Prior to 2008, portions of remains that could neither be tested nor identified, and portions of remains later identified that the [family or other representative] requested not to be notified of (requesting that they be appropriately disposed of) were cremated under contract at a civilian crematory and returned to [Dover]. This policy began shortly after September 11, 2001, when several portions of remains from the Pentagon attack and the Shanksville, Pennsylvania, crash site could not be tested or identified.

These cremated portions were then placed in sealed containers that were provided to a biomedical waste disposal contractor. Per the biomedical waste contract at that time, the contractor then transported these containers and incinerated them. The assumption on the part of [Dover] was that after final incineration nothing remained. A [Dover] management query found that there was some residual material following incineration and that the contractor was disposing of it in a landfill. The landfill disposition was not disclosed in the contractual disposal agreement.