Presidio of San Francisco

Landfill Closure Principles

1. Consolidate—Reduce Widely Separated Extent of Wastes

Debris fill, garbage and hazardous waste is spread over seventeen separate Presidio sites where people, plants and animals can be exposed, now or in the future. Consolidation of at least some Presidio landfills onsite or off-site would considerably reduce or, more appropriately, eliminate the widely separated extent of wastes at the Presidio.

2. Relocate Small Landfills

Where landfill areas and volumes are small they can be readily moved. The EPA’s April 1996 Guidance, “Application of the CERCLA Municipal Landfill Presumptive Remedy to Military Landfills” recommends that landfills not be moved if they are over 100,000 cubic yards in volume. Most of the Presidio landfills are under 10,000 cubic yards—none are over 100,000 cubic yards (see attached Table 9.0-1 from the Army’s Final Remedial Investigation Report, Presidio Main Installation, January 1997). Therefore, according to the guidance all Presidio landfills are candidates for excavation and off-site disposal.

3. Reuse of National Park Lands is Unrestricted

Reuse of the Presidio National Park lands are thoroughly described in the Park Service’s General Management Plan Amendment, July 1994 and updated by such reports as the Final Draft Wetland and Riparian Corridor Restoration Feasibility Study, August 1995. These plans required considerable time and effort to develop and involved a great degree of community input. Nevertheless, as the final plans for a particular site emerge, the details may vary, sometimes significantly, from the initial concept. Flexibility for changing reuse scenarios ensures that the Park and the Presidio Trust may employ the best possible site reuse for the Park so that it may achieve its self-sufficiency needs. Therefore, it remains essential that deed restrictions or institutional controls are not imposed on Presidio contamination sites, limiting the reuse of the property and diminishing its value for the millions of expected Park visitors.

In addition, a 1991 San Francisco Regional Water Quality Control Board Policy regarding foundation piles through closed landfills (see attached) illuminates hidden costs for construction at capped landfill sites, and suggests that there will likely be substantial compliance costs if Presidio decision-makers decide to build on landfills in the future. These future compliance costs may severly limit reuse at the Presidio landfills and should be considered .

4. Clear Waste from Groundwater Saturation Zones

As indicated in Table 9.0-1 from the Presidio Remedial Investigation (attached), a substantial number of the Presidio landfills were created by dumping debris, garbage and hazardous waste in ravines and low-lying areas where small creeks and seeps existed. These freshwater saturation zones are now the sites of potential ongoing contamination. By relocating wastes in an appropriately designed and monitored off-site disposal facility with modern leachate collection systems, Presidio surface water and percolating groundwater will remain free from future contamination. Wastes should, therefore, be removed from water saturation zones where toxic leaching in toxic amounts is more likely to occur.

5. Recycle Building and Construction Debris

Much of the material in Presidio fill sites is described as debris fill and rubble. These materials are now commonly recycled and need not be sent to a landfill. Recycling materials when appropriate and feasibile would reduce the cost of off-site disposal.

6. Consider Cost of Remedy Only After Other Threshold Issues are Resolved

The community must assume that a containment presumptive remedy has been selected at Lanfill E, since monies have been spent designing that remedy. According to the EPA’s April 1996 Guidance, “Application of the CERCLA Municipal Landfill Presumptive Remedy to Military Landfills,” land reuse and community acceptance should be ascertained before a presumptive remedy is implemented. To implement a presumptive remedy, the Administrative Record must contain site-specific information documenting how the presumptive remedy satisfies, among other site-specific remedy selection criteria, community acceptance. Community acceptance is based on examining a site for expected future reuse and alternative remedies for cleanup. The Army should not claim a priori that the cost of excavation and off-site disposal is prohibitive and therefore, excavation is not to be considered—particularly when the community is not given the detailed cost information to evaluate. Once given the detailed cost information the community can assess whether costs for containing wastes in place include sufficient funding for monitoring and cap maintenance. Annual maintenance costs for containing and monitoring landfills could be considerable and would be a permanent additional burden to the Park, suggesting that a permanent removal action may be a more appropriate remedy. Therefore, remedy cost should be considered after all alternatives are reviewed for site reuse and community acceptance.

7. The Presidio has Special Status as a National Park

The Army has stated that it fully recognizes the importance of the historical and recreational resources at the Presidio and its unique status among Base Realignment and Closure (BRAC) sites. However, there is no indication in any reuse scenario described to date that containment of contamination sites on the Presidio furthers some significant future reuse purpose. The containment of waste at the Presidio of San Francisco is entirely inconsistent with the vision, goals and reuse scenarios of the Park. In consideration of the Park’s future reuse needs, landfills, fill sites and disturbed areas should be excavated and disposed of off-site.

8. The Cleanup Remedy is Acceptable to the Community

According to the National Contingency Plan each alternative is assessed against nine evaluation criteria. The ninth criterion, one of the so-called modifying criteria, is that an alternative should be acceptable to the community. The final disposition of Presidio landfills should, therefore, be acceptable to community representatives. While not the only body capable of giving community input regarding the Presidio cleanup effort, the Restoration Advisory Board is the Army-sponsored, community input advisory group and should therefore be consulted. The Army has not conferred with community representatives from the Restoration Advisory Board regarding disposition of the Presidio landfills. Rather, it has pursued a course of implementing a presumptive remedy, particularly at Landfill E, without community acceptance. As with any site at the Presidio, landfill cleanup alternatives and presumptive remedies must pass the criterion of community acceptance.