requirements), passive gas venting system and controls, and
institutional controls.
1
Contaminants of Potential Concern
A-l
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DATA SUMMARY TABLE FOR MILITARY LANDFILLS APPENDIX (CONT.)
ROD /Site Name, State,
Region, ROD Sign Date
Newport Naval Education
and Training Center,
McAllister Point Landfill,
Rl, Region 1
9/27/93
Otis Air National Guard,
Camp Edwards,
Massachusetts Military
Reservation, MA,
Region 1
1/14/93
Pease AFB(OU1),NH,
Region 1
9/27/93
Fort Dix Landfill Site, NJ,
Region 2
9/24/91
Naval Air Engineering
Center (OU3), NJ,
Region 2
9/16/91
Naval Air Engineering
Center (OU3),NJ,
Region 2
9/16/91
Disposal Area, Size,
Volume of Waste
McAllister Point Landfill,
11. 5 acres
Landfill Number 1 (LF-1),
100 acres
LF-5, 23 acres
Main area, 126 acres
Site 26, 1500 sq. ft., volume
not reported
Site 27, 6.4 acres
Type of Waste
Deposited
Domestic refuse, spent
acids, paints, solvents,
waste oils, and PC6-
contaminated transformer
oil
General refuse, fuel tank
sludge, herbicides, blank
ammunition, paints, paint
thinners, batteries, DDT,
hospital wastes, sewage
sludge, coal ash, possibly
live ordnance
Domestic and industrial
wastes, waste oils and
solvents, and industrial
wastewater treatment
plant sludge
Domestic waste, paints
and paint thinners,
demolition debris, ash,
and solvents
Oil, roofing materials,
building debris
Scrap steel cable
Contaminants of
Concern
VOCs, PAHs,
PCBs, pesticides,
phenols, metats
VOCs, SVOCs,
inorganics
VOCs, PAHs,
arsenic and other
metals
VOCs, metals
No contamination
was detected
No contamination
was detected
Remedy
Remedy: Capping (RCRA Subtitle C, multi-layer cap), landfill gas
management, surface controls, and institutional controls.
Remedy: Capping (composite-low-permeability cover system),
institutional controls, soil cover inspection, and ground water
monitoring.
Remedy: Excavation, dewatering and consolidation and
regrading of waste under a composite-barrier type cap,
institutional controls, and extraction and treatment of ground water
with discharge to base wastewater treatment facility.
Remedy: Capping 50-acre portion (New Jersey Administrative
Code 7:26 closure plan for hazardous waste), installing gas
venting system and an air monitoring system, ground water,
surface water, and air monitoring, and institutional controls.
Remedy: Source: No action.
Remedy: Source: No action.
A-2
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DATA SUMMARY TABLE FOR MILITARY LANDFILLS APPENDIX (CONT.)
ROD /Site Name, State,
Region. ROD Sign Date
Disposal Area, Size,
Volume of Waste
Type of Waste
Deposited
Contaminants of
Concern
Remedy
Naval Air Engineering
Center (OU17), NJ,
Region 2
9/26/94
Site 29,20 acres
Construction debris,
metal, asbestos, solvents,
other miscellaneous
wastes
VOCs, SVOCs,
metals
Remedy: Source: No action.
Pittsburgh AFB, LF-022,
NY, Region 2
9/30/92
LF-022, approx. 13.7 acres,
approx. 524,000 cy
Household refuse
Metals, pesticides
Remedy: Capping (NY State requirements for solid waste
landfills, 12 inch soil cap), and institutional controls.
Pittsburgh AFB, LF-023,
NY, Region 2
9/30/92
LF-023, approx. 9 acres,
approx. 406,000 cy
Household refuse, debris,
car parts
Metals, VOCs,
SVOCs, PCB,
pesticides
Remedy: Capping (NY State requirements for solid waste
landfills, low permeability cap), and institutional controls.
U.S. Army Aberdeen
Proving Grounds (OU 1),
MD, Region 3
Michaelsville Landfill, 20
acres, greater than
100,000 cy
Household refuse, limited
quantities of industrial
waste, burned sludges,
pesticide containers,
paint, asbestos shingles,
solvents, waste motor
oils, grease, PCB
transformer oils, possible
pesticides
Metals,
pesticides, VOCs,
PCBs, PAHs
Remedy: Capping (multi-layer cap in accordance with MDE
requirements for sanitary landfills, using a geosynthetic
membrane, 0-2 feet compacted earth material), surface water
controls, and gas venting system.
6/30/92
Marine Corps Base,
CampLejeune(OUI),
NC, Region 4
9/15/94
Site 24,100 acres, volume
not reported
Fly ash, cinders, solvents,
used paint stripping
compounds, sewage
sludge, spiractor sludge,
construction debris
Pesticides,
metals, SVOCs,
PCBs
Remedy: Source: No action.
Robins AFB (OU1), QA,
Region 4
6/25/91
Main area (Landfill No. 4),
45 acres, greater than
100,000 cy
Household refuse,
industrial waste
VOCs, metals
Remedy: Capping (to maintain a minimum 2-foot cover over the
waste materials), renovation of current soil cover including
clearing, filling, regrading, adding soil and clay cover material and
seeding to maintain a minimum 2-foot cover over the waste
material.
A-3
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DATA SUMMARY TABLE FOR MILITARY LANDFILLS APPENDIX (CONT.)
ROD/Site Name, State,
Region, ROD Sign Date
Disposal Area, Size,
Volume of Waste
Type of Waste
Deposited
Contaminants of
Concern
Remedy
Twin Cities AFB Reserve,
MN, Region 5
3/31/92
Main area, approx. 2 acres,
volume not reported
Household refuse, small
amounts of industrial;
some burned waste
VOCs, metals
Remedy: Source: Institutional controls, natural attenuation,
ground water and surface water monitoring.
Wright-Patterson AFB,
(Source Control Operable
Unit) OH, Region 5
7/15/93
LF-8,11acres, 187,300 cy
General refuse and
hazardous materials
PAHs, pesticides,
PCBs, VOCs,
metals,
inorganics
Remedy: Capping (low-permeability clay cap that complies with
Ohio EPA regulations for sanitary landfills which meet or exceed
RCRA Subtitle D requirements), institutional controls, ground
water treatment and monitoring.
Wright-Patterson AFB,
(Source Control Operable
Unit) OH, Region 5
7/15/93
LF-10,8 acres, 171,600 cy
General refuse and
hazardous materials
PAHs, pesticides,
PCBs, VOCs,
metals,
inorganics
Remedy: Capping (low-permeability clay cap that complies with
Ohio EPA regulations for sanitary landfills which meet or exceed
RCRA Subtitle D requirements), institutional controls, ground
water treatment and monitoring.
Hill AFB (OU4), UT,
Region 8
6/14/94
Landfill 1,3.5 acres,
140,000 cy
Burned solid waste, small
amounts of waste oils
and solvents (from
vehicle maintenance
facility).
VOCs (TCE)
Remedy: Capping (clay OP multi-media cap), pumping, treating,
and discharging ground water to POTW, treating contaminated
surface water, soil vapor extraction, implementing institutional
controls and access restrictions.
Defense Depot, Ogden
(OU1), UT, Region 8
6/26/92
Plain City Canal Backfill
Area, 4,000 cy
Electrical wire, glass, ash,
charcoal, asphalt, wood,
concrete, plastic and
metal fragments
Metals, PCBs,
dioxins, furans,
VOCs
Remedy: Excavation, sorting, and off-site disposal in a RCRA
permitted facility.
Defense Depot, Ogden
(OU3), UT, Region 8
9/28/92
Burial Site 3-A: Chemical
Warfare Agent Identification
Kit Burial Area, 100 cy
Vials of chemical surety
agents, broken glass
Metals, chemical
warfare agents
Remedy: Excavation, sorting, and off-site disposal in a RCRA
permitted facility.
Defense Depot, Ogden
(OU3), UT, Region 8
9/28/92
Burial Site 3-A: Riot Control
and Smoke Grenade Burial
Area, 90 cy
Unfused grenades and
grenade fragments, as
well as riot control
grenades
No contaminants
identified
Remedy: Excavation, sorting, and off-site disposal in a RCRA
permitted facility.
A-4
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DATA SUMMARY TABLE FOR MILITARY LANDFILLS APPENDIX (CONT.)
ROD/Site Name, State,
Region. ROD Sign Date
Disposal Area, Size,
Volume of Waste
Type of Waste
Deposited
Contaminants of
Concern
Remedy
Defense Depot, Ogden
(OU3), UT, Region 8
Burial Site 3-A:
Compressed Gas Cylinder
Reburial Area
Two compressed gas
cylinders and four smaller
steel tanks removed from
the Chemical Warfare
Agent Identification Kit
and Riot Control and
Smoke Grenade burial
areas
Unknown,
possible chemical
warfare agents
Remedy: Excavation of compressed gas cylinders and disposal
by a commercial operator.
9/28/92
Defense Depot, Ogden
(OU3), UT, Region 8
9/28/92
Burial Site 3-A:
Miscellaneous Items Burial
Area, 230 cy
Chemical Warfare Agent
Identification Kits
containing no CWAs,
World War II gas mask
canisters, paint, broken
glass, wooden boxes,
and pieces of iron
No contaminants
identified
Remedy: Excavation and transportation for off-site disposal in a
RCRA permitted hazardous waste landfill.
Defense Depot, Ogden
(OU3), UT, Region 8
9/28/92
Water Purification Tablet
Burial Area, 110cy
Bottles containing
halazone water
purification tablets
No contaminants
identified
Remedy: Excavation and transportation for off-site disposal in a
RCRA permitted industrial waste landfill.
Defense Depot, Ogden
(OU4), UT, Region 8
9/28/92
4-A, 7SOO, sq. ft., 3000 cy
Wood, crating materials,
paper, greases, debris,
medical waste, oils, some
burned waste
Pesticides, VOCs,
PCBs
Remedy: Excavation and transportation for off-site disposal in a
RCRA permitted hazardous waste landfill.
Defense Depot, Ogden
(OU4), UT, Region 8
9/28/92
4-B, (inside 4-E), less than
7,500, sq. ft.
Fluorescent tubes
No contaminants
identified
Remedy: Excavation and transportation for off-site disposal in a
RCRA permitted landfill.
Defense Depot, Ogden
(OU4), UT, Region 8
9/28/92
4-C, 6,000 sq. ft
Food products, sanitary
landfill waste
Pesticides, VOCs,
PCBs
Remedy: Excavation and transportation for off-site disposal in a
RCRA permitted landfill.
A-5
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DATA SUMMARY TABLE FOR MILITARY LANDFILLS APPENDIX (CONT.)
ROD /Site Name, State,
Region. ROD Sign Date
Disposal Area, Size,
Volume of Waste
Type of Waste
Deposited
Contaminants of
Concern
Remedy
Defense Depot, Ogden
(OU4), UT, Region 8
9/28/92
4-D, 2,000 sq. ft.
Methyl bromide cylinders,
halazone tablets (jars)
Possibly methyl
bromide
Remedy: Excavation and transportation for off-site disposal in a
RCRA permitted industrial landfill.
Defense Depot, Ogden
(OU4), UT, Region 8
9/28/92
4-E, 7,500 sq. ft., volume
not reported
Oils, spent solvents,
industrial waste
PCBs, VOCs,
pesticides
Remedy: Excavation and transportation for off-site disposal in a
RCRA permitted hazardous landfill.
Rocky Mountain Arsenal,
Shell Section 36
Trenches (OU23), CO,
Region 8
5/3/90
Shell Trench Area, 8 acres
Rags, plastic and metal
cans, glass jars, piping,
pipe fittings, insulation,
refuse, insulation, liquid
and solid wastes
generated from the
manufacture of pesticides
VOCs, SVOCs,
pesticides2
Remedy: Capping (physical barrier with a soil and vegetative
cover).
Fort Ord Landfills (OU2),
CA, Region 9
Landfills, 150 acres
8/23/94
Household and
commercial refuse, dried
sewage sludge,
construction debris, small
amounts of chemical
waste including paint, oil,
pesticides, and epoxy
adhesive, electrical
equipment
VOCs
Remedy: Capping (California Code of Regulations for non-
hazardous waste), institutional controls, extraction, treatment, and
recharge of ground water.
Riverbank Army
Ammunition Plant Site,
CA, Region 9
3/24/94
Landfill, 4.5 acres
Paper, oils, greases,
solvents, hospital wastes,
construction debris, and
industrial sludges
Metals
Remedy: Capping (a multi-layer cap as specified in Dispute
Resolution Agreement), pump and treat ground water, discharge
treated water to on-site ponds.
2 Contaminants identified as emanating from the trenches but not contaminants of concern
A-6
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DATA SUMMARY TABLE FOR MILITARY LANDFILLS APPENDIX (CONT.)
ROD /Site Name, State,
Region, ROD Sign Date
Williams AFB(OU1),AZ,
Region 9
5/18/94
Williams AFB(OU1),AZ,
Region 9
5/18/94
Williams AFB(OU1),AZ,
Region 9
5/18/94
ElmendorfAFB(OUI),
AK, Region 10
9/29/94
ElmendorfAFB(OUI),
AK, Region 10
9/29/94
ElmendorfAFB(OUI),
AK, Region 10
9/29/94
Disposal Area, Size,
Volume of Waste
Landfill LF-04, 90 acres,
59,000 cy
Pesticide Burial Area (DP-
13), 0.4 acre
Radioactive Instrumentation
Burial Area (RW-11), 100
sq.ft.
LF05, 17 acres
LF07, 35 acres
LF13, 2 acres
Type of Waste
Deposited
Dried sewage sludge,
domestic trash and
garbage, wood, metal,
brush, construction
debris, some solvents
and chemicals
Pesticides
Cement; radioactive
instruments
General refuse, scrap
metal, used chemicals
and other scrap material
Base generated refuse,
scrap metal, construction
rubble, drums of asphalt,
empty pesticide
containers, small
amounts of shop wastes,
and asbestos wastes
Empty drums, metal
piping, drums of asphalt,
and small quantities of
quicklime
Contaminants of
Concern
Soil, pesticides,
SVOCs,
inorganics,
including
beryllium, lead,
zinc
Pesticides, VOCs,
metals
Radium
(background
levels)
VOCs, PCBs,
metals, PAHs
VOCs, PCBs,
metals, PAHs
VOCs, PCBs,
metals, PAHs
Remedy
Remedy: Capping (a permeable cap with a 24 inch soil cover),
stormwater runoff controls, institutional actions, and soil and
ground water monitoring.
Remedy: Source: No action.
Remedy: Source: No action.
Remedy: Source: No action.
Remedy: Source: No action.
Remedy: Source: No action.
A-7
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DATA SUMMARY TABLE FOR MILITARY LANDFILLS APPENDIX (CONT.)
ROD/Site Name, State,
Region, ROD Sign Date
Disposal Area, Size,
Volume of Waste
Type of Waste
Deposited
Contaminants of
Concern
Remedy
ElmendorfAFB(OUI),
AK, Region 10
9/29/94
LF59, 2 landfills (.5 acres
each)
General refuse and
construction debris, and
tar seep
VOCs, RGBs,
metals, PAHs
Remedy: Source: No action.
FairchildAFB(OU1),WA,
Region 10
2/13/93
Southwest area,
12.6 acres, 407,300 cy
Coal ash, solvents, dry
cleaning filters, paints,
thinners, possibly
electrical transformers.
VOCs
Remedy: Capping (low-permeability cap designed to meet the
closure requirements of Washington State's Minimum Functional
Standards for Solid Waste handling and of federal RCRA Subtitle
D), SVE/ treatment system, extracting contaminated ground water
and treating by air stripping and granular activated carbon,
disposal off-site, monitoring off-site water supply wells.
FairchildAFB(OU1),WA,
Region 10
2/13/93
Northeast area, 6 acres,
291,000 cy
Coal ash, solvents, dry
cleaning filters, paints,
thinners, possibly
electrical transformers.
VOCs
Remedy: Capping (low-permeability cap designed to meet the
closure requirements of Washington State's Minimum Functional
Standards for Solid Waste handling and of federal RCRA Subtitle
D), SVE/ treatment system, extracting contaminated ground water
and treating by air stripping and granular activated carbon,
disposal off-site, monitoring off-site water supply wells.
Fort Lewis Military
Reservation, Landfill 4
and the Solvent Refined
Coal Pilot Plant, WA,
Region 10
9/24/93
LF4,52 acres
Domestic and light
industrial solid waste (no
landfill records were
maintained).
VOCs, metals
Remedy: Source: Institutional controls, treat ground water and
soil using SVE and air sparging system.
Naval Air Station,
Whidbey Island, Ault
Field (OU1),WA,
Region 10
12/20/93
Area 6 Landfill, 40 acres.
Within Area 6 there are 2
distinct areas where wastes
were disposed.
Household waste,
construction debris, and
yard waste
VOCs
Remedy: Capping (low-permeability cap to meet Washington
State Minimum Functional Standards for non-hazardous closure),
air stripping ground water, ground water monitoring, and
institutional controls.
Naval Air Station,
Whidbey Island, Ault
Field (OU2),WA,
Region 10
12/20/93
Area 2,13 acres; Area 3,
1.5 acres. Both treated
together due to close
proximity.
Solid waste from the
base, industrial wastes,
and construction and
demolition debris
Metals, PAHs
Remedy: Source: Institutional controls, ground water monitoring.
A-8
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DATA SUMMARY TABLE FOR MILITARY LANDFILLS APPENDIX (CONT.)
ROD /Site Name, State,
Region, ROD Sign Date
Naval Reactor Facility,
ID, Region 10
9/27/94
Naval Reactor Facility,
ID, Region 10
9/27/94
Naval Reactor Facility,
ID, Region 10
9/27/94
Disposal Area, Size,
Volume of Waste
Landfill Unit 8-05-1,
(350 ft. by 450 ft. by 4-25
ft.)
Landfill Unit 8-05-51,
(450 ft. by 100 -175 ft. by
10-1 5 ft.)
Landfill Unit 8-06-53, (900
ft. by 1200 ft. by 7- 10 ft.)
Type of Waste
Deposited
Construction debris, small
quantities of paints,
solvents, cafeteria
wastes, and petroleum
products
Construction debris, small
quantities of paints,
solvents, cafeteria
wastes, and petroleum
products
Construction debris, small
quantities of paints,
solvents, cafeteria
wastes, and petroleum
products
Contaminants of
Concern
Metals, VOCs
Metals, VOCs
Metals, VOCs
Remedy
Remedy: Capping (24-inch native soil cover), institutional
controls.
Remedy: Capping (24-inch native soil cover), institutional
controls.
Remedy: Capping (24-inch native soil cover), institutional
controls.
A-9
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United States
Environmental Protection
Agency
Washington, D.C. 20460
Official Business
Penalty for Private Use
$300
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