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Fact Sheet

June 2014

Public Comment for Draft Hazardous Waste Management Permit and Proposed Final Remedy for Cleanup, Black Hawk County Landfill, Waterloo, Black Hawk County, Iowa


EPA Region 7 invites the public to comment on the draft Resource Conservation and Recovery Act (RCRA) hazardous waste management permit and the proposed final remedy for the Black Hawk County Landfill (BHCL) Site (EPA ID # IAD075848085) in Waterloo, Iowa. The public comment period will run from June 18, 2014, through August 4, 2014.

Written comments on the permit renewal or proposed remedy should be mailed or emailed no later than August 4, 2014, and should be sent to:

Ruby Crysler
EPA Region 7 (AWMD/WRAP)
11201 Renner Blvd.
Lenexa, KS 66219
Email: crysler.ruby@epa.gov


The site encompasses about 320 acres on Washburn Road, between Hammond Avenue and Hess Road, approximately 1 mile south of Waterloo, Iowa. The site was initially developed and operated by Landfill Service Corporation in 1975. The Iowa Department of Natural Resources (IDNR) issued the Landfill Service Corporation the original sanitary disposal project permit in May 1975, and the facility began operation in July 1975. Since that time, the BHCL has served as the primary disposal site for the residential, commercial, and industrial wastes generated in Black Hawk County, Iowa.

In 1981, the BHCL was designated as a hazardous waste disposal facility under the interim status provisions of RCRA. At that time, the RCRA landfill consisted of 150 acres, with two Solid Waste Management Units (SWMUs) which were designated as regulated units: SWMU-1, the Co-Disposal Area including the Sludge Drying Beds; and SWMU-2, the Neutral Trench Area. These units are the only identified SWMUs requiring cleanup at the facility.

Municipal waste and hazardous waste were disposed of in SWMU-1 until 1985. The hazardous waste disposed of in SWMU-1 included wastewater treatment sludges, solvent residues, plating bath residues (cyanidic processes), heavy metals (arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver), corrosive wastes, and reactive wastes. SWMU-2 received only the stabilized and dewatered wastes from SWMU-1 from 1981 to 1985 and some dry wastes.

The Black Hawk County Solid Waste Management Commission (Commission) purchased BHCL in 1984. After the Commission purchased the BHCL, the Commission stopped accepting manifested hazardous waste and began formal closure procedures for the two SWMUs.

EPA issued a RCRA Post-Closure Permit on May 28, 1991, and renewed the Permit on January 29, 2004. The permit has been continued since its expiration in March 2014. EPA has prepared a draft permit to renew the post-closure care requirements of the regulated units/SWMUs. 


Closure of SWMU-2 was completed on March 7, 1989, with grading and capping. No excavation of waste was completed. The debris was covered with a minimum of six inches of clay fill, and an impervious cover was installed, consisting of a high-density polyethylene liner, two layers of geonet drainage material, and a geotextile filter fabric. Cover soil placed above the filter fabric was 18 inches to 2 feet thick. Leachate collected in the unit is currently pumped to the Waterloo sanitary sewer.

SWMU-1 was closed on November 15, 1989. This unit was also graded and capped. Unit closure included regrading existing waste areas; construction of a 2-foot-thick compacted clay liner; construction of a passive gas vent system with risers; installation of a polyvinyl chloride geomembrane, geonet, and geotextile; construction of a perimeter drain tile system; construction of a 3-foot-thick soil cover and a ½-foot-thick vegetative cover layer. Both SWMUs are formally closed under RCRA and are currently in post-closure care.


EPA is proposing the following corrective measures to address hazardous waste in place:

EPA proposes containment as a presumptive remedy for the SWMUs. The containment corrective measure would be the existing engineered caps on the units. Presumptive remedies are preferred technologies or response actions for sites with similar characteristics. Selection of presumptive remedies is based on patterns of historical corrective measures selection practices, EPA’s scientific and engineering evaluation of performance data on corrective measures implementation, and EPA policies.

EPA is proposing the final remedy of long-term groundwater monitoring and maintenance, in addition to containment and institutional controls. Inspection, maintenance and repairs of the caps are necessary to ensure their effectiveness in the containment of hazardous wastes disposed of in the landfills, and to determine if the institutional controls are preventing damage to the caps and restricting residential use of the site or other uses that would expose receptors to hazardous waste or hazardous constituents.

FOR MORE INFORMATION: EPA encourages the public to review the Administrative Record and comment on the draft permit. Comments or requests should be submitted by August 4, 2014. 

Guidelines for Commenting:

A public hearing has not been scheduled, but will be held if there is sufficient public interest. Requests for a public hearing must be made in writing to the EPA contact at the address listed above, and must state the nature of issues to be raised at the hearing. EPA will evaluate any request and hold a formal hearing if EPA determines that a hearing will contribute to the decision-making process by clarifying significant issues affecting the draft permit or remedy.

EPA will make the final permit decision and final remedy selection only after the public comment period ends and all comments are reviewed. EPA may modify the draft permit or remedy based on any new information and comments from the public.

Individuals may write to the EPA contact below to join the mailing list. Joining the mailing list will allow an individual to receive any updated information directly throughout the permitting process. If you have questions or want to receive further information about the mailing list, please contact:

Emily Albano
Office of Public Affairs
U.S. EPA Region 7
11201 Renner Blvd.
Lenexa, KS 66219
Phone: 913-551-7860
Toll-free: 1-800-223-0425
Email: albano.emily@epa.gov

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