Application of the CERCLA Municipal Landfill Presumptive Remedy to Military LandfillsUnited States Environmental Protection Agency Office of Solid Waste and Emergency Response
Directive No. 9355.0-67FS December 1996 Application of the CERCLA Municipal Landfill Presumptive Remedy to Military Landfills
Federal Facilities Restoration and Reuse Office 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 containment presumptive remedy to military landfills. Specifically, this guidance:
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 containment presumptive remedy. Highlight 2 lists the characteristics of municipal landfills that are compatible with the presumptive remedy of containment.
Highlight I
Highlight II
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:
Several directives, including 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, 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 landfills, 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 the process of selecting response actions for sites regulated under CERCLA and corrective measures for facilities regulated 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 Investigations, simplify evaluation of remedial alternatives in the Corrective Measures Study, and influence remedy selection in the Statement of Basis. For more information, refer to the RCRA Corrective Action Plan, the proposed Subpart S regulations, and the RCRA Corrective Action Advance Notice of Proposed Rulemaking. 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 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 at 10 landfills and remedial actions were chosen at 41 landfills (see Appendix). Of these 41 landfills, containment was selected at 23 (56 percent). For the remaining 18 landfills where other remedies were selected, institutional 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 mentioned 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, commercial (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). Highlight 3 lists typical municipal and military wastes, including:
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 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 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 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 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 bases that are closing, 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 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).
Highlight 3 Examples of Municipal-Type and Military-Specific Wastes Municipal-Type Wastes: Municipal landfills contain predominantly non- hazardous material~. 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 landiills as a result of past disposal practices Predominant Constituents:
Found In Low Proportion: Military-Type Wastes The majority of military landfils contain primarily nonhazardous wastes. The materials listed in this column are rarely predominant constituents of military landfills. Low Hazard Military-Specific Wastes: These types of wastes are specific to military bases but generally are no more hazardous than some wastes found in municipal lanfills.
High-Hazard Military Specific Wastes: These wastes are extremely hazardous and may possess unique safety, risk, and toxicity characteristics. Specific consideration and expertise are required to address these wastes. Military Munitions
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.
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. 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 selected 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 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 Loring Air Force Base, a closing base in Limestone, Maine, base landfills 2 and 3 (9 and 17 acres, respectively) consisted primarily of municipal and flightline wastes. The selected remedy for these landfills included a multi-layer cap, passive venting system, and institutional 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 specified 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 subgrade for the landfills (after demonstrating compliance with RCRA Land Disposal Restrbenefits. In addition to cost savings realized by providing subgrade, other bencfits have been realized, such as limiting the number of parcels requiring deed restrictions and minimizing 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, 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 levels of 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 selection of a containment remedy. PRESUMPTIVE REMEDY ADMINISTRATIVE RECORD DOCUMENTATION DOCUMENTS 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 presumptive remedy. Generic Information
Site-specific Information Focused FS or EE/CA. Military-specific wastes 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. As noted on pages 1 and 2 of this directive, the presumptive 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 acceptance, 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 applicable to a significant number of military landfills. These landfills need not be identical to municipal landfills in all regards. Key factors determining whether the containment 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
NOTICE The policies set out in 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,o rto 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.
|
![[logo] US EPA](http://www.epa.gov/epafiles/images/logo_epaseal.gif){kind=logo}
Federal Facilities Restoration and Reuse
- You are here: EPA Home
- Federal Facilities Restoration and Reuse
- FFRRO Library
- Application of the CERCLA Municipal Landfill Presumptive Remedy to Military Landfills
