United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Directive No,9355.0-62FS
EPA/540/F-96/007
PB96-963307
April 1996
Application of the CERCLA
Municipal Landfill Presumptive
Remedy to Military Landfills
(Interim Guidance)
Federal Facilities Restoration and Reuse Office
Quick Reference Fact Sheet
Presumptive remedies are preferred technologies for common categories of sites based on historical patterns of
remedy selection and 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 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 CERCLA municipal landfill sites in
September of 1993 (see Highlight 1 for components of the presumptive remedy). 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
containment presumptive remedy to military landfills.
Specifically, this guidance:
• describes the relevant characteristics of municipal
landfills for applicability of the presumptive
remedy;
• presents the characteristics specific to military
installations that affect application of the
containment presumptive remedy; and
• provides a decision framework to determine
applicability of the containment presumptive
remedy to military landfills.
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 landfalls, source
containment, is described in detail in the directive
entitled Presumptive Remedy for CERCLA Municipal
Landfill Sites. Highlight 1 outlines the components of
the containment presumptive remedy. Highlight 2
lists the characteristics of municipal landfills that are
compatible with the presumptive remedy of containment
The presumptive remedy process involves streamlining
of the remedial investigation/feasibility study (RI/FS)
by:
• relying on existing data to the extent possible
ratherthan characterizing landfill contents (limited
or no landfill source investigation);
* conducting a streamlined risk assessment; and
« developing a focused feasibi lity study that analyzes
only the presumptive remedy and the no action
alternatives.
The Presumptive Remedy for CERCLA Municipal
Landfill Sites. Conducting Remedial Investigations/
Feasibility Studies for CERCLA Municipal Landfill
Sites, and Streamlining the RI/FS for CERCLA
Municipal Landfill Sites Directives provide a complete
discussion of these streamlining principles.
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
landfills, these differences do not preclude use of
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source containment as the primary remedy at
appropriate 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 A). Of these 41 landfills,
containment was selected at 23 (56%) of the landfills.
For the remaining 18 landfills where other remedies
were selected, institutional controls only were selected
at 3, excavation and on-site consolidation was selected
at 4 landfills, and excavation and off-site disposal was
selected for the remaining 11 landfills.
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
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.
The military landfills examined range in size from 300
square feet to 150 acres with a wide variety of waste
types. Of the 41 landfills, 14 (34%) are one acre or less
in size, and containment was not selected for any of
these landfills. Twenty-seven (66%) of the landfills
are more than one acre in size and containment was
chosen at 23 (85%) of these landfills. This indicates
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
wastes, commercial (e.g., hospital wastes, grease,
construction debris), and industrial (e.g., process
wastes, solvents, paints). 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.
Highlight 3 lists typical municipal and military wastes.
Column A lists wastes that are common to both
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, industrial solid wastes
Lesser quantities of hazardous waste are
present as compared to municipal wastes
Land application units,surface impoundments,
injection wells, or waste piles are not included
municipal landfills and military landfills. Column B
lists wastes that are usually specific to military bases,
but may not pose higher risks than other industrial
wastes commonly found in municipal landfills (Low-
Hazard Military-Specific Wastes), depending on the
volume and heterogeneity of the wastes. Column C
lists high-hazard military wastes that, because of their
unique characteristics, would require special
consideration (High-Hazard Military-Specific Wastes)
Military-specific wastes (both low- and high-hazard)
need to be addressed in site-specific analyses when
determining 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. 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," as discussed in
the Presumptive Remedy for CERCLA Municipal
Landfill Sites Directive (see pages 5-6 of this guidance
for a discussion of hot spots).
The proportion and distribution of hazardous wastes
in a landfill are important considerations. Generally,
municipal 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 in comparison to overall
site activities. In these cases, there may be a higher
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Highlight 3: Examples of MLF and Military Wastes
Column A: 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. Furthermore, hazardous wastes are found in most municipal landfills due to past disposal
practices.
Column B: These types of wastes are specific to military bases, but generally are no more hazardous
than some wastes found in municipal landfills.
Column C: These wastes are extremely hazardous and may possess unique safety, risk and toxicity
characteristics. Special consideration and expertise are required to address these wastes.
A
Municipal-Type Wastes
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
Paints and paint thinner
Pesticides
Transformer oils
Other solvents
Military-Specific Wastes
B
Low-Hazard Military-Specific
Wastes
Low-level radioactive wastes
Decontamination kits
Munitions hardware
C
High-Hazard Military-Specific
Wastes
Military Munitions
Chemical warfare agents
(e.g., mustard, tear agents)
Chemical warfare agent training kits
Artillery, Small arms, Warheads
Other military chemicals
(e.g., demolition charges,
pyrotechnics, propellents)
Smoke grenades
Note: The majority of military landfills contain primarily non-hazardous
wastes. The materials listed in these columns are rarely predominant
constituents of military landfills.
proportion and wider distribution of industrial (i.e.,
potentially hazardous) wastes present than at other
less industralized facilities.
PRACTICAL CONSIDERATIONS
Site-specific conditions may limit the use of the
containment 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 habitat as
a result of a particular remedial action could all be
important factors in the selection of the remedy.
Reasonably anticipated future land use is also an
important consideration at all sites. However, at
military bases undergoing base closure procedures,
where expeditiously converting property to civilian
use is one of the primary goals, land use may receive
heightened attention. Thus, at closing bases, it is
particularly important for reuse planning to proceed
concurrently with environmental investigation and
restoration activities. The local reuse group is
responsible for developing the preferred reuse
alternatives. The base cleanup 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).
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.
/. Collect Available Information. Determine the
sources, types and volume of landfill wastes using
historical records and available sampling data. This
information should be sufficient to determine whether
source containment is the appropriate remedy for the
landfill. If adequate data does not exist, the collection
of additional sampling or monitoring data may be
necessary. The installation point of contact
(environmental coordinator, base civil engineer, or
public works office) should be contacted to obtain
records or disposal procedures. Current and former
employees are also good sources of information.
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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: Municipal-type waste
can include lesser quantities
of industrial or hazardous
waste in proportion to total
volume of waste, but not
including military-specific
wastes.
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
aste Definition
Military-Specific Wastes
Are Present; Consult With
Military Experts
Is
Containment
the Most
Appropriate
Remedy?
Don't Us*
Containment
Presumptive
Ronwdy
(Although other
remedial
alternatives are
sonsidered, source
containment still
may be selected)
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
(No Action and Presumptive Remedy are the only
alternatives considered. The Presumptive Remedy
albws for treatment of hot spots)
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2. Consider the Effects of Land Reuse Plans on
Remedy Selection. For smaller landfills (generally
less than 2 acres), land reuse plans may influence the
decision on 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
characteristics of the 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.
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
contaminants may pose safety issues for site workers
and the community. Highlight 3 (Columns B and C)
presents examples of these types of materials. 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 when determining whether military-
specific wastes at a site fall into Column B or Column
C (See Highlight 5). Responsibilities for response are
clearly spelled out in the joint regulation entitled:
Interservice Responsibilities For Explosive Ordnance
Disposal.
5. Is Excavation Practical? The volume of landfill
contents, types of wastes, hydrogeology, and safety
considerations are important criteria 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 versus
the initial high capital construction 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 2
acres, 30 feet deep) would normally not be considered
forexcavation. 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.
If excavation of the landfill contents is going to be
considered as an alternative, the presumptive remedy
should not be used. Therefore, a standard feasibility
study would be required to adequately analyze and
select the appropriate remedial actions.
Highlight 5
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:
• The Army Ordnance Environmental Support
Office (OESO) and the Program Manager for
Chemical Demilitarization, U.S. Army Chemical
Material Destruction Agency, Aberdeen Proving
Ground, Maryland21010-5401, (410) 671-1435/
3325.
Navy ordnance related items specialists:
• The Navy OESO, Naval Surface Warfare Center,
Indian Head, Maryland 20460-5035, (301) 743-
4534/4906/4450.
Navy Low-Level Radioactive wastes specialists:
• The Naval Sea Systems Command Detachment,
Radiological Affairs Support Office, Yorktown,
Virginia 23691-5908, (804)887-4692.
Air Force Ordnance specialists:
• The Air Force Civil Engineering Support Agency,
Contingency Support Division Tyndall AFB,
32403-5319, (904) 283-6410.
6. Is Containment the Most Appropriate Remedy?
In most cases, if excavation is not practical, then
containment will be the appropriate remedial response.
The site manager will make the initial decision of
whether a particular military landfill site is suitable
for the presumptive remedy or whether a more
comprehensive RI/FS is required. This determination
shouldbe made before the RI/FS is initiated. Generally,
this decision will depend on whether the site is a
potential candidate forexcavation, and if not, whether
the nature of contamination is such that a streamlined
risk evaluation can be conducted1. A site generally is
eligible for a streamlined risk evaluation if groundwater
contaminant concentrations clearly exceed chemical-
specific standards or other conditions exist that provide
a justification for action (e.g., direct contact with
landfill contents due to unstable slopes).
"See the directive: Role of the Baseline Risk Assessment In
Super fund Remedy Selection Decisions.
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The presumptive remedy also allows for the treatment
of hot spots containing military-specific wastes. Four
questions must be answered to warrant characterization
and treatment of any area as a hot spot. They are:
1. Does evidence exist to indicate the presence and
approximate location of waste?
2. Is the hot spot known to be principal threat waste?2
3. Is the waste in a discrete, accessible part of the
landfill?
4. Is the hot spot known to be large enough that its
remediation will reduce the threat posed by the overall
site but small enough that it is reasonable to consider
removal (e.g., 100,000 cubic yards or less)?
An affirmative answer to all of the above would
indicate that is it likely that the integrity of the
containment system would be threatened, or that
excavation and treatment of hot spots would be
practicable, and that a significant reduction in risk at
the site would occur as a result of treating hot spots.
For further information and case studies on treatment
of hot spots, please refer to the Presumptive Remedy
for CERCLA Municipal Landfill Sites Directive.
CASE HISTORIES
The following case histories present examples of where
the containment presumptive remedy was or was not
applied, based on site-specific conditions. In some
cases, even through a containment remedy was selected,
the streamlining principles of the presumptive remedy
process were not followed. In other cases, land reuse
considerations precluded use of a containment remedy.
The purpose of this guidance is to encourage use of the
streamlining principles outlined in the presumptive
remedy process to save cost and time.
Disposal of MLF-Type Wastes
At the Michaelsville Landfill Site, in Aberdeen,
Maryland, the majority of wastes in the 20-acre landfill
were domestic wastes and trash from non-industrial
operations. The remaining portion of the wastes
included sludges from the waste water treatment plant,
asbestos shingles and pesticides. The selected
containment remedy included a multi-layered cap,
surface water controls, and a gas venting system. Off-
site incineration and excavation were also considered.
This is a case where the streamlining principles of the
presumptive remedy process could have been utilized,
at a savings in study costs and time, because the wastes
were municipal-type wastes that could be easily
contained without further consideration of treatment
alternatives.
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 selected remedy for the landfills at the site
included the installation of anative 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
subsidence 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
protective. 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 the 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 the 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 munitions 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.
Land Reuse Considerations
At Fort Devens in Ayer, Massachusetts, a closing base,
a well serving as a primary source of potable groundwater
for the base was located several hundred feet upgradient
from the base landfill. Anticipating additional
groundwater use under its reuse plan, the redevelopment
Principal threat wastes are those source materials considered
to be highly toxic or highly mobile that generally cannot be
reliably contained or would present a significant risk to human
health or the environment should exposure occur.
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authority decided that the well's pumping rate would
need to increase to accommodate demands after land
reuse. Selection of source containment, the presumptive
remedy, to remediate this landfill would have required
applying institutional controls and restricting increased
groundwater use, because raising pumping rates would
have unacceptably increased the risk of contaminants
migrating into the well. Under these circumstances,
authorities proposed to enable increased pumping of the
well by consolidating the landfill with other landfills in
the area. All hazardous wastes in the landfill, including
low-hazard wastes that would otherwise have been
contained, will be treated or disposed on or off the site.
Due to future land use considerations, the streamlined
presumptive remedy process was not used at this site.
Instead, a standard feasibility study was conducted to
analyze both excavation and containment as remedial
alternatives.
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 I2-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, containment 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 polycyclic 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 use of the
presumptive remedy.
PRESUMPTIVE REMEDY ADMINISTRATIVE
RECORD DOCUMENTATION
REQUIREMENTS
The Administrative Record must contain the following
generic and site-specific information documenting the
selection or non-selection of the containment
presumptive remedy. 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. If the military landfill in question
contains the Military-Specific Wastes as described
under Columns B and C in Highlight 3, then the site-
specific administrative record should address whether
anything about these wastes would make the
engineering controls specified in the presumptive
remedy for municipal landfills less suitable as a 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.
OSWER Directive 9355.0-47FS
* Presumptive Remedy for CERCLA Municipal
Landfill Sites OSWER Directive 9355.0-049FS
* Application of the Municipal Landfill
Presumptive Remedy to Military Landfills.
OSWER Directive 9355.0-62FS
* Feasibility Study Analysis for CERCLA
Municipal 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 material such as
technical references and old feasibility studies. Each
EPA Regional Office has a copy of this file.
Site-specific Information
A. Site-Specific Documents. These should include;
• Focused FS orEE/CA. A focused feasibility study
(or, for non-time-eritical removal actions, a focused
engineering evaluation/cost analysis) which
analyzes only the presumptive remedy and the no
action alternative. The focused feasibility study
does not account for the full range of alternatives
that are addressed in a standard feasibility study.
This study should present the data and explain the
rationale for the selection of the containment
presumptive remedy for the military landfill under
investigation. This explanation should specify the
site-specific conditions (e.g., waste types, volumes,
and risk data) that support the use of the presumptive
remedy. It should also state that guidance in this
document (Application of the CERCLA Municipal
Landfill Presumptive Remedy to Military Landfills)
was used in selecting the containment presumptive
remedy. In addition, the focused FS or EE/CA
should include a site-specific explanation of how
the application of the presumptive remedy satisfies
the NCR's three site-specific remedy selection
criteria (state ARAR compliance, state acceptance
and community acceptance).
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B. Site-specific comments. If these have been received,
the record should include:
• copies of the comments received; and
• copies of generic responses to the comments,
including:
- a brief discussion relating each relevant generic
response to circumstances at the specific site;
and
- an explanation for this site of the rejection of
any technology suggested in a site-specific
comment but not analyzed in an existing
generic EPA response.
CONCLUSION
This directive recommends the use of the containment
presumptive remedy at appropriate military landfills.
The remedies selected at numerous military
installations indicate that source containment is
applicable to a significant number of military landfills.
These landfills need not be identical to municipal
landfills in all regards. Key factors in the determination
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 high-hazard
military wastes.
REFERENCES
California Base Closure Environmental Committee,
Integrating Land Use and Cleanup Planning at Closing
Bases. December 1994.
RCRA, 40 CFR Part 258, Definitions.
U.S. Department of Navy Interservice Responsibilities for
Explosive Ordnance Disposal OPNAVINST8027.1G (also
known as MCO 8027.1D, AR 75-14; or AH 32-3002);
February 14,1992.
U.S. Environmental Protection Agency, OSWER
Directive 93557-04, Land Use in CERCLA Remedy
Selection. May 1995.
U.S. Environmental Protection Agency, OSWER
Directive 9355.0-49FS, Presumptive Remedy for
CERCLA Municipal Landfill Sites. October 1993.
U.S. Environmental Protection Agency, OSWER
Directive 9355.3-06FS, A Guide to Principal Threat
and Low Level Threat Wastes. November 1991.
U.S. Environmental Protection Agency, OSWER
Directive 9355.0-30, Role of the Baseline Risk
Assessment in Superfund Remedy Selection Decisions.
April 22, 1991.
U.S. Environmental Protection Agency, OERR, EPA/
540/P-9I/001, Conducting Remedial Investigations/
Feasibility Studies for CERCLA Municipal Landfill
Slies, February 1991.
U.S. Environmental Protection Agency, OSWER
Directive 9833.3A.I, Final Guidance on Administrative
Records for Selecting CERCLA Response Actions.
December 3, 1990.
U.S. Environmental Protection Agency, OSWER
Directive 9355.3-11FS, Streamlining the RI/FS for
CERCLA Municipal Landfill Sites. September 1990.
Notice:
The policies set out in this document are intended solely as guidance to the U.S. Environmental
Protection Agency (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 document, 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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APPENDIX A:
DATA SUMMARY TABLE FOR MILITARY LANDFILLS
ROD / Site Name, State,
Region, ROD Sign Date
Brunswick NAS, Sites 1
and 3 (OU1), ME,
Region 1
6/16/92
Brunswick NAS, Site 8
(OU4), ME, Region 1
8/31/93
Brunswick NAS, Sites 5
and 6 (OU3), ME,
Region 1
8/31/93
Brunswick NAS, Sites 5
and 6 (OU3), ME,
Region 1
8/31/93
Loring AFB Landfills 2
and 3 (OU2), ME,
Region 1
9/30/94
Loring AFB Landfills 2
and 3 (OU2), ME,
Region 1
9/30/94
Newport Naval Education
and Training Center,
McAllister Point Landfill,
RI, Region 1
9/27/93
Disposal Area, Size, Volume
of Waste
Site 1 , 8.5 acres, volume
unknown; Site 3, 1.5 acres,
volume unknown. Sites are in
close proximity and not easily
distinguishable
Site 8, 0.6 acres
Site 5, 0.25 acres
Site 6, 1 .0 acre
Landfill 2, 9 acres
Landfills, 17 acres
McAllister Point Landfill, 1 1 .5
acres
Type of Waste
Deposited
Household refuse, waste
oil, solvents, pesticides,
paints, isopropyl alcohol
Rubble, debris, trash,
and possibly solvents
Asbestos-covered pipes
Construction debris and
aircraft parts, asbestos
pipes
Domestic waste,
construction debris,
flightline wastes,
sewage sludge and oil-
filled switches
Waste oil/fuels, solvents,
paints, thinners, and
hydraulic fluids
Domestic refuse, spent
acids, paints, solvents,
waste oils, and PCB-
contaminated
transformer oil
Contaminants
of Concern
SVOCs,
inorganics,
metals, VOCs,
PAHs, RGBs,
pesticides
PAHs, metals,
pesticides,
PCBs, and
VOCs
Asbestos
Asbestos
PCBs, VOCs,
SVOCs,
pesticides
VOCs, SVOCs,
PAHs,
pesticides,
PCBs, metals
VOCs, PAHs,
PCBs,
pesticides,
phenols, metals
Remedy
Remedy: Capping (RCRA Subtitle D cap) of 12 acres with a
slurry wall and pump and treat ground water within cap and
slurry wall.
Remedy: Excavation, containerization, and transport to landfill
Sites 1 and 3 for use as fill under cap.
Remedy: Excavation, containerization, and transport to landfill
Sites 1 and 3 for use as fill under cap.
Remedy: Excavation, containerization, and transport to Sites 1
and 3 landfill for use as fill under cap.
Remedy: Capping (RCRA Subtitle C, multi-layer cap), gas
assessment and controls, and institutional controls.
Remedy: Capping (RCRA Subtitle C, multi-layer cap), gas
assessment and controls, and institutional controls.
Remedy: Capping, (RCRA Subtitle C, multi-layer cap) gas
management, surface controls, and institutional controls.
A-l
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APPENDIX A:
DATA SUMMARY TABLE FOR MILITARY LANDFILLS (CONT.)
ROD / Site Name, State,
Region, ROD Sign Date
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
Naval Air Engineering
Center (OU1 7), NJ,
Region 2
9/26/94
Pittsburgh AFB, LF-022,
NY, Region 2
9/30/92
Disposal Area, Size, Volume
of Waste
Landfill Number 1 (LF-1), 100
acres; volume not reported
LF-5, 23 acres
Main area, 1 26 acres
Site 26, 1500 sq. ft., volume
not reported
Site 27, 6 acres
Site 29, 20-acres
LF-022, approx. 13.7 acres,
approx. 524,000 cy
Type of Waste
Deposited
General refuse, fuel tank
sludge, herbicides, blank
ammunition, paints,
paint thinners, batteries,
pesticides, 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
Construction debris,
metal, asbestos,
solvents, other
miscellaneous wastes
Household refuse
Contaminants
of Concern
VOCs, SVOCs,
inorganics
VOCs, PAHs,
arsenic and
other metals
VOCs, metals
No
contaminants
identified above
established
cleanup levels.
No
contaminants
identified.
VOCs, SVOCs,
metals
Metals,
pesticides
Remedy
Remedy: Capping (RCRA Subtitle C, multi-layer cap),
Institutional controls, soil cover inspection and ground water
monitoring.
Remedy: Excavation, dewatering and consolidation of waste
under a cap (RCRA Subtitle C); regrading and capping of
existing landfill; institutional controls; and extraction and
treatment of ground water with discharge to base wastewater
treatment facility.
Remedy: Capping 50-acre portion (NJAC 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.
Remedy: Source: No action.
Remedy: Capping (NY State requirements for solid waste
landfills, 12 inch soil cap) and institutional controls.
A-2
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APPENDIX A:
DATA SUMMARY TABLE FOR MILITARY LANDFILLS (CONT.)
ROD / Site Name, State,
Region, ROD Sign Date
Pittsburgh AFB, LF-023,
NY, Region 2
9/30/92
U.S. Army Aberdeen
Proving Grounds, MD,
Region 3
6/30/92
Marine Corps Base,
Camp Lejeune (OU1),
NC, Region 4
9/15/94
Robins AFB (OU1), GA,
Region 4
6/25/91
Twin Cities AFB Reserve,
MM, Region 5
3/31/92
Wright-Patterson AFB,
OH, Region 5
7/15/93
Wright-Patterson AFB,
OH, Region 5
7/15/93
Disposal Area, Size, Volume
of Waste
LF-023, approx. 9 acres,
approx. 406,000 cy
Michaelsville Landfill, 20
acres, greater than 100,000
cy
Site 24, 100 acres, volume
not reported
Main area (Landfill No. 4), 45
acres, greater than 100,000
cy
Main area, approx. 2 acres,
volume not reported
LF-8, 11 acres, 1 87,300 cy
LF-1 0,8 acres, 171,600cy
Type of Waste
Deposited
Household refuse,
debris, car parts
Household refuse,
limited quantities of
industrial waste, area
used for burning
Fly ash, cinders,
solvents, used paint
stripping compounds,
sewage sludge,
spiractor sludge,
construction debris
Household refuse,
industrial waste
Household refuse, small
amounts of industrial;
some burned waste
General refuse and
hazardous materials
General refuse and
hazardous materials
Contaminants
of Concern
Metals, VOCs,
SVOCs, PCB,
pesticides
Metals,
pesticides,
VOCs, PCBs
Pesticides,
metals
VOCs, metals
VOCs, metals
PAHs,
pesticides,
PCBs, VOCs,
metals,
inorganics
PAHs,
pesticides,
PCBs, VOCs,
metals,
inorganics
Remedy
Remedy: Capping ( NY State requirements for solid waste
landfills, low permeability cap) and institutional controls.
Remedy: Capping, (MD regs. for sanitary landfill; RCRA Subtitle
C multi-layer cap, 0-2 feet compacted earth material), surface
water controls, and gas venting system.
Remedy: Source: No Action.
Remedy: Capping (RCRA Subtitle C cap), Renovation of soil
cover (w/soil & clay).
Remedy: Source: institutional controls, natural attenuation,
groundwater and surface water monitoring.
Remedy: Capping (Ohio EPA regulations for sanitary landfills),
institutional controls, ground water treatment and monitoring.
Remedy: Capping, institutional controls, ground water treatment
and monitoring.
A-3
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APPENDIX A:
DATA SUMMARY TABLE FOR MILITARY LANDFILLS (CONT.)
ROD / Site Name, State,
Region, ROD Sign Date
Disposal Area, Size, Volume
of Waste
Type of Waste
Deposited
Contaminants
of Concern
Remedy
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 (RCRA Subtitle D 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.
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: CWA
Identification Kit Burial Area
(100 cy)
Vials of chemical surety
agents, (CSAs) broken
glass
VOCs, SVOCs,
metals, CWAs
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
VOCs, SVOCs,
metals
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: Compressed
Gas Cylinder Reburial Area
Two compressed gas
cylinders and four
smaller steel tanks
removed from the
Chemical Warfare Agent
(CWA) Identification Kit
and Riot Control and
Smoke Grenade burial
areas
Unknown,
possible
chemical
warfare agents
(CWAs)
Remedy: Excavation of compressed gas cylinders and disposal
by a commercial operator.
Defense Depot, Ogden
(OU3), UT, Region 8
9/28/92
Burial Site 3-A: Miscellaneous
Items Burial Area (230 cy)
Chemical Warfare Agent
(CWA) Identification Kits
containing no CWAs,
World War II gas mask
canisters, paint, broken
glass, wooden boxes,
and pieces of iron
VOCs, SVOCs,
metals
Remedy: Excavation and off-site disposal in a RCRA permitted
hazardous waste landfill.
A-4
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APPENDIX A:
DATA SUMMARY TABLE FOR MILITARY LANDFILLS (CONT.)
ROD / Site Name, State,
Region, ROD Sign Date
Defense Depot, Ogden
(OU3), UT, Region 8
9/28/92
Defense Depot, Ogden
(OU4), UT, Region 8
9/28/92
Defense Depot, Ogden
(OU4), UT, Region 8
9/28/92
Defense Depot, Ogden
(OU4), UT, Region 8
9/28/92
Defense Depot, Ogden
(OU4), UT, Region 8
9/28/92
Defense Depot, Ogden
(OU4), UT, Region 8
9/28/92
Rocky Mountain Arsenal,
Shell Section 36
Trenches (OU23), CO,
Region 8
5/3/90
Disposal Area, Size, Volume
of Waste
Water Purification Tablet
Burial Area (110cy)
4-A, 7500, sq. ft., volume not
reported
4-B, (inside 4-E), less than
7500, sq. ft., volume not
reported
4-C, 6000 sq. ft., volume not
reported
4-D, 2000 sq. ft., volume not
reported
4-E, 7500 sq. ft., volume not
reported
Shell Trench Area, 8 acres
Type of Waste
Deposited
Bottles containing
halazone water
purification tablets
Wood, crating materials,
paper, greases, debris,
medical waste, oils,
some burned waste
Fluorescent tubes
Food products, sanitary
landfill waste
Methyl bromide
cylinders, halazone
tablets (jars)
Oils, spent solvents,
industrial waste
Rags, plastic and metal
cans, glass jars, piping,
pipe fittings, insulation,
refuse, insulation, liquid
and solid wastes
generated from the
manufacture of
pesticides
Contaminants
of Concern
No
contaminants
identified
Pesticides,
VOCs, PCBs
None identified
Pesticides,
VOCs, PCBs
Possibly methyl
bromide
PCBs, VOCs,
pesticides
VOCs, SVOCs,
pesticides, and
DNAPLs
Remedy
Remedy: Excavation and off-site disposal in a RCRA permitted
industrial waste landfill.
Remedy: Excavation and off-site disposal in a RCRA landfill.
Remedy: Excavation and off-site disposal in a RCRA landfill.
Remedy: Excavation and transportation to off-site disposal in a
RCRA landfill.
Remedy: Excavation and transportation to off-site disposal in a
RCRA landfill.
Remedy: Excavation and transportation to off-site disposal in a
RCRA landfill.
Remedy: Capping (soil and vegetative cover RCRA Subtitle C),
constructing a physical barrier.
A-5
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APPENDIX A:
DATA SUMMARY TABLE FOR MILITARY LANDFILLS (CONT.)
ROD / Site Name, State,
Region, ROD Sign Date
Disposal Area, Size, Volume
of Waste
Type of Waste
Deposited
Contaminants
of Concern
Remedy
Fort Ord Landfills (OU2),
CA, Region 9
8/23/94
Landfills, 150 acres
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.
Rlverbank Army
Ammunition Plant Site,
CA, Region 9
3/24/94
Landfill, 4.5-acres, volume not
reported
Paper, oils, greases,
solvents, hospital
wastes, construction
debris, and industrial
sludges
Metals
Remedy: Capping (RCRA Subtitle C clay cap) pump and treat
ground water, discharge treated water to on-site ponds.
Williams AFB(OU1),AZ,
Region 9
5/18/94
Landfill LF-04,90-acres,
59,000 cy
Dried sewage sludge.
Domestic trash and
garbage, wood, metal,
brush, construction
debris, some solvents
and chemicals
Soil, pesticides,
SVOCs,
inorganics,
including
beryllium, lead,
and zinc GW:
BTEX, VOCs,
SVOCs
Remedy: Capping (permeable cap), stormwater runoff controls,
institutional actions, and soil and ground water monitoring.
Williams AFB(OU1),AZ,
Region 9
5/18/94
Pesticide Burial Area (DP-13),
0.4-acre, volume not reported
Pesticides
Pesticides,
VOCs, metals
Remedy: Source: No action.
Williams AFB(OU1),AZ,
Region 9
5/18/94
Radioactive Instrumentation
Burial Area (RW-11), 100 sq.
ft., volume not reported
Cement; radioactive
instruments
Radium
(background
levels)
Remedy: Source: No action.
ElmendorfAFB(OUI),
AK, Region 10
9/29/94
LF05,17-acres, volume not
reported
General refuse, scrap
metal, used chemicals
and other scrap material
VOCs, PCBs,
Metals, PAH
Remedy: Source: No action.
A-6
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APPENDIX A:
DATA SUMMARY TABLE FOR MILITARY LANDFILLS (CONT.)
ROD / Site Name, State,
Region, ROD Sign Date
Disposal Area, Size, Volume
of Waste
Type of Waste
Deposited
Contaminants
of Concern
Remedy
Elmendorf AFB(OU1),
AK, Region 10
9/29/94
LF07, 35-acres, volume not
reported
Base generated refuse,
scrap metal,
construction rubble,
drums of asphalt, empty
pesticide containers,
small amounts of shop
wastes, and asbestos
wastes
VOCs, RGBs,
Metals, PAH
Remedy: Source: No action.
Elmendorf AFB(OU1),
AK, Region 10
9/29/94
LF13, 2-acres, volume not
reported
Empty drums, metal
piping, drums of asphalt,
and small quantities of
quicklime
VOCs, PCBs,
Metals, PAH
Remedy: Source: No action.
Elmendorf AFB(OU1),
AK, Region 10
9/29/94
LF59, 2.5-acres, volume not
reported
General refuse and
construction debris, and
tar seep
VOCs, PCBs,
Metals, PAH
Remedy: Source: No action.
FairchildAFB(OUI), 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 (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.
Fairchild AFB (OU1), WA,
Region 10
2/13/93
Northeast area, 6 acres with
291,000 cy of waste
Coal ash, solvents, dry
cleaning filters, paints,
thinners, possibly
electrical transformers.
VOCs
Remedy: Capping (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.
A-7
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APPENDIX A:
DATA SUMMARY TABLE FOR MILITARY LANDFILLS (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 Station,
Whidbey Island, Ault
Field (OU1),WA,
Region 10
12/20/93
Area 6 Landfill; 40 acres; no
volume reported. Within Area
6 there are 2 distinct areas
where wastes were disposed.
Household waste,
construction debris, yard
waste, small volumes of
solvents, oily sludges,
thinners, and other
hazardous compounds
VOCs
Remedy: Capping (Washington State Minimum Functional
Standards for non-hazardous closure); RCRA Subtitle D), 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, no volume
reported; Area 3,1.5 acres;
no volume reported; 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.
Naval Reactor Facility,
ID, Region 10
9/27/94
Landfill Unit 8-05-1, (350 ft by
450ft.)(11,780m3)
Construction debris,
small quantities of
paints, solvents,
cafeteria wastes, and
petroleum products
Metals, VOCs
Remedy: Capping (native soil cover, RCRA Subtitle C),
institutional controls.
Naval Reactor Facility,
ID, Region 10
9/27/94
Landfill Unit 8-05-51, (100-
175ft. by 450 ft. by 10-15 ft.)
(1,610m3)
Construction debris,
small quantities of
paints, solvents,
cafeteria wastes, and
petroleum products
Metals, VOCs
Remedy: Capping (native soil cover, RCRA Subtitle C),
institutional controls.
Naval Reactor Facility,
ID, Region 10
9/27/94
Landfill Unit 8-06-53, (900 ft.
by 1200ft. by 7-10 ft.)(45,114
m3)
Construction debris,
small quantities of
paints, solvents,
cafeteria wastes, and
petroleum products
Metals, VOCs
Remedy: Capping (native soil cover, RCRA Subtitle C),
institutional controls.
A-8
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